ML030770750

10 CFR 50.59/72.48 Screening for Renewal of Internals from AF-117 and Upgrade Open Function of AFW Pumps mini-recirc Valves to Safety Related

ML030770750
Person / Time
Site:	Point Beach
Issue date:	10/10/2002
From:	Black D, Chapman R Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0094 SCR 2002-0359-02
Download: ML030770750 (10)

Text

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) Venfy SCR number on all pages Page 1 Title of Proposed Activity: Removal of Internals from AF- 117 and Upgrade Open function of AFW pumps Mini-Recirc Valves to Safety-Related (MR 02-029)

Associated Reference(s) #: SCR 2002-0010-01, SCR 2002-0321 and 2002-0339; MR 01 -144, AF-4007/4014 Backup Nitrogen Supply, MR 02-001, 1/2AF-4002 Backup Air Supply; EVAL 2002-005, Permanent Plant Changes to Address Simultaneous Failure of All AFW Pumps; FCR 02-019; SE 97-085, MR 97-038 AFW Motor Driven Pump Pressure Discharge Valve Modification; Fay Letter to NRC, NRC Bulletin 88-04, Potential Safety-Related Pump Loss, June 28, 1988; NPM 2002-0228, Designation Of Backup Pneumatics For AFW Mini- Recirculation Valves As Safety-Related, NRC 2002-0068, Point Beach Nuclear Plant, Units I and 2 Reply to a Notice Of Violation (EA-02-03 1) NRC Special Inspection Report No. 50-266/01-17 (DRS); 50-301/01-17 (DRS), NRC 2002-0086, Clarification of Reply to a Notice of Violation (EA-02 031) NRC Special Inspection Reports No. 50-266/01-17 (DRS); 50-301/01-17 (DRS)

Prepared by: David Black Name (Print) I &Si(-* Date:

/cii262c Reviewed by: Rob Chapman Date: - - 0 Z Name (Print)

PART I (50.59/72.48) - DESCRIBE THE PROPOSED ACTIVITY AND SEARCH THE PLANT AND ISFSI LICENSING BASIS (Resource Manual 5.3.1)

NOTE: The "NMC 10 CFR 50.59 Resource Manual" (Resource Manual) and NEI 96-07. Appendix B. Guidelines for 10 CFR 72.48 Implementation should be used for guidance to determine the proper responses for 10 CFR 50.59 and 10 CFR 72.48 screenings.

1.1 Describe the proposed activity and the scope of the activity being covered by this screening. (The 10 CFR 50.59 / 72.48 review of other portions of the proposed activity may be documented via the applicability and pre-screening process requirements in NP 5.1.8.) Appropriate descriptive material may be attached.

The scope of this screeninginvolves thefollowing activities associated with MR 02-029:

- Remove internalsfor AF-1 17. the Auxiliary FeedwaterPump Common Mini-Recirc Header Check Valve to prevent a common mode activefaflure in the recirc i etutn header.

- Upgradethe open function for the air-operatedAuxiliaryfeedwaterpump mini-recirc valves (J(2)AF- 4002, AF-4007.AF 4014) to safety-related(also being done by ISTgroup for inservice test procedurechanges underscreenings SCR 2002-0321 and 2002-0339). The check valves upstreamof the AO Vs (1/2AF-114, AF-J15 andAF-116) are already classified as safety related in CHAMPS; they will now have a safery function to open. Inservice test procedure changes to verify the openfunction of the check valves are supportedby screeningsSCR 2002-0321 and 2002-0339.

- The backup nitrogen and airsupply systems installedunder modifications MR 01-144 and MR 02-001 as reviewed under screening SCR 2002-0010-01 now have a safety-relatedsupportfunction to provide a pneumaticsource to open or maintain open these valves (l(2)AF- 4002. AF-4007. AF-4014) in the event of loss of instrument air.

- State in the FSAR (FSAR 7.3, 9.7 and 10.2) and TechnicaiSpecqfcation Bases(S 3.7 5j that (1) the openfunctionforAuxiliary feedwater pump mini-recircvalves (1(2) AF-4002. AF-4007. AF-4014) is safety-related,and (2) the availabilityof a recirculationline downstream of theflow restrictingorifices is requiredfor AFW operability. The line downstream of theflow restrictingorifices is nA safety-relatedsincefailure of the line is conservative. The Bases will indicate that mini-recirculation flowpaths have to be availablefor the AFWsystem to be operable. Specific discussion of the check valves function to open will not be included in the FSAR because it can be inferredfrom the discussion of the AOVs (avoids excessive detail in the FSAR).

PI3F-1515c REC'D OCT 1 1 2002 Revision I 04/03/02 Reercn,.c NP 5 I S

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59172.48 SCREENING (NEW RULE) Verify SCR number on all pages Page 2 A simplified P&ID of the mini-recireheader is shown below To Condensate Storage Tank T-248 From P-38A. P 388. &2P-29 From 1P-29 To Condensate Storage 2-~C-4Tank T-24A EVAL 2002-005 evaluatedpermanent procedure changes that were implemented in response to a condition (CR 01-3595) that was identified where, with aprocedure-directedoperatoraction to controlsteam generatorlevel (which could be accomplishedby reducingflov, through one or more AFWpumps), concurrent with a loss ofinstrument air (which would cause the AFW pumps' mini-recirculationvalves to/ail close), the potentialexistedfor a simultaneousfailureof the multi stage high pressureAFW pumps due to very low or noflow through runningAFW pumps. The procedure changes added instructionsto the operatorsthat if any AFW pump mini-recircvalve/ails shut OR annunciator COI A 1-9, INSTRUMENT AIR HEADER PRESSURE LOW is in alarm, then monitor and maintain minimum AFW flow or stop the affected AFWpump as necessary to control SIG levels. Minimum flow valuesfor each pump were also includedin the procedures. The majority of the changes were associatedwith EOP and ECA foldout pages. The procedures were initially revised as a compensatory measure to support AFWpump operability. The 50.59 evaluationreviewed the procedurechanges as a permanent change to the procedures as describedin the FSAR to confirm consistency with the licensing basis. The permanentprocedure changes restoredthe AFW pumps tofull'operablestatus. .

This evaluation also was the basisforchanges to the FSAR to clarify that the mini-recirculationvalves requireinstrument air to/unction and that either a pump minimum flow is maintainedorpumps are secured if the valve/ails or instrument air is lost (FCR 02-019).

Screening SCR 2002-0010-01 reviewedmodifications to provide backup air sources to allFtVpump minimumflow recirculationvalves These modificationswere an enhancement that reduced the core damageprobabilityfrom a loss of instrument air and increasedthe timefor an operatorto take manual action to override the valves open Instrument air accumulatortanks were installedby MR 02-001for the 1/2P-29 valves (1/2AF-4002), and the existing nitrogen backup system for the MDAFP discharge valves were tied in by MR 01-144/for the P-38AfB valves .AF-4007.AF PointBeach has made an NRC commitment to upgrade the open/unction/orall mini-recircvalves to safety-relatedas stated in NMC letter NRC 2002-0068:

"To furtherimprove the future effectiveness ofthe AFW system by providingadditionalpump protection against low flow, Point Beach is classifying the open/unction ofthe pump recirculation flow control valves, as safety-related This will provide a redundantmethod ofprovidingfor minimum AFW pump flow and consequently, pump cooling. As a result, testing andquality assurance requirementr required/forsafety-relatedfunctionr will be appliedto the open/function ofthese valves As discussedpreviously, internalpump cooling is designed to be providedby minimum forwardflow through the pumps. Classifying the recirculationflow control valves as safety-relatedwill provide greaterassurancethat minimum flow will be availableto provide internalpump cooling. The pneumatic backup supply to the recirculationflow control valves is limiting and therefore Point Beach will also continue to specify operatoraction to manually open these recirculationvalves Similarto other plants, Point Beach has one common recirculationflowpathfromall the AFW pumps to the condensatestorage tanks" The scope of this screening also includes FSAR changes and Technical Specification Bases changes to coincide with the mini-recirculationsafety upgrade described above rev isioI5c Reterncric NP 5 1 8 Revision 1 04/03/02

Point Beach Nuclear Plant SCR 2002-0359-02 Verify SCR nuxnbcr on all pages 10 CFR 50.59/72.48 SCREENING (NEW RULE) Page 3 Requests 1.2 Search the PBNP Current Licensing Basis (CLB) as follows: Final Safety Analysis Report (FSAR), FSAR Change (FCRs) with assigned numbers, the Fire Protection Evaluation Report (FPER), the CLB (Regulatory) Commitment Database, Specifications, the Technical Specifications Bases, and the Technical Requirements Manual. Search the ISFSI the Technical Compliance, the CLB (Regulatory) licensing basis as follows: VSC-24 Safety Analysis Report, the VSC-24 Certificate of Commitment Database, and the VSC-24 10 CFR 72.212 Site Evaluation Report. Describe the pertinent design function(s),

appropriate. Identify performance requirements, and methods of evaluation for both the plant and for the cask/ISFSI as where the pertinent information is described in the above documents (by document section number and title). (Resource Manual 5.3.1 and NEI 96-07, App. B, B.2)

The Auxiliary Feedwater(AFW) system has the followingfunctions describedin the licensing basts:

a. To automaticallystart and ensure that adequatefeedwater is supplied to the steam generatorsfor heat removal duringaccidents which may result in a main steam safety valve opening (Loss of Normal Feedwater - including ATWS, andLoss ofAC to the Station Auxiliaries).

require or

b. To automaticallystart and provideflow to maintain steam generatorlevels during accidents which (Steam Generator Tube Rupture and Rupture.of a Steam Pipe).

result in rapidreactorcoolantsystem cooldown

c. To allow the isolationofall lines to the ruptured steam generator in the SGTR event.

blackout d To provide sufficient feedwater to remove decay heatfrom both units for one hour during a station

- - .-. - C -

- (SBO) event (FDAFPonly)....

72

e. To provide sufficient flow to the steam generatorsto remove decay heat to achieve cold shutdown within hoursfollowing a plantfire (Appendix R).

steam f To withstand a seismic event (i.e., the seismic Class I portions of the system) and to ensure that generator levels are maintainedduring a seismic event.

or hot standby g To provideflow to the steam generatorsduringplant startup andshutdown, and during hot shutdown and when operation of the main feedwater and condensate systems is not warranted conditionsfor chemical additions pumps (1/2AF These modifications affect the operation of the minimum recirculationvalves for the auxiliaryfeedwater 4002 AF-4007, AF-4014). These valves have the following design functions:

to the

1. To isolate the minimum recirculationline to ensure that the auxiliaryfeedwaterpumps deliver the requiredflow SGTR. A TWS, Appendix steam generatorsas needed to support thefollowing accidents or events: LONF, LOA C, MSLB.

R, and SBO.

and to dissipatepump

2. To open to provideflow through the auxiliaryfeedwater pumps to prevent hydraulic instabilities heat.

3. To maintain the pressure boundary integrity of the auxiliaryfeedwater system.

two electric motor-driven FSAR 10.2.2, System Design and Operation.states: "The auxiliaryfeedwatersystem consists of necg.sary_

-........-- pum,,ps; ,'o-stec.m turbi'.e-drivenpumps, pump suction and dischargepiping, atnd-te controls andjzntnrmentoti.on systems, two different sources of power for the for operationof the system. Redundancy is providedby utilising two pumping is categorized as seismic Class I and is designed to ensure pumps, and two sources of watersupply to the pumps. The system that a singlefault will not obstruct the system function."

CLB

References:

FSAR 7.2.3.2- Specific Control and ProtectionInteractions FSAR 7.3.3.4 - Manual AFW Flow Control DuringPlant Shutdown FSAR Section 7.4. 1 - A'ASA C FSAR Section 10 1 - Steam and Power Conversion System FSAR Section 10.2 -Auxiliary Feedwater FSAR Figure10 2-1 fheet I - Bech M-217 Sh. I - Auxiliary Feedwater System FSAR Figure10.2-1 Sheet 2- Bech M-217 Sh 2- Auxiliary FeedwaterSystem FSAR Section 14. 1. 10 - Loss of Normal Feedwater FSAR Section 14 1. 11 - Loss ofAlI AC Power to the StationAuxiliaries FSAR Section 14.2.4 - Steam Generator Tube Rupture FSAR Section 14 2.5 - Rupture ofa Steam Pipe FSAR Appendix A I - Station Blackout FCR 02-019 FPER 5 2 2 - Safe Shutdown Systems and Equipment PBF-IS15c Reference" NP 5 I S Reviston I 04/03/02

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) Verfy SCR number on all page Page 4 FPER 5.2.5.2.3 -Auxiliary FeedwaterPump Room Tech Spec 3.7.5 - Auxiliary Feedwater Tech Spec Bases B 3.7.5 - Auxiliary Feedwater NRC 2002-0068, PointBeach NuclearPlant. Units I and2 Reply to a Notice Of Violation (EA-02-03.l) NRC Special Inspection Report No. 50-266/01-17 (DRS); 50-301/01-17 (DRS)

Specifications require a 1.3 Does the proposed activity involve a change to any Technical Specification? Changes to Technical License Amendment Request (Resource Manual Section 5.3.1.2).

Technical Specification Change : E] Yes 0 No is required.

If a Technical Specification change is required, explain what the change should be and why it in any VSC-24 cask 1.4 Does the proposed activity involve a change to the terms, conditions or specifications incorporated VSC-24 cask Certificate of Compliance require a CoC amendment request.

Certificate of Compliance (CoC)? Changes to a E]Yes ED No be and why it is required.

If a storage cask Certificate of Compliance change is required, explain what the change should 10 CFR 50.59 SCREENING (Resource Manual 5.3.2)

PART 11 (50.59) - DETERMINE IF THE CHANGE INVOLVES A DESIGN FUNCTION questions:

Compare the proposed activity to the relevant CLB descriptions, and answer the following YES NO QUESTION credited in the 0 E] Does the proposed activity involve Safety Analyses or structures, systems and components (SSCs)

Safety Analyses?

Z E] Does the proposed activity involve SSCs that support SSC(s) credited in the Safety Analyses?

[ El Does the proposed activity involve SSCs whose failure could initiate a transient (e.g., reactor trip, loss of feedwater, etc.) or accident, OR whose failure could impact SSC(s) credited in the Safety Analyses?

"DdE- he proposed activity involve CLB-described SSCs or procedural cuntrou6"that perform furrctions that are or technical required by, or otherwise necessary to comply with, regulations, license conditions, orders specifications?

E] 0 Does the activity involve a method of evaluation described in the FSAR?

El [] Is the activity a test or experiment? (i.e., a non-passive activity which gathers data)

El [] Does the activity exceed or potentially affect a design basis limitfor afission product barrier(DBLFPB)?

(NOTE: If THIS questions is answered YES, a 10 CFR 50.59 Evaluation is required.)

the 10 CFR 50.59 screening in the If the answers to ALL of these questions are NO. mark Part III as not applicable, document Questions.

conclusion section (Part IV), thin proceed directly to Part V - 10 CFR 72.48 Pre-screening function(s), method of evaluation(s) or DBLFPB(s)

If any of the above questions are marked YES, identify below the specific design involved.

the auxiliaryfeedwaterpumps

1. The AF- 117 check valve has an implicitfunction to open to allow minimum recirculationflowfrom in the licensing basis, other than that the to return to the condensatestorage tank(s). There is no direct discussion of thisfunction valve appears in FSAR Figure 10 2-'i.

PD F-1515c Reterence NP 5 1 S Rcvision I 04/03/02

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) Vrfy SCR number on al pag Page 5 A search ofplant documents did not yield any reference to a needfor valve AF-117 to close (orremain closed). The following uses

-were consideredas possiblefunctionsfor the closed position:

a. To prevent backflow of heatinz steam condensate from entering the eini-recirculation return header. Given that the min recirculationheaderis not drainedandremainsfilled with water during andafterpump operation, migrationof heating steam condensate into the header in any significant amounts is unlikely. Further,the plant no longer returns heating steam condensate to the condensatestorage tank because of water quality concerns, and it is extremely unlikely that this plant designfeature will ever be used again. Regardless. this reasonfor preventing backflow does not constitutea licensing basis designfunction.

Therefore thisfunction will not be evaluatedfor adverse effects.

b. To prevent backflow and siphoning of water from the condensate storace tanks throuO AF-4035 in the event that this valve opens due to hitch pressure in the line, or due to a break in the header. The valve's nominal reliefsettingis 50 psi. ForAF-4035 to open. either an event occurs where multiple pumps start with high recircflowratesandpressurize the line, or there is a blockage in the line. The safety-relatedflow restricting orifices in the recirc linefrom each AFW pump limit theflow and pressurefrom eachpump. Further,if the line is blocked either by mispostioningofmanual valves orfailureof the check valve to open, there is noflowpathfor backflow. The only credible way for the headerto break is during a seismic event, in which case waterfrom the condensate storage tank cannot be creditedfor accident mitigation. The prevention ofbackflow from the condensate storage tanks cannotbe considereda licensing basis designfunction. Therefore this function will not be evaluated for adverse effects

2. The minimum recircidlationvalvesfor the auxiliaryfeedwaterpumps (l/2AF- 4002. AF-4007. AF-4014) have the designfunctions to isolate the minimum recirculationline to ensure that the auxiliaryfeedwaterpumps deliver the requiredflow to the steam generatorsas needed to support the mitigationof accidents or events. The proposed activity is to make the openfunctionfor these valves and the associatedpump-side check valves a safety-relatedfunction. The new componentsfor modifications MR 02-001 andMR 01-144 as discussed above were installedsafety-relateddue to their risk significance. These components were classified safety-related based on a PBNP management decision, as describedin NPM 2002-0228. These modifications ensure a safety relatedsupply of air or nitrogen to ensure that the auxiliaryfeedwaterpumps have adequate cooling.

PART Il1 (50.59) - DETERMINE WHETHER THE ACTIVITY INVOLVES ADVERSE EFFECTS (Resource Manual 5.3.3)

If ALL the questions in Part II are answered NO then Part III is [] NOT APPLICABLE.

Answer the following questions to determine if the activity has an adverse effect on a design function. Any YES answer means that a 10 CFR 50.59 Evaluation is required, EXCEPT where noted in Part 111.3.

III.! CHANGES TO THE FACILITY OR PROCEDURES YES NO QUESTION E1 0 Does the activity adversely affect the designfunction of an SSC credited in safety analyses?

I [] Does the activity adversely affect the method of performing or controlling the designfunction of an SSC credited in the safety analyses?

If any answer is YES, a 10 CFR 50.59 Evaluation is required. If both answers are NO, describe the basis for the conclusion (attach additional discussion as necessary):

pumps to

1. The onlyfunction identifiedfor the AF-117 check valve was to open to allow mini-recirculationwaterfrom AFW return to the condensatestorage tank. It has no designfunction to close. Therefore removing the check valve internals has no adverse effict on the openfunction and precludes the valve from failing to open

2. The change in designation of the openfunction of mini-recirculationvalves 1/2,4F- 4002. AF-4007, AF-4014 as safety relatedhas no adverse affect on the valve'sfunction to open or close. The open function was a designfunction desribed in the FSAR. Designatingthe openfunction as safety-relatedrequires addition quality control and testing andshould, therefore, make the open functions of the valve more reliable The necessary backup air/nitrogen supplies were installed as safety-relatedso no additionalphysical changes to the plant are required SCR 2002-0010-01 assessed the installation of these backup pneumatic supplies on the close function of the valves and no adverse effects were identified Therefore there is no adver3e effect on the functions of these valves.

PBF-1515c Rcvision I 04/03102 Rcicrcnce NP 5 1 S

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) vcn-y SCR number on all pages Page 6 3 Changes will be made in the FSAR to state that the open functionfor all Auxiliaryfeedwaterpump mini-recirc valves is safety-related The Technical SpecificationBases will indicatethat the mini-recirculationflowpaihshave to be OPERABLEfor the AFW system to be operable. These changes only reflect the activities discussed above, which have already been assessedand determined that there is no adverse effect on a designfunction FSAR changeswill also be made to reflect the recirculationline downstream of the flow restrictingorifices has a safetyfunction and is requiredfor AFW operability,but the line is not safety-relatedsincefailure of the line is conservative. No physical changes were made to this line. If the linefails. a break or opening will be creat'edwhich may increaseoverallflow through the recirculationline. The service-watersystem is the safety-relatedwatersupplyfor the AFW system. The loss of CST inventory due to the linefailingand recirculationwater spilling only affects the non-safety-relatedwater sourcefor the AFW system. The requiredminimum CST water is basedon the station blackout(SBO) event, SBO is not an event that would cause this line tofail (open). Therefore, based on the above, the licensing basis documents changes do not have an adverse effect on any designfunctions.

111.2 CHANGES TO A METHOD OF EVALUATION (If the activity does not involve a method of evaluation, these questions are El NOT APPLICABLE.)

YES NO' QUESTION

[: El Does the activity use a revised or different method of evaluation for performing safety analyses than that described in the CLB?

[I El Does the activity use a revised or different method of evaluation for evaluating SSCs credited in safety analyses than that described in the CLB?

If any answer is YES, a 10 CFR 50.59 Evaluation is required. If both answers are NO, describe the basis for the conclusion (attach additional discussion, as necessary).

111.3 TESTS OR EXPERIMENTS If the activity is not a test or experiment, the questions in I1.3.a and I1I.3.b are 0 NOT APPLICABLE.

a. Answer these two questions first:

YES NO . QUESTION . . . . .

[E [E Is the proposed test or experiment bounded by other tests or experiments that are described in the CLB?

[E E] Are the SSCs affected by the proposed test or experiment isolated from the facility?

If the answer to BOTH questions in V.3.a is NO, continue to III.3.b. If the answer to EITHER question is YES, then describe the basis.

b. Answer these additional questions ONLY for tests or experiments which do NOT meet the criteria given in 111.3.a above.

If the answer to ei her question in III.3.a is YES, then these three questions are Z NOT APPLICABLE.

YES NO QUESTION El El -Does the activity utilize or control an SSC in a manner that is outside the reference bounds of the design bases as described in the CLB?

El El Does the act.iyity utilize or control an SSC in a manner that is inconsistent with the analyses or descriptions in the CLB?

PBF-1515c Revision I 04/03/02 Rcfcrcnce. NP 5.1 S

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59172.48 SCREENING (NEW RULE) Veify SCR number on all pages Page 7 E] EL Does the activity place the facility in a condition not previously evaluated or that could affect the capability of an SSC to perform its intended functions?

the If any answer in 1Il.3.b is YES, a 10 CFR 50.59 Evaluation is required. If the answers in III.3.b are ALL NO describe basis for the conclusion (attach additional discussion as necessary):

Part IV - 10 CFR 50.59 SCREENING CONCLUSION (Resource Manual 5.3.4).

Check all that apply:

"A10 CFR 50.59 Evaluation is El required or ED NOT required.

"APoint Beach FSAR change is Z required or El NOT required. If an FSAR change is required, then initiate an FSAR Change Request (FCR) per NP 5.2.6.

A P.egf,'tory Commitment (CLB Commitment Database) change is El required or Z NOT required. If a Regulatory..

Commitment Change is required, initiate a commitment change per NP 5.1.7.

Technical Specification Bases is A Technical Specification Bases change is 0 required or [] NOT required. If a change to the required, then initiate a Technical Specification Bases change per NP 5.2.15.

to the Technical Requirements A Technical Requirements Manual change is [E required or [D NOT required. If a change change per NP 5.2.15.

Manual is required, then initiate a Technical Requirements Manual 10 CFR 72.48 SCREENING used for guidance to determine the NOTE: NET 96-07, Appendix B. Guidelines for 10CFR 72.48 Implementation should be proper responses for 72.48 screenings.

PART V (72.48) - 10 CFR 72.48 INITIAL SCREENING QUESTIONS and VII) for the proposed activity.

Part V determines if a full 10 CFR 72.48 screening is required to be completed (Parts VI YES NO QUESTION sr/tanspqr

- -Does the proposed activity involve IN ANY MANNERth~e.dry fuel swt-rge-.c-sk.(s),_tm.*askj SSC(s), or any ISFSI facility monitoring as follows: Multi-Assembly Sealed Basket equipment, any ISFSI facility (VCC), Ventilated Storage (MSB), MSB Transfer Cask (MTC), MTC Lifting Yoke, Ventilated Concrete Cask Links, Pad Data/Communication Cask (VSC), VSC Transporter (VCST), ISFSI Storage Pad Facility, ISFSI Storage or PPCS/ISFSI Continuous Temperature Monitoring System?

in the plant specifically added to support El 1 Does the proposed activity involve IN ANY MANNER SSC(s) installed System (CRF), or cask loading/unloading activities, as follows: Cask Dewatering System (CDW), Cask Reflood Hydrogen Monitoring System?

for plant operation which are also used to El ED Does the proposed activity involve IN ANY MANNER SSC(s) needed support cask loading/unloading activities, as follows: Spent Fuel Pool (SFP), SFP Cooling and Filtration (SF),

System (VNDRM),

Primary Atdiliary Building Ventilation System (VNPAB), Drumming Area Ventilation (Drumming Area Vent RE-105 (SFP Low Range Monitor), RE-135 (SFP High Range Monitor), RE-221 Gas Monitor), PAB Crane, SFP Platform Bridge, Gas Monitor), RE-325 (Drumming Area Exhaust Low-Range Truck Access Area, or Decon Area?

criteria for external events such as El 0 Does the proposed activity involve a change to Point Beach CLB design earthquakes, tornadoes, high winds, flooding, etc.?

for areas of the plant used to support cask El E0 Does the activity involve plant heavy load requirements or procedures loading/unloading activities?

PBF-1 5 1Sc Reference NP 5 1.3 Revision I 04/03/02

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) verify SCR number on all pages Page 8 transported or stored?

El [] Does the activity involve any potential for fire or explosion where casks are loaded, unloaded, the questions in If ANY of the Part V questions are answered YES then a full 10 CFR 72.48 screening is required and answers to the questions in Part V are answered NO, then check Parts VI and VII as not Part VI and Part VII are to be provided. If ALL applicable. Complete Part VIII to document the conclusion that no 10 CFR 72.48 evaluation is required.

FUNCTION PART VI (72.48) - DETERMINE IF THE CHANGE INVOLVES A ISFSI LICENSING BASIS DESIGN (If AL.L the questions in Part V are NO, then Part VI is Z NOT APPLICABLE.)

questions:

Compare the proposed activity to the relevant portions of the ISFSI licensing basis and answer the following YES NO QUESTION El El Does the proposed activity involve cask/ISFSI Safety Analyses or plant/cask/ISFSI structures, systems and components (SSCs) credited in the Safety Analyses?

El El Does the proposed activity involve plant, cask or ISFSI SSCs that support SSC(s) credited in the Safety Analyses?

Ml F Dcs thz Frcpnscd a*tivity involve plant, cask or ISFSI SSCs whose filnction is relied uipon for prevention ofa radioictive release, OR whose failure could impact SSC(s) credited in the Safety Analyses?

E] F] Does the proposed activity involve cask/ISFSI described SSCs or procedural controls that perform functions that are required by, or otherwise necessary to comply with, regulations, license conditions, CoC conditions, or orders?

F] F] Does the activity involve a method ofevaluation described in the ISFSI licensing basis?

[] [] Is the activity a test or experiment? (i.e., a non-passive activity which gathers data)

E] E] Does the activity exceed or potentially affect a cask design basis limitfor afissionproduct barrier(DBLFPB)?

(NOTE: If THIS questions is answered YES, a 10 CFR 72.48 Evaluation is required.)

If the answers to ALL of these questions are NO mark Parts VII as not applicable, and document the 10 CFR 72.48 screening in the conclusion section (Part VIII).

of evaluation(s) or DBLFPB(s)

If any of the above questions are marked YES, identify below the specific design function(s), method involved.

El 9 6-7, FPART- -VIII(7-.I8) --DETET.... LNE WHETHE.R THE ACTIVITY INVOLVES ADVERSE EFFECTS (N Appendix B, Section B.4.2. 1)

(if ALL the questions in Part V or Part VI are answered NO then Part VII is Z NOT APPLICABLE.)

Any YES answer means that a Answer the following questions to determine if the activity has an adverse effect on a design function.

10 CFR 72.48 Evaluation is required; EXCEPT where noted in Part VII.3.

VII. I Changes to the Facility or Procedures YES NO QUESTION in safety

[] F] Does the activity adversely affect the designfunction of a plant, cask, or ISFSI SSC credited analyses?

of a plant, El [] Does the activity adversely affect the method of performing or controlling the design/unction cask, or ISFSI SSC credited in the safety analyses?

the basis for the conclusion If any answer is YES a 10 CFR 72.48 Evaluation is required. If both answers are NO. describe (attach additional discussion, as necessary):

PBIs-15i5c Reference NP 5 1 3 Revision I 04103/02

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) vrify SCR number on all pages Page 9 VII.2 Changes to a Method of Evaluation (If the activity does not involve a method of evaluation, these questions are Z NOT APPLICABLE.)

YES NO QUESTION E] 0l Does the activity use a revised or different method of evaluation for performing safety analyses than that described in a cask SAR?

El El Does the activity use a revised or different method of evaluation for evaluating SSCs credited in safety analyses than that described in a cask SAR?

If any answer is YES, a 10 CFR 72.48 Evaluation is required. If both answers are NO describe the basis for the conclusion (attach additional discussion, as necessary):

- ~ ~)

- ' - - '_ ., - . - . - % , I- - - -

VII.3 Tests or Experiments (If the activity is not a test or experiment, the questions in VII.3.a and VlI.3.b are [ NOT APPLICABLE.)

a. Answer these two questions first:

YES NO QUESTION E] El Is the proposed test or experiment bounded by other tests or experiments that are described in the cask ISFSI licensing basis?

E] El Are the SSCs affected by the proposed test or experiment isolated from the cask(s) or ISFSI facility?

If the answer to both questions is NO, continue to VII.3.b. If the answer to EITHER question is YES, then briefly describe the basis.

b. Answer these additional quebtions ONLY for tests or experiments which do not meet the criteria given in VII.3 a above.

If the answer to either question in VII.3.a is YES, then these three questions are [D NOT APPLICABLE:

YES NO QUESTION El El Does the activity utilize or control an SSC in a manner that is outside the reference bounds of the design bases as described in the ISFSI licensing basis?

E] El Does the activity utilize or control a plant, cask or ISFSI facility SSC in a manner that is inconsistent with the analyses or descriptions in the ISFSI licensing basis?

E] El Does the activity place the cask or ISFSI facility in a condition not previously evaluated or that could affect the capability of a plant, cask, or ISFS[ SSC to perform its intended functions?

I If any answer in VII.3.b is YES, a 10 CFR 72.48 Evaluati6n is required. If the answers are all NO, describe the basis for the conclusion (attach additional discussion as necessary):

PBF-I515c Revision I 04/03/02 Refereni.e NP 5 1 -4

Point Beach Nuclear Plant SCR 2002-0359-02 10 CFR 50.59/72.48 SCREENING (NEW RULE) Verify SCR number on all pages Page 10 PART VIII - DOCUMENT THE CONCLUSION OF THE 10 CFR 72.48 SCREENING Check all that apply:

A 10 CFR 72.48 Evaluation is E] required or Z NOT required. Obtain a screening number and provide the original to Records Management regardless of the conclusion of the 50.59 or 72.48 screening.

A VSC-24 cask Safety Analysis Report change is [] required or Z NOT required. If a VSC-24 cask SAR change is required, then contact the Point Beach Dry Fuel Storage group supervisor.

A Regulatory Commitment (CLB Commitment Database) change is [] required or ED NOT required. Ifa Regulatory Commitment Change is required, initiate a commitment change per NP 5.1.7.

A change to the VSC-24 10 CFR 72.212 Site Evaluation Report is El required or 0D NOT required. If a VSC-24 10 CFR 72.212 Site Evaluation Report change is required, then contact the Point Beach Dry Fuel Storage group supervisor.

PBF- IS I 5c Revision I 04/03/02 Refercnce NP 5 1 3