ML030800251

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10 CFR 50.59 Screening 2002-0463, Entitled, Temporary Changes to Pc 43 Part 5, Service Water to Auxiliary Feedwater Pump Line Flush Monthly, Including Procedural Temporary Modification Tm 02-47/48.
ML030800251
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 11/04/2002
From:
Nuclear Management Co
To:
Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0095, SCR 2002-0463 PBF-1515c, Rev 1
Download: ML030800251 (8)


Text

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) Vcrfv SCR number on all pages Page I Title of Proposed Activity: Temporary Changes to PC 43 PART 5, SERVICE WATER TO AUXILIARY FEEDWATER PUMP LINE FLUSH MONTHLY, Including Procedural Temporary Modifications TM 02-47 I 48.

Associated Reference(s) #: Bechtel Drawings M-207, Sht. IA and M-217, Shts. I and 2 SCR 99-0374-01 SW to AFW Pump Suction Line Flushing Using Fire Hoses OM 3.26 Use of Dedicated Operators; NP 8.4.17 PBNP Flooding Barrier Control NP 8 4.16 PBNP High Energy Line Break Barriers / Vent Paths Service Water Flow Analysis, Modification MR 89-046*1B SCR 2002-0223 Changes to PC 43 Part 5, 01 70, I-SOP-CC-00 I, and 2-SOP-CC-00 I Calculation 2002-0041.

Prepared by: Scott Manthei ,a Date. oo 7-.,

Name (Print) Signa re Reviewed by: -)5- /6,~~L _ ae i~

Name (Print) Signature PART 1 (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 proposed activity is a temporary change to PC 43 PART 5, to support an alternate method of flushing the Service Water (SW) Supply Lines to the Auxiliary Feedwater (AFW) Pumps, using fire hoses per Procedural Temporary Modifications TM 02-047 and TM 02-048. Presently, flushing of the supply lines is accomplished with the use of a permanent piping arrangement. Prior to this arrangement, flushing was accomplished with the use of a fire hose which was connected to the supply lines and then run through the AFW Room Door, AFW Tunnel Door, through the Unit I Turbine Hall and back to the forebay (SCR 99-0874-01). The temporary change will again rely on the use of a fire hose, which will now be directed to a large tank in the Unit I Turbine Hall Truck Bay.

The present flushing configuration consists of a permanent piping arrangement that taps into the SW supply line at its lowest point, just prior to the "AFW Suction from SW Control Valves", and returns to the SW Return Header. For the Turbine Driven AFW Pumps (1/2P-29), the piping arrangement consists of 2-1/2 inch pipe, a sight glass (1/2 SG-4338), and an isolation valve (I/2SW-775). A small drain line, containing valves IAF-25A and 2AF-63A is located at the lowest point of the 2-112 inch line, just prior to the sight glass. The temporary change to PC 43 PART 5, directs that the supply and flush lines be drained to a level that allows for the removal of the sight glass, which is installed between two unions. Once the sight glass is removed, a 2-1/2 inch fire hose will be connected with the appropriate fittings (rated for Service Water pressure or higher), and routed through AFW Room Door-321. through AFW Tunnel Door-19, and then to a large tank in the Unit I Turbine Hall Truck Bay. The vertical section of pipe, above the position of the sight glass which will be removed, with valve I/2SW-775 at the end has been seismically evaluated per Calculation 2002-004 1. Additional vertical and horizontal support will be added, prior to the removal of the sight glass, to ensure that the SW System remains seismically qualified.

Additionally the flooding concern, introduced by routing the fire hose to the tank in the 8' Elevation of the Turbine Hall, is bounded by "Catastrophic Flooding" in NEM-89-183, Evaluation of NRC Information Notice No. 8749: Deficiencies In Outside Containment Flooding Protection, March 14, 1989. This lead to the installation of back-draft danpers (Modification MR 89-046"B) in the Turbine Buildings to relieve flood water. q  % (.

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Re'eren.-e NP 5 I S

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) Verify SCR number on all pas Page 2 Presently PC 43 PART 5, Rev. 9 establishes Initial Conditions of: SLr Service Water Pumps are Operable OR Five Service Water Pumps are OperableAND all 4 CCW HX inlet and outlet blowdown volies are shut. During the proposed activity, Six Service Water Pumps must be Operable AND all four Component Cooling Water Heat Exchanger Inlet and Outlet Blowdown Valves are SHUT. This creates a conservative, bounding condition to ensure that the Service Water Flow Analysis limitations, as ensured by T/S 3.7.8 Service Water System and TRIM 3.7.7 Service Water System, are NOT challenged.

Service Water is also used as the normal cooling water source for the pump bearings, which will be isolated. The alternate bearing cooling source, Fire Water, will also be isolated. During the proposed activity, the associated Turbine Driven AFW Pump (112P-29), will be declared Out of Service and TSAC 3.7.5 B will be voluntarily entered A Level 3 Dedicated Operator will be assigned to secure flushing by shutting SW-1 13 / SW-134 as directed by the DSS in accordance with OM 3.26, in the event of any significant leakage, if AOP-9A, SW System Malfunction is entered, or if SW needs to be aligned to the suction of one of the other AFW Pumps Appropriate Security Measures will be taken and Fire rounds will be established. The requirements ofNP 8 4.16 PBNP High Energy Line Break Barriers / Vent Paths and NP 8.4.17 PBNP Flooding Barrier Control will be met.

1.2 Search the PBNP Current Licensing Basis (CLB) as follows: Final Safety Analysis Report (FSAR), FSAR Change Requests (FCRs) with assigned numbers, the Fire Protection Evaluation Report (FPER), the CLB (Regulatory) Commitment Database, the Technical Specifications, the Technical Specifications Bases, and the Technical Requirements Manual. Search the ISFSI licensing basis as follows: VSC-24 Safety Analysis Report, the VSC-24 Certificate of Compliance, the CLB (Regulatory)

Commitment Database, and the VSC-24 10 CFR 72212 Site Evaluation Report. Describe the pertinent design function(s),

performance requirements, and methods of evaluation for both the plant and for the cask/ISFSI as appropriate. Identify 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 Technical Specifications for the Service Water System [T/S 3.7.8 (Service Water (SW) System)] and the Auxiliary Feedwater System [T/S 3.7.5 (Auxiliary Feedwater (AFW) System], their associated Bases, TRMs, and the CLB were all surveyed for relevant information regarding the proposed activity. The following documents were found to contain pertinent information:

The use of Service Water as the long-term source of water to the suction of the Auxiliary Feedwater Pumps when the Condensate Storage Tank is not available is described in the following documents:

- FSAR Section 6.2 (Safety Injection System)

- FSAR Section 7.4.3 (AFW Pump Trip on Low Suction Pressure)

- FSAR Section 9.6 (Service Water System)

- FSAR Section 10.2 (Auxiliary Feedwater System)

- FSAR Section 14.1.10 (Loss of Normal Feedwater)

- FSAR Appendix A.5 (Seismic Design Analysis)

- FSAR Table A.6-1 (Shared System Analyses)

- SER 90-0005 (Station Blackout)

- Technical Specifications Bases 3.7.5 (Auxiliary Feedwater (AFW) System)

- Technical Specifications Bases 3.7.8 (Service Water (SW) System)

- TRM 3.7.7 (Service Water System)

- FPER Rev. I Page 99 (Mechanical Support)..

- GL 89-13 (Progrhm Document)

- VPNPD-90-027 (Response to GL 89-13 Safety Related Service Water Problem Point Beach Nuclear Plant)

- Appendix C License Condition for DPR-24 Amendment Number 174

- Appendix C License Condition for DPR-27 Amendment Number 178

- NEM-89-183, Evaluation of NRC Information Notice No. 87-49: Deficiencies In Outside Containment Flooding Protection, March 14, 1989.

PIIF.I5ISc I,.., I lfl' itfrme Pi' 1 1(f

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) Vcrif SCR number on all p__es Page 3 1.3 Does the proposed activity involve a change to any Technical Specification? Changes to Technical Specifications require a License Amendment Request (Resource Manual Section 5.3.1.2).

Technical Specification Change: []Yes Z No If a Technical Specification change is required, explain wvhat the change should be and why it is required.

14 Does the proposed activity involve a change to the terms, conditions or specifications incorporated in any VSC-24 cask Certificate of Compliance (CoC)? Changes to a VSC-24 cask Certificate of Compliance require a CoC amendment request.

D Yes Z No If a storage cask Certificate of Compliance change is required, explain what the change should be and why it is required.

10 CFR 50.59 SCREENING PART 11 (50.59) - DETERMINE IF THE CHANGE INVOLVES A DESIGN FUNCTION (Resource Manual 5.3.2)

Compare the proposed activity to the relevant CLB descriptions, and answer the following questions:

YES NO QUESTION

[] El Does the proposed activity involve Safety Analyses or structures, systems and components (SSCs) credited in the Safety Analyses?

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

[D 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?

0] El Does the proposed activity involve CLB-described SSCs or procedural controls that perform functions that are required by, or otherwise necessary to comply with, regulations, license conditions, orders or technical specifications?

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

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

El 0] Does the activity exceed or potentially affect a design basis hmitfor afissionproduct barrer(DBLFPB)?

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

If the answers to ALL of these questions are NO, mark Part III at not applicable, document the 10 CFR 50.59 screening in the conclusion section (Part IV), then proceed directly to Part V - 10 CFR 72.48 Pre-screening Questions.

If any of the above questions are marked YES, identify below the specific design function(s), method of evaluation(s) or DBLFPB(s) involved The proposed activity affects the use of Service Water as the long-term source of water to the suction of the Turbine Driven AFW Pumps when the Condensate Storage Tank is not available. Service Water is also used as the normal cooling water source for the pump bearings, which will be isolated. The alternate bearing cooling source. Fire Water. will also be isolated. The affected Turbine Driven AFW Pump will be declared Out of Service during the proposed activity.

As well, the Service Water System's capability to provide cooling to Safety Related equipment is also involved. The function of several Doors as HELB, Flood, Fire, and Security barriers, is also included.

I1 51L IIF-IS

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) Verin fSCR number on all padcs Page 4 PART 1I1(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.

111.1 CHANGES TO THE FACILITY OR PROCEDURES YES NO QUESTION

[] [] Does the activity adversely affect the designfinctionof an SSC credited in safety analyses?

[] [] Does the activity adversely affect the method of performing or controlling the designfinction of an SSC credited in the safety analyses 9 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):

The proposed activity will not affect the operation, function, or method of performing or controlling the function of the Service Water System or the Auxiliary Feedwater System, or any other SSC described in the CLB. The flushing activity is allowed by the Service Water Flow Analysis and will not affect the performance of the SW and AFW Systems.

Subsequently, the declaration of one inoperable AFW Pump, (1/2P-29), will be addressed by TSAC 3.7.5.B. In the event of any significant leakage, if AOP-9A, SW System Malfunction is entered, or if SW needs to be aligned to the suction of one of the other AFW Pumps, the dedicated operator would immediately isolate the hose from the SW System. Applicable Fire.

Security, HELB, and FLOOD Barrier procedural requirements, related to propping open doors during the proposed activit),

will be met. The vertical section of pipe, above the position of the sight glass which will be removed, with valve 1/2SW-775 at the end has been seismically evaluated per Calculation 2002-0041. Additional vertical and horizontal support will be added, prior to the removal of the sight glass, to ensure that the SW System remains seismically qualified.

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

YES NO QUESTION 0 D Does the activity use a revised or different method of evaluation for performing safety analyses than that described in the CLB?

El 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 111.3.a and 1II.3.b are [I NOT APPLICABLE.

a. Answer these two questions first:

YES NO QUESTION

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

5 0] Are the SSCs affected by the proposed test or experiment isolated from the facility?

PBF-15I5c p I: ;...o I ic l 'tT Reference %V5 I X

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) VerR SCR number on all pacs Page 5 Ifthe answer to BOTH questions in V.3.a is NO, continue to 1ll.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 lll.3.a above.

Ifthe answer to either question in 111.3 a is YES. then these three questions are El NOT APPLICABLE.

YES NO QUESTION E] Z 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 0] Does the activity utilize or control an SSC in a manner that is inconsistent with the analyses or descriptions in the CLB?

El 0] 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?

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

The proposed activity will not affect the operation, function, or method of performing or controlling the function of the Service Water System or the Auxiliary Feedwater System, or any other SSC described in the CLB. The flushing activity is bounded by the Service Water Flow Analysis and will not affect the performance of the SW and AFW Systems.

Subsequently, the declaration of one inoperable AFW Pump will be addressed by TSAC 3.7.5.B. In the event of any significant leakage, if AOP-9A, SW System Malfunction is entered, or if SW needs to be aligned to the suction of one of the other AFW Pumps, the dedicated operator would immediately isolate the hose from the SW System. The vertical section of pipe, above the position of the sight glass which will be removed, with valve 1/2SW-775 at the end has been seismically evaluated per Calculation 2002-0041. Additional vertical and horizontal support will be added, prior to the removal of the sight glass, to ensure that the SW System remains seismically qualified. Flood concerns are bounded by existing analysis and barriers / flow paths. Finally, applicable Fire, Security, HELB, and FLOOD Barrier procedural requirements, related to propping open doors during the proposed activity, will be met.

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

Check all that apply:

A 10 CFR 50.59 Evaluation is E] required or 0E NOT required.

A Point Beach FSAR change is [3 required or 0 NOT required. If an FSAR change is required, then initiate an FSAR Change Request (FCR) per NP 5.2.6.

-A Regulatory Commitment (CLB Commitment Database) change is [] required or 0 NOT required.. If a Regulatory Commitment Change is required, initiate a commitment change per NP 5.1.7.

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

A Technical Requirements Manual change is El required or 0 NOT required. If a change to the Technical Requirements Manual is required, then initiate a Technical Requirements Manual change per NP 5.2.15.

PBF-1515c

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Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59/72.48 SCREENING (NEW RULE) verify SCR number on a11pag Page 6


10 CFR 72.48 SCREENING-----------...............

NOTE: NEI 96-07. Appendix B. Guidelines for 10 CFR 72.48 Implementation should be used for guidance to determine the proper responses for 72.48 screenings.

PART V (72.48) - 10 CFR 72.48 INITIAL SCREENING QUESTIONS Part V determines if a full 10 CFR 72.48 screening is required to be completed (Parts VI and VII) for the proposed activity.

YES NO QUESTION El E Does the proposed activity involve IN ANY MANNER the dry fuel storage cask(s), the cask transfer/transport equipment, any ISFSI facility SSC(s), or any ISFSI facility monitoring as follows: Multi-Assembly Sealed Basket (MSB), MSB Transfer Cask (MTC), MTC Lifting Yoke, Ventilated Concrete Cask (VCC), Ventilated Storage Cask (VSC), VSC Transporter (VCST), ISFSI Storage Pad Facility, ISFSI Storage Pad Data!Communication Links, or PPCS/ISFSI Continuous Temperature Monitoring System?

E] 0 Does the proposed activity involve IN ANY MANNER SSC(s) installed in the plant specifically added to support cask loading/unloading activities, as follows: Cask Dewatering System (CDW), Cask Reflood System (CRF), or Hydrogen Monitoring System?

5]

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

Primary Auxiliary Building Ventilation System (VNPAB), Drumming Area Ventilation System (VNDRM),

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

El 1Z Does the proposed activity involve a change to Point Beach CLB design criteria for external events such as earthquakes, tornadoes, high winds, flooding, etc.?

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

5 [] Does the activity involve any potential for fire or explosion where casks are loaded, unloaded, transported or stored?

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 VI and Part VII are to be provided. If ALL the questions in Part V are answered NO then check Parts VI and VII as not applicable. Complete Part VIII to document the conclusion that no 10 CFR 72.48 evaluation is required.

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

Compare the proposed activity to the relevant portions of the ISFSI licensing basis and answer the following questions:

YES NO QUESTION 5 [] Does the proposed activity involve cask/ISFSI Safety Analyses or plant/caskIISFSI structures, systems and components (SSCs) credited in the Safety Analyses?

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

5 [] Does the proposed activity involve plant, cask or ISFSI SSCs whose function is relied upon for prevention of a radioactive release, OR whose failure could impact SSC(s) credited in the Safety Analyses?

[ 5] 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?

0 Z Does the activity involve a method ofevalztation described in the ISFSI licensing basis?

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

P iBF-1iS1c P*'.*.t,,,*n I 0410V~li). R leireii.e NI' 5 I

Point Beach Nuclear Plant SCR 2002-0463 10 CFR 50.59172.48 SCREENING (NEW RULE) Verify SCR number on all pates Page 7 Cj Z 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).

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

The SW System provides cooling to the Spent Fuel Pool (SFP) Heat Exchangers. The proposed activity, Temporary Changes to PC 43 PART 5, Service Water To Auxiliary Feedwater Pump Line Flush Monthly, including Procedural Temporary Modifications TM 02-47 /48, is bounded by the Service Water Flow Analysis limitations, as ensured by T/S 3.7.8 Service Water System and TRM 3.7.7 Service Water System; therefore, the SW System's ability to provide sufficient flow to the SFP HXs will NOT be challenged PART VII (72.48) - DETERMINE WHETHER THE ACTIVITY INVOLVES ADVERSE EFFECTS (NEI 96-07, Appendix B, Section B.4.2.1)

(If ALL the questions in Part V or Part VI are answered NO then Part VII is E 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 72.48 Evaluation is required; EXCEPT where noted in Part VII.3.

VII.I Changes to the Facility or Procedures YES NO QUESTION 0 ED Does the activity adversely affect the designfimction of a plant, cask, or ISFSI SSC credited in safety analyses?

El 0 Does the activity adversely affect the method of performing or controlling the designfunction of a plant, cask, or ISFSI SSC credited in the safety analyses?

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):

VII.2 Changes to a Method of Evaluation (If the activity does not involve a method of evaluation, these questions are 0 NOT APPLICABLE.)

YES NO QUESTION El El 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):

PBF7-1 5 tS Relurcn,,e NI' 5 I ."

Point Beach Nuclear Plant SCR 2002-0463 "10CFR 50.59/72.48 SCREENING (NEW RULE) Verify SCR numberon all pag Page 8 VII.3 Tests or Experiments (If the activity is not a test or experiment, the questions in VII.3.a and VII.3.b are Z NOT APPLICABLE.)

a Answer these two questions first:

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

El 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 questions 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 [I 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?

0l 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?

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 ISFSI SSC to perform its intended functions?

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

PART VIII - DOCUMENT THE CONCLUSION OF THE 10 CFR 72.48 SCREENING Check all that apply:

A 10 CFR 72.48 Evaluation is C] 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 E] required or 0 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 0 NOT required. If a 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 E] required or 0)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-I 5154 Reference NI' I8 Rc, irion I 04/03/02