ML19261E753

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Responds to NRC Requesting Addl Info Re IE Bulletins79-06A & 79-06A Revision 1.Summary of Owners Group Review of Emergency Procedures & Intended Procedural Revisions Will Be Submitted by 791231
ML19261E753
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 08/23/1979
From: Fay C
WISCONSIN ELECTRIC POWER CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
References
NUDOCS 7908300740
Download: ML19261E753 (11)


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1 Wisconsin Electnc nm comur 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 August 23, 1979 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C.

20555 Attention: Mr. A. Schwencer, Chief Operating Reactors Branch 1 Gentlemen:

DOCKET NOS. 50-266 AND 50-301 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING IE BULLETINS79-06A AND 79-06A REVISION 1 P0 INT BEACH NUCLEAR PLANT. UNITS 1 AND 2 Attached are responses to the request for additional infomation regarding IE Bulletins79-06A and 79-06A Revision 1 as requested by your letter of August 3,1979. The attached infomation responds, item by item, to the nine action areas listed in the request.

As noted in the response to Item 2 of the attachment, the review of emergency procedures currently being conducted by the Westinghouse Owner's Group is expected to be completed by mid-October 1979. Following the receipt of the procedural guidelines resulting from that review, we will prepare a sumary of the review results and draft modifications to the Point Beach emergency procedures which are indicated by the review results. This summary of the review results along with our intended revisions to the Point Beach procedures will be provided to you by December 31, 1979.

The schedule for implementing the revisions to the procedures and completing operator training will depend upon the extent of involvement dastred by your staff regarding these procedural revisions.

If your review of our modified procedures is required, we will not implement the revised procedures or revise operator training program:. responding to modified procedures until your review is complete.

y 7an 3\\ 79 08300Td

Mr. Harold R. Denton, Director August 23, 1979 We believe that this schedule provides for the proper application of administrative procedures and established safety reviews to ensure ; e continued safe operation of the Point Beach Nuclear Plant.

Very truly yours, I

C.' l j "f C. W. Fay, Director Nuclear Power Department Attachments

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ATTACHMENT RESPONSES TO THE REQUEST FOR ADDITIONAL INFORMATI0U AS A RESULT OF STAFF REVIEU 0F PREVIOUS RESPONSES TO BULLETINS79-06A AND 79-06A (REVISION 1)

POINT BEACH NUCLEAR PLANT, UNITS 1 ANE 1 DOCKET NUS. 50-266; 50-301 The items below are numbered to correspond to the Bulletin action items.

2.

Provide a date for completion of your review.

Provide a summary of the results including revisions to operating procedures.

In addition, evalu-ate the completeness of your current 2.b. response following completion of your overall review.

Also identify all instrumentation which aight be used in void recognition; summarize the review results and actions taken with regard to the natural circulation mode of operation and identify any aids provided to the operators to detect voiding conditions.

Discuss instrumentation available to confirm that natural circulation is occurring, and actions prescribed to enhance natural circulation.

RESPONSE

Wisconsin Electric Power Company is a member of the Westinghouse Owner's Group which expects to complete its review of emergency procedures by mid-October, 1979. A sunmary of the review results and Wisconsin Electric's intended revi-sions to procedures will be provided to the NRC by December 31, 1979.

The summary will provide the results of our review of the previous Item 2.b.

response, as well as a review and discussion of instrumentation and operator action related to recognizing void conditions and establishing natural ci rculation.

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4.

Discuss whether containment isolation allows running of the reactor coolant punps (RCP).

If this is prevented, discuss manual actions that would be needed to permit RCP operation.

RESPONSE

Containment isolation does not prevent operation of reactor coolant pumps at Point Beach.

The seal water injection lines utilize check valves to provide the containment isolation function and the component cooling water isolation valves to the reactor coolant pumps are not automatically actuated. The seal water return is isolated upon containment isolation causing seal water return flow to be directed to the pressurizer relief tank. The current NRC position on reactor coolant pump operation, as stated in IE Bulletin No.79-06C, requires that all operating reactor coolant pumps are to be tripped immediately upon receipt of a reactor trip and initiation of safety injection caused by low reactor coolant system pressure. At present, the Point Beach administrative controls require that the reactor coolant pumps be tripped upon reactor trip and initiation of high pressure safety injection caused by low reactor coolant pressure.

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Prepare and confirm that you have implemented procedures which identify 6.

those plant indications which an operator may use to determine that a PORV is open.

RESP 0!iSE A review of the actions taken relative to IE Bulletin 79-06A Item 6 have con-firmed that the special order described in the response to Item 6.b. has been However, the initial special order concerned only operator action to issued.

manually close and isolate the PORV when RCS pressure is reduced to below the It has since been revised and setpoint for normal automatic valve closure.

reissued to include the response to Item 6.a. which identifies those plant

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indications which are available to the operator for determination of an open Those plant indications and operator actions will be included in the PORV.

revised procedures consistent with the schedule stated in Item 2 above. -

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8.

With regard to your reviews of alignment, requirements, and procedures controlling manipulation of safety-related valves, submit a summary of the results of the review and any revisions found necessary.

Confirm that the proper position of all safety-related valves has been reviewed --

both procedurally and actually. Confirm that proper valve positions are verified by actual inspection periodically. Also confirm that you have reviewed plant procedures and have revised them as necessary to ensure that locked safety-related valves are subjected to periodic surveillance.

Submit a summary of the results of the review.

RESPONSE

The methods employed at Point Beach to insure the safety-related valves are correctly positioned have been in effect for many years. Periodic reevalua-tions of the plant administrative centrols and procedures have been made when implementing new requirements such as ASME Code Section XI and Appendix J.

These projects have resulted in a number of additional procedures to insure that the Point Beach administrative controls are complete. A re-review of these areas, as required by Bulletin 79-06A, has been made and no abnormalities have been found. One additional administrative control has been added per Item 5 below.

This review confirms that proper valve positions have been and are verified by actual monthly inspections.

The administrative systems used at Point Beach are summarized below:

1.

At the end of each refueling outage, complete valve lineups are made on all safety related systems. These lineups are required by procedure OP-1A, " Cold Shutdown to Low Power Operation".

2.

The ASME Code Section XI requires testing of specified pumps and valves.

The Point Beach test procedures verify that the valves and pumps are properly positioned at the completion of each test.

3.

In addition to the above, the position of all manual valves which are accessible and which if malpositioned would prevent the opera-tion of a safety system are checked on a monthly basis.

These valves are, if practicable, locked in their required position with a non-reusable seal lock.

4.

On occasion, a specific valve or system is taken out-of-service for maintenance in accordance with the provisions of the Technical Speci fications. Valve lineup checks are used to insure the systens are returned to the proper operating condition before the system is declared operational.

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Continued...

5.

Those safety-related pumps and valves which are provided with remote indications in the main control room are checked each shift by the operator per the appropriate control room log.

This check has always been the practice at Point Beach; however, in the past the checks were not documented.

This practice has been revised to include documentation of the checks on the control room logs.

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9.

Review the resetting of safety injection, containment ventilation isolation and containment isolation to ensure that inadvertent release of radioactive liquids and gases will not occur when reset.

Provide the results of this review.

RESPONSE

Resetting or safety injection, containment ventilation isolation, and cca-tainment isolation will not automatically open any of the fluid paths to or from containment which are isolated upon receipt of the initiating signal.

Containment ventilation isolation valves are currently locked shut and may only be opened during a cold shutdown. Additionally, resetting of safety injection does not reset containment ventilation isolation or containment isolation. Containment isolation can be reset manually only after resetting safety injection. Liquid release via the containment sump cannot occur.

inadvertently since one of the two isolation valves in each drain line is

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normally closed and each valve receives a containment isolation signal upon SI actuation. Also, there is no automatic actuation of the containment sump.

An operator is required to hold the valve control switch in the open position (spring return to the closed position) while gravity draining of liquid from the containment occurs.

This review ensures that resetting of the above systems will not result in the inadvertent release of radioactive liquids or gases from containment.

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10. a.

Explain what administrative proced.res are in effect to prevent a con-tainment air cooler or auxiliary f sedwater pump from being removed from service when a redundant cooler of pump is already out of service.

(In lieu of an actual test of the redundant component, operability should be verified by at least a visual inspection of the status of the redundant component.)

c.

Identify the level of authority required for removing and returning systems to service.

RESPONSE

a.

Any time safety-related equipment is taken out of service, it is identi-fied on the main control board by the appropriate isolation tags ind it is listed on the out-of-service status board, one per unit, located by each unit's control board in the control room.

This administrative control has been adequate in the past and we believe it

.equately insures that the requirements of the Technical Specifications are, met at all times.

c.

Licensed supervisors on shift are the only personnel authorized to remove a system from service.

The Duty Shift Supervisor (SR0 license) is the only individual authorized to allow the return of a system to service.

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Confirm that you have revised your procedures as necessary to ensure NRC notification within one hour of the time the reactor is not in a controlled or expected condition of operation. Note that your Emergency Plan and Technical Specifications may not cover all the situations requiring noti-fication. Also provide the date on which procedural revisions were or are expected to be complete.

RESPONSE

Specific guidance has been given to the appropriate management personnel, Duty and Call Superintendents, Group Heads and the Duty Shift Supervisors, to insure the proper notification to the NRC is made.

This guidance is not new, the initial memo being written October 17, 1975.

Revisions to this reflecting the knowledge of Three Mile Island and the NRC bulletin were issued on July 20, 1^79, and August 7,1979.

The permanent changes to the Emergency Plan in this area are being incorp, orated as part of the annual review.

These changes will be accomplished by October 1,1979, and fully implemented by November 1,1979.

The activation criteria for the PBNP Gnergency Plan and the actual reactor control and conditions of operation as compared to the Technical Specifications provide the basis for situations requiring NRC notification.

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12.

Review and discuss in more detail the available methods fcr removing hydrogen from the reactor coolant system and provide the schedule for incorporating these methods into appronriate procedures.

RESPONSE

The basic method for removing hydroge.. from the reactor coolant system is to strip the reactor coolant letdown of all gas via the letdown gas strippers.

The gas so removed can be put back into the reactor coolant system or discharged to waste gas decay tanks.

The procedural controls for degassing are specified in procedure OP-50, " Chemical Addition and Control".

It is noted that the use of this system is curtailed in a safety injection condition by the containrent isolation signal; however, the system could be used at such time as the contain --

ment isolation signal is reset.

The existing procedures are. considered to be sufficient for removal of hydrogen from the reactor coolant system and no'revi-sions are planned, l2 )

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