ML20003B028

Application for Amend of Licenses DPR-24 & DPR-27,submitted as Tech Spec Change Request 65 Incorporating Interim TMI Mods

ML20003B028
Person / Time
Site:	Point Beach
Issue date:	02/04/1981
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20003B029	List: ML20003B028 ML20003B034
References
TAC-12271, TAC-12272, TAC-43742, TAC-43743, TAC-46520, TAC-46521, NUDOCS 8102100239
Download: ML20003B028 (3)

Text

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I WISC0nSin Electnc eom comw 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE. WI 53201 February 4,1981 Hr. Harold R. Denton, Director Office of Huclear Reactor Regulation '

U. S. NUCLEAR REGULATORY COMMISSION-Washington, D. C. 20555 i 1

Dear Hr. Denton:

-00CKETS HOS. 50-266 AND 50-301 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 65 POINT BEACH h0_ CLEAR PLANT UNITS 1 AND 2 In accordance with Part 50.59 of Title 10 of the Code of Federal Regulations, Wisconsin Electric Power Corapany (Licensee) hereby requests amendments to Facility Operating Licenses DPR-24 and DPR-27 to incorporate the foEowing changes and additions to the Technical Specifications for the Point Beach Nuclear Plant U.iits 1 and 2. 'These Technical Specifications were originally requested by the Huclear Regulatory Comission (NRC) in Mr. Darrell G. Eisenhut's letter'to All Pressurized Water Reactor Licensees dated July 2,1980. Licensee responded to that letter on September 18, 1930, with an outline of a policy for requesting Technical Specifications which address Point Beach Nuclear Plant modifications resulting from Licensee's response to the TMI Action Plan items. This request represents Licensee's initial submittal. covering those final and interim THI modifications which have been completed to date.

The attached proposed Tachnical Specification changes and additions have been patterned after the model specification guidance provided with l Mr. Eisenhut's July 2,1980, letter, but maintain the format of the existing I

Point Beach Technical Specifications. A brief sumary of the changes or additions is provided as follows:

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1. Specifications have been added to Section 15.3.1, Reactor-m .[ m Coolant System, to describe limiting conditions for operation 2 _

(LCO) concerning the pressurizer, the pressurizer power fifc operated relief valves (PORVs) and the PORY block valves.

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A discussion of these LCOs has also been added to the basis r for this specification, n

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2. Specification 15.3.5.0 and Table 15.3.5-5 have been added to a

iT - 12 Section 15.3.5, " Instrumentation Systems". These additions AY/ s 8a o 2 2 oo;237

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L Nr. Harold.R. Denton February 4,1981 I

j describe the LC0 for the accident monitoring instrumentation channels listed in the new table. Two new ESF initiation instrument settings have been added to Table 15.3.5-1 to list the setpoints for auxiliary feedwater initiation. Item 16 i fmm Table 15.3.5-2 has been moved to the new Table -15.3.5-5 where it sure properly belongs. Table 15.3.5-3, Emergency t Cooling, has also been expanded to include minimum operable channel requirements for the auxiliary feedwater initiation-circuitry.

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! 3. Table 15.4.1-1 has been changed to include minimum check, calibration, and testing requirements, as necessary, for; the instrumentation added tc the LCOs discussed above.

4. Item 23 has been added to Table 15.4.1-2 to prescribe

necessary surveillance of. the PORY block valves. A sur-

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veillance requirement has also been added as Item 24 to evaluate the integrity of those systems outside contain-i ment used for post design basis accident recovery. Tnis item enforces Licensee's pmvious commitment tow systems

, integrity monitoring program.. -

5. Section 15.6.3, " Facility Staff Qualifications" and . -

Figure 15.6.2-2 " Conduct of Plant Oparations' have been

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l modified to- describe the goalifications and duty status requirements 'for the Duty;1achnical Advisors. , - -

> You will observe that the'LC0 ' specifications-p'ro' pose'd'herein - '

generally require placing the affected unit in a. hot shutdown' status if-

-the-operability of. the equipment cannot be. restored within a specified time period. The model specifications generally require placing the-unit

in a cold shutdown condition if.the equipment cannot be restored in an -

L additional time period. .Licenseelhas:not adopted that 'reconmendation of. '

the. endel spectfication. ' Lice _nsee believes the specifics of the repair or restoration situation will dictate whether placing a unit in cold shut-down is necessary or even desirable.1 Arbitrarily. going to cold-shutdown-4 after a specified time period provides no significant added safety benefit

'and in some cases may make core cooling less assured..

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As discussed in the September 18,-1980 letter, there Lare portions of the model specification which have not been included in these pmposed

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i Technical Specification changes. - Licensee has not included Engineered '

2 Safety Features-(. ,F) Response Tina specifications in this submittal; The-i Point Beach Nuclear Plant was not designed'to aCCoENDdate such testing.:

The NRC has provided no justification for including response time' testing except to pmvide assurance that ESF action functions are completed within? ~

the time limits assumed in the accident analyses. -It is Licensee's opinion- .

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I February 4,1981

. Mr. ' Harold R. Denton that such assurance can be achieved by proper observation of comprehensive ESF system tests, such as' the loss of AC with safety injection sequence testing, conducted each refueling.

Containment isolation valves LCOs have not been included with this proposal . The integrity and operability of containment iso 14tinn e ves are assured by the containment tests presently part of specification 15.4.4 and proposed with a 10 CFR Part 50 Appendix J Technical Specification change request submitted on December 12, 1975. Similarly specifications for auxiliary feed-water pump operability were submitted for NRC consideration by letter dated July 8,1980, and have not been included herein.

Licensee has reviewed the requirements of 10 CFR Part 170.22 regarding the schedule of fees for facility license amendment reviews and approvals. It is our determination that this license amendment application to incorporate-Technical Specification changes and additions resulting from TMI Action Plan implementations represents a Class III Amendment for Facility Operating License DPR-24. The basis for this determination is that all the changes and additions are the result of a single sMety issue namely the TMI Action Plan, they all have acceptability for the ttems clearly identified by NRC positions, and they do not involve significant hazards considerations. The license amendment for Facility Operating License DPR-27 for Point Beach Unit 2 should be a duplicate of the Unit I amendment and is, therefor , a Class I amendment approval. Accord-ingly, we have enclosed herewith a check in the amount of $4,400 as full payment for the amendment reviews and approvals.

Included with this amendment application are proposed revised pages for the Point Beach Nuclear Plant Technical Specifications. These pages have a margin bar opposite the specific changes or additions on each sheet. Licensee has enclosed three signed originals of this amendments application and attach-

-ments. Forty additional copies are being supplied under separate cover. Bhsed on our present schedule for further THI related modifications, as presented in the previously referenced December 23,-1980 letter, Licensee anticipates that the next submittal of TMI related Technical Specification changes and additions for the Point Beach Huclear Plant will be provided to you in January 1182.

Should you have any questions regarding this submittal, please -let us i3ow.

Very truly yours,

> D Sol Burstein Executive Vice President Attachments Subscribed and sworn to before me This 4th day of February,1981.

0Uh! s.Y%u i.

Notary Public, State of Wisconsin -

liy Commission Expires 7dfM Copy to NRC: Resident: Inspector

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