ML20040H025

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Informs That 811116 Proposed Amend to Tech Specs Re Establishment of Redundancy of Decay Heat Removal Capability During All Modes of Operation Is Unacceptable.Application Should Be Modified
ML20040H025
Person / Time
Site: Point Beach  
Issue date: 01/22/1982
From: Clark R
Office of Nuclear Reactor Regulation
To: Burstein S
WISCONSIN ELECTRIC POWER CO.
References
TAC-42114, TAC-42115, NUDOCS 8202170019
Download: ML20040H025 (3)


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RAClarkDISTRIBUTION Docket Nos. 50-266 My DOCKET FILE 8

NRC PDR and 50-301 in! / g NSIC f31 TERA Mr. Sol Burstein ORB #3 Rdg Executive Vice President 1"

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Dear Mr. Burstein:

/,,s T lb On November 16, 1981 you submitted in respdriktmgu i '

at 14, Iypi HMer an amendment request proposing Technical Specificat-1 changes for Point Beach Units 1 and 2 to establish redundancy of decay heat removal capability during all modes of operation. He have revieeed your request and find it unaacepp h54ef6cr th the following reasons:

1.

The action statements of proposed Technical Specification 15.3.1.

A.2.b(3) should apply for the conditions described in proposed Technical Specification 15.3.1A.2.a(4) as well. It is not clear from your request that you intend this requirement to apply for reactor coolant temperatures above 1400F.

2.

Technical Specification 15.3.1.A.2(2) for Point Beach Units 1 and 2 presently requires that "One 5 team generator shall be. operable whenever the average reactor coolant temperature is above 3500F".

In our August 14, 1981 letter we acknowledged that this specification meets in part the requirements for redundancy of decay heat removal, Your application for Technical Specification changes has proposed climinating this requirement which in effect would remove decay heat removal redundancy requirements for reactcr coolant temperatures above 3500F. We consider this an oversight on your part and as discussed with and approved by members of your staff during telephone o conversations we will reinstate this Technical Specification in our amendment.

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3.

The basis for proposed Technical Specification 15.3.1.A.2 states that "A single reactor coolant loop with its associated steam gen-erator or a single residual heat removal loop porvides sufficient heat removal capacity for removing the reactor core decay heat". Point mWh Beach Units 1 and 2 are rated at 1518.5 IG thermal. Table 6.2-7

, 88 nfthePointBeachFFDSARlistsgheheatremovalcapacityofasingle KHR heat exchanger as 24.15 x 10 STU/hr or approximately 0.47% of

,o rated core thermal output. The bases of existing Technical Specification cation 15.3-3 gices the decay heat load 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown from w

'88 100 days at full pwer to be 0.62% rated core thermal output. Thus,

'Q one RilR loop coupled with either another RHR loop or c reactor coolant loop and steam generator well not be sufficient to establish redundancy

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of decay heat removal aapability until the decay heat load has been

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reduced to less than the capacity of a single RHR heat exchanger, pre-embly some period of time in excess of 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> from shutdown following 100 or more da s operation at full pocer.

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4.

The standard Technical Specifications give as one method of decay heat removal a " reactor coolant loop and its associated steam gen-erator and reactor coolant pump". This is to ensure a driv $tig force (reac (reactor coolant pump) exists to ensure adequate thermal mixing.

Qualifications are given in the Standard Technical Specifications for starting starting a reactor coolant punp below 2750F in any reactor coolant system cold leg. Telephone conversations with members of your staff indicate that the reasons the Point Beach Unit 1 and 2 proposed Tech-nical Specifications do not specifically address operability of the reactor coolant lopp and reactor coolant pump (with associated qualifying statements for louteemperature starting) are because Point Beach Units 1 and 2 have no reactor coolant loop isolation valves and that the units are capable of removing up to 10% rated core tucreal output by natural circulation.

In a situation where the two steam generators are relied upon as the redundant mehbods for decay heat removal, show that (1) either adequate thermal mixing will take place for temperatures down to 1400F cold leg temperature (lower limit of the proposed Technical Specificazions whereby steam generators are considered as a method of decay heat removal) or that (2) reactor vessel void formation and possible core thernal dam-age will not take place prior to the establishment of sufficient thermal driving head to initiate natural circulation flow.

5.

In reviewing your proposed change to Technical Specification 15.3.3.A-2 we have discovered an item deserving of clarification, for all instances where a redundant component is taken out of service to conduct repairs, the other conponent is tested to demonstrate operability prior to in-itiating repairs. The exception is when an accumulator is isolated to ccnduct check valve leakage.te'stsPWe: request 1that2you' add wordsito this section of the Technical Specifications to the effect that "one accum-ulator isslation valve is checked open prior to shutting of the other accumulotor isolation valve.

6.

We also suggest that you clarify the wording of proposed Technical Specification 15.3.A.2.b(3) by replacing the words "... in the reactor decay heat load..." which is uncontrollable, to "... in reactor coolant system temperature..." which is controllable. Further, since you have dev developed the concept of RH2 loop in proposed Technical Specification 15.3-1, you could combine Technical Specifications 15.3.3.A.1(d) and (e) into a single requirement, e.g; Two residual heat removal loops are operable".

We request that you modify your application for amendment dated Movember 16, 1931 to address the a!:ove concerns. Your response is requested within 30 days receipt of this letter.

The reporting requirements of this letter affect fewer than 10 respondents; there-fore OM3 cicarance is not required under P.L.90-511.

[')DFMligned by Robert A. Clark Robert A. Clark. Chief Operating Reactors Branch #3 0IV15IUU u6 L I Lu.i:e IU j omen..cc:...krv. ice. List.....

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e Wisconsin Electric Power Compary cc:

Mr. Bruce Churchill, Esquire Mr. William Guldemond Shaw, Pittman, Potts and Trowbridge USNRC Resident Inspectors Office 1800 M Street, N. W.

6612 Nuclear Road-Washington, D. C.

20036 Two Rivers, Wisconsin 54241

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Joseph Mann L.ibrary 1516 Sixteenth Street Two Rivers, Wisconsin 54241 Mr. Glenn A. Reed, Manager Nuclear Operations Wisconsin Electric Power Company Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, Wisconsin 54241 Mr. Gordon Blaha Town Chairman Town of Two Creeks Route 3

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Two Rivers, Wisconsin 54241 Ms. Kathleen M. Falk General Counsel Wisconsin's Environmental Decade 114 N. Carroll Street Madison, Wisconsin 53703 U. S. Environmental Protection Agency Federal Activities Branch Region V Office

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Regional Radiation' ATTN:

Representative 230 S. Dearborn Street c

Chicago, Illinois 60604 Chairman Public Service Commission of Wisconsin Hills Farms State Office Building Madison, Wisconsin 53702 Regional Administ'rator Nuclear Regulatory Commissio.n, Region III Office of Inspection and Enforcement 799 Roosevelt Road Glen Ellyn, Illinoir 60137 O