ML20083B005

Application for Amends to Licenses DPR-24 & DPR-27, Consisting of TS Change Request 172,modifying TS Section 15.4.1, Operational Safety Review

ML20083B005
Person / Time
Site:	Point Beach
Issue date:	05/02/1995
From:	Link B WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20083B009	List: ML20083B005 ML20083B010
References
CON-NRC-95-030, CON-NRC-95-30 VPNPD-95-045, VPNPD-95-45, NUDOCS 9505110232
Download: ML20083B005 (7)

Text

,

A' c Wisconsin 1 Electnc POWER COMPANY 231 W Mictag rt PO Bcm 2046. Mdwoukee, WI 53201-2046 (414)221 2345 ,

VPNPD-95-045 10 CFR 50.4 NRC-95-030 10 CFR 50.90 i May 2, 1995 Document Control Desk U. S. NUCLEAR REGULATORY COMMISSION  ;

Mail Station P1-137 Washington, DC 20555 Gentlemen:

DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATIONS CHANGE REOUEST 172 MODIFICATIONS TO TECHNICAL SPECIFICATIONS SECTION 15.4.1

" OPERATIONAL SAFETY REVIEW" POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.4 and 50.90, Wisconsin Electric Power Company (Licensee) hereby requests amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2, respectively, to incorporate changes to the plant Technical Specifications. This proposal revises Technical Specifications Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests of Instrument Channels," of Section 15.4.1, " Operational Safety Review," by deleting the Radiation Monitoring System (RMS) surveillance requirements, changing the Containment High Range Radiation surveillance requirements, and adding Main Steam Line Radiation surveillance requirements. Marked-up Technical Specifications pages, a safety evaluation, and the No Significant Hazards consideration are enclosed.

DESCRIPTION OF CURRENT LICENSE CONDITION Technical Specification Section 15.4.1, " Operational Safety Review," specifies that calibration, testing, and checks of analog channels and testing of logic channels shall be performed as detailed in Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests of Instrument Channels." Item 25 of this table specifies requirements for the Containment High Range Radiation monitors. Item 36 specifies requirements for the Radiation Monitoring System (RMS) which includes Main Steam Line Radiation monitors. Radioactive effluent monitoring instrumentation surveillance requirements are specified in Section 15.7.4, " Radioactive Effluent Monitoring Instrumentation Surveillance Requirements," according to Note 7 of Table 15.4.1-1.

~  ;

9505110232 950502 ^

PDR ADOCK 05000266 - y0 p PDR

% _3 %,  % ;

I

- . i Document Control Desk May 2, 1995 i Page 2 l

DESCRIPTION OF PROPOSED CHANGES i The test requirement for line 25, " Containment High Range  ;

Radiation," of Table 15.4.1-1 will be changed from monthly to I quarterly.

The channel description of line 36 of Table 15.4.1-1 will be changed from " Radiation Monitoring System" to " Main Steam Line Radiation." The check, calibration, and test frequencies will be changed to each shift, each refueling, and each quarter respectively; the same as that for the Containment High Range Radiation monitors.

Note 7 of Table 15.4.1-1 will be deleted since it was only needed to qualify the Radiation Monitoring System channel description.

Numbering of remaining notes within the table will be adjusted for this change.

BASIS AND JUSTIFICATION The Radiation Monitoring System includes post-accident radiation i monitors, radioactive effluent monitors, area monitors, and process monitors which are not included in the Radioactive '

Effluent Technical Specifications (RETS). Post-accident monitoring equipment and RETS required effluent monitoring  !

equipment must be treated separately due to their heightened radiological safety importance. The post-accident radiation monitoring instrumentation (containment high range and main steam line radiation monitors) will be left in Table 15.4.1-1. The radioactive effluent monitoring instrumentation surveillance requirements are specified in Section 15.7.4. Since the area and non-effluent process monitors do not provide a function satisfying the criteria in the NRC Staff's Final Policy Statement on Technical Specification Improvements (58 FR 39132), inclusion in the Technical Specifications is not necessary.

Area and non-RETS required process monitors are used to monitor  ;

general plant conditions and will still be subject to surveillance requirements. However, since the instrumentation to be removed does not include RETS required effluent monitors or FSAR Table 7.7-2 " Post-Accident Monitoring Instrumentation" monitors, inclusion in the Technical Specifications is not necessary. Area and non-RETS required process monitors provide no safety related  !

function, are not used for accident mitigation, and are not included in the Westinghouse owners Group Standardized Technical

Document' Control Desk May 2, 1995

, Page 3 Specifications with the exception of post-accident monitoring instrumentation. Checks, tests, and calibrations for these instruments will continue to be performed under existing PBNP' procedures.

Main Steam Line Radiation monitors are required for post-accident

. monitoring and are listed in line 36, " Radiation Monitoring.

' System," of Table 15.4.1-1. These monitors will be_ explicitly

. listed when the rest of~the RMS is removed from the table.

Technical Specifications Tables 15.7.4-1, " Radioactive Liquid s

. Effluent Monitoring Instrumentation. Surveillance Requirements,"

and 15.7.4-2, " Radioactive-Gaseous Effluent Monitoring Instrumentation Surveillance Requirements," require that the radioactive effluent monitoring instrumentation be tested quarterly. The test frequency for the post-accident radiation monitoring instrumentation (containment high range and main steam line monitors) will be changed from monthly to quarterly. The instrumentation is checked for operability every shift and calibrated every refueling outage. Changing to quarterly testing will provide consistency with the above mentioned surveillance requirements which eliminates the test frequency discrepancy between the radioactive affluent monitoring instrumentation and the equally important post-accident radiation monitoring instrumentation.

Changing the post-accident monitoring instrumentation test frequency from monthly to quarterly will reduce wear and tear on associated equipment as well as control operator distractions as Health Physics personnel will'not be in the-control room to perform tests as often. Also, removing area and non-RETS required process monitors from the Technical Specifications will allow future surveillance requirement changes to be made for these instruments without the need for Technical Specification Change Requests.

We have determined that the proposed changes do not involve a significant hazards consideration, authorize a change in the types or total amounts of any effluent release, or result in any significant increase in individual or cumulative occupational radiation exposure. We therefore conclude that the proposed changes meet the requirements of 10 CFR 51.22 (c) (9) and that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared.

~ ! *. . , .

-Document control. Desk' '

-May 2,.1995

.Page'4- .

l Ulease contact us if there are any questions.

. Sincerely, B Li k Vice President Nuclear Power Enclosures cc: NRC Resident Inspector NRC Regional Administrator Subscribqd and sworn to before me this ,Qh4 day of Inn, , 1995.

4 ,

rim oi ,a hut ka i et.rypublic,stateofWisconsin  ;

M Commission expires I D-Sn- % .

JSG/cmo 1

i l

l

Technical Specifications Change Request 172 safety Evaluation INTRODUCTION Wisconsin Electric Power Company (Licensee) is applying for amendments to facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant (PBNP), Units 1 and 2. The proposed changes will revise Technical Specifications Table 15.4.1-1,

" Minimum Frequencies for Checks, Calibrations, and Tests of Instrument Channels," of Section 15.4.1, " Operational Safety Review," by deleting the Radiation Monitoring System (RMS) surveillance requirements, changing the Containment High Range Radiation surveillance requirements, and adding Main Steam Line Radiation surveillance requirements.

EVALUATION RMS instrumentation which does not serve as Radiological Effluent Technical Specification (RETS) required effluent monitoring equipment or FSAR Table 7.7-2 " Post-Accident Monitoring Instrumentation" equipment, does not warrant inclusion in the Technical Specifications. The affected monitors do not perform any function as defined in the NRC Staff's Final Policy Statement on Technical Specifications improvements (58 FR 39132) requiring inclusion in the Technical Specifications.

The removal of area and non-RETS required monitors from the Technical Specifications will not compromise the safe operation of PBNP. The surveillance program currently in place will continue to ensure the reliability of these monitors. This change is consistent with the guidelines of the Westinghouse Owners Group Standardized Technical Specifications. Appropriate changes to support the removal of these requirements are made to Technical Specifications Table 15.4.1-1.

Radioactive effluent monitoring instrumentation surveillance requirements are given in Technical Specifications Section 15.7.4,

" Radioactive Effluent Monitoring Instrumentation Surveillance Requirements," which is part of the Radiological Effluent Technical Specifications (RETS). Tables 15.7.4-1, " Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements," and 15.7.4-2, " Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements," indicate the functional test requirements for the radioactive liquid and gaseous effluent monitoring instrumentation. Every RETS required effluent monitor is required to be tested quarterly.

The RETS required effluent monitors are important because they monitor and control environmental releases. There is no technical reason for the post-accident RMS monitors to be tested on a shorter time interval considering they are of equal importance.

' CONCLUSION

+ The proposed changes result 7in the PBNP Technical! Specifications being consistent with the Westinghouse Owners Group Standardized Technical Specifications:by providing' requirements for the post-accident monitoring instrumentation while eliminating general requirementa for RMS surveillance.

The proposed changes will bring Point Beach Technical Specificatione:in line with the Westinghouse Improved Standard  ;

Technical Specifications by eliminating general RMS surveillance '

requirements while maintaining post-accident monitoring instrumentation in the Technical Specifications. The proposed change in post-accident RMS surveillance requirements will eliminate the current inconsistency in the Technical Specifications by having all radiation monitoring system testing done quarterly. This change will not affect the continued safe operation of Point Beach Nuclear Plant.

I I

l Technical Specification Change Request 172 No Significant Hazards Consideration In accordance with the requirements of 10 CFR 50.91 (a), Wisconsin Electric Power Company (Licensee) has evaluated the proposed changes against the standards of 10 CFR 50.92 and has determined that the operation of Point Beach Nuclear Plant, Units 1 and 2, in accordance with the proposed amendments, does not present a significant hazards consideration. The analysis of the requirements of 10 CFR 50.92 and the basis for this conclusion follows.

Operation of this facility under the proposed Technical Specifications changes will not create a significant increase in the probability or consequences of an accident previously evaluated. The radiation monitors being removed from Table 15.4.1-1 are not directly involved with mitigating an offsite release in the case of an accident. The surveillance requirements for monitors which would measure and mitigate such a release are listed in Technical Specifications Section 15.7.4, " Radioactive Effluent Monitoring Instrumentation Surveillance Requirements."

Post-accident radiation monitors will still be included in Table 15.4.1-1. Monitors to be removed include area and non-RETS required process monitors. These are necessary to monitor plant conditions and will still be subject to surveillance requirements. i The removed monitors do not have any safety function with regard l to radioactive releases. Therefore, the consequences of an l accident will not be increased. The radiation monitors are not  !

initiators for any accident analyses in the FSAR, therefore, the probability of an accident previously evaluated is not increased. l Operation of this facility under the proposed Technical Specifications changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

There is no physical change to the facility, its systems, or its operation, therefore, a new or different kind of accident cannot occur.

Operation of this facility under the proposed Technical Specifications changes will not create a significant reduction in a margin of safety. The removal of much of the RMS equipment from the Technical Specifications will not affect the surveillance program already in place. The change in test frequency for the post-accident monitoring instrumentation will not have a significant impact on the margin of safety. Test frequencies continue to meet acceptable standards. RETS required effluent monitors, which are of prime importance due to their release mitigation function, are checked quarterly in accordance with Technical Specifications Section 15.7.4, " Radioactive Effluent Monitoring Instrumentation Surveillance Requirements." Therefore, the margin of safety is not reduced.

1