ML20091G359

Suppls 910301 Application for Amends to Licenses DPR-24 & DPR-27,consisting of Change Request 143 to Clarify Spec 15.3.4.C.2 Re AFW Pump Testing

ML20091G359
Person / Time
Site:	Point Beach
Issue date:	12/06/1991
From:	Zach J WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091G361	List: ML20091G359 ML20091G672
References
CON-NRC-91-143 VPNPD-91-431, NUDOCS 9112130361
Download: ML20091G359 (4)

Text

,o r i r

Wisconsin Elecinc POWER COMPAhY l

• 231 w M,chon Fo iku Nu MAe-e #!.3?ct (4141221m VPNPd 4 31 NRC-P1- 14 3 December 6, 1991' Document Control Desk U. S. NUGLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:

DECI&Tf9_E(1-266 AND 50-301 SUPPLEMENT TO TECHNICAL SPECIFICATION CHANGE REQ MST 143 AUXILIARY FEEDWATER PUMP TESTING POINT BEACH HUCLEAR PLANT. UNITS 1 AND 2 In a letter dated March 1, 1991, Wisconsin Electric Power Company, '

Licensee for the Point Beach Nuclear Plant, requested an amendment to Facility operating Licenses DPR-24 and DPR-27 which would revise the Point Beach Technical Specifications to require quarterly testing'of the auxiliary feedwater (AFW) pumps. This amendment application is presently in the process of being reviewed by the NRC-NRR staff.

During a recent review of the AFU Technical Specifications, Mr. Jack Gadzala, the Point Beach resident inspector, questioned the interpretation of Specification 15.3.4.C.2. This specification presents a modification to the-limiting conditions for operation (LCO) for_the.APW pumps during single unit operation. The intent of that specification is to permit one of the three operable AFW.

pumps associated with that unit to bo out of service for a limited period of time. The specification potentially could be

-ints preted, however, to permit both the steam-driven AFW pump and one-of the two motor-driven APW pumps to be out of service at the same time.

Having more than one AFW pump out of service at one time is an undesirable situation because of the arrangement of the shared AFW system at Point: Beach. Details ofithe AFW system are provided in FSAR Section 10.2 and Figure 10.2-5. Each of the two motor driven-pumpsLaupplies rne-of the two steam generators in each unit. Thuc pump P-38A supplies the "A" steam generator'in eacn unit and P-38B supplies the "B" steam generator in each unit. The steam-driven AFW-pumps are unit-specific and supply both the."A" and "B" steam generators in its associated single unit. If both the steam-driven and one motor-driven AFW pump were out of service, only one of the steam generators in the operating-unit could be supplied with r auxiliary feedwater. If the postulated accident which necessitated the initiation of auxiliary feedwater also incapacitated that steam \

generator,-one of the mechanisms for controlling reactor decay heat V\

removal would_then be degraded.  ;

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r Document Control Desk December 6, 1991 Page 2 We are requesting in this supplement to Change Request 143 to clarify r,pecification 15.3.4.C.2 by including the following centence in this specification: "One of the three operable auxiliary feedwater pumps associated with a unit may be out-of-service for the below specified times." Including this sentence in specification 15.3.4.C.2 would be analogous to the same limitation in Specification 15.3.4.C.1 and would remove any question of the misinterpretation of the specification. A revised mark-up of page 15.3.4-2a including this addition is attached.

Submitted as an enclosure to this application is our analysis of this amendment request pursuant to 10 CPR 50.91(a) regarding the issue of no significant hazards considerations. We have concluded that the change proposed in this application does not constitute a significant hazards consideration.

We have also concluded that r!nce this change relates no the clarification of an existin n,acification, the amendment will meet the eligibility critoria fo. <

..tegorical exclusion set forth in 10 CPR 51.22(c)(9). Pursuant to 10 CPR 51.22 (b) no environmental impact statement or environmental assessment need be prepared in connection with the consideration of this amendment application.

We have discussed the basis for this subluittal with Mr. Robert Samworth of your staff and have informed him that we intended to submit this clarification as an addition to our outstanding AFW amendment request. Please contact us if you have any questions concerning this application.

Very truly yours, the g ,.f' c

Jam m J. Zach VicMPresident Nuclear Power Enclosure Copies to: NRC Regional Administrator, Region III NRC Resident Inspector Mr Lannie Smith, PSCW Subscribed and sworn to pefore me this _k'A day of $ w h , 1991.

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_ Notary Pub 3ic, State of Wisconsin My Commission expires 1 /S'. .

l Enclosure No Bignificant Hazards Determination We have evaluated thm change to t"e specifications proposed in the supplement to Change Request 143 in accordance with the requirements of 10 CFR 50.91(a) against the standards for significant hazards considerations in 10 CFR 50.92. This change is a clarification of an existing spec-rication and does not affect any of the accident evaluations .n FSAR Chapter 14. Our evaluation of this change against each of the criteria in 50.92 and the basis that the change involve "no significant hazards" is presented in the following paragraphs.

Critprion 1 Operation of a facility in accordance with a proposed amendme.V, docu not present a significant hazard if it does not result in an increase in the probability or consequences of an accident previously analyzed.

The intent of Specification 15.3.4.C.2 is to perm ., as discussed in 15.3.0, " General Considerations," a temporary relaxation of the single failure critoria, consistent with overa'.1 reliability censiderations, to allow limited time periods during which corrective actions may be taken to restore the AFW pumps to full operability. The proposed amendment to 15.3.4.C.2 serves to clarity that only one of the three operable APW pumps associated with a single unit may be taken o.t of service at one time. This is consistent with the bases and with Specification 15.3.4.C.1 for two-unit operation. The proposed change requires no hardware or procedural change and can be characterized as administrative an nature. Accordingly, this change has no impact on the probability or consequences of previously evaluated accidents since the assumptions for the accidents are not altered and the LCO operability requirements provide rho necessary assurance that the mitigative measures will be availabPs.

Criteri,on 2 Operation of a facility in accordance with a proposed amendment does not present a significant hazard if it cannot create the possibility of an accident different from any previously evaluated.

This change does not result from any physical change or modification to the facility or its operation. The ooerability of equipment necessary for accident mitigation, such as the AFW pumps, is assured by periodic surveillance and testing. The continued availability of that equipment during plant operations is controlled by the limiting conditions for operation. Once operability is established through the successful completion of periodic testing and surveillance, the presumption 12 that the system will function as designed in the accident analyses. Since

r there has been no change to the function, design or cperation of the AFW system, one may conclude that a now or different kind of accident will not result from the propost*4 channes.

Criterion 3 operation of the facility in acc.rdance with a proposed amendment will not present a significant hazard if it does not renult in a significant reduction in a margin of safety.

Under the existing Specification 15.3.4.C.2 one may argue that the specification would permit two AFW pumps to bc out of service during single Lnit operation 'or a restricted period of time.

.iu:h a condition would not satisfy the intent of the specification which is to provide for redundant sources of ,

aux 114ary feedwater to an operating unit at all times. The availability of a single AFW pump for single unit operations would result in a reduction in the margir f saf ety. In that the pronosed change will provide further assuranet that during power operations no more than one AFW pump may be out of servico at any one time, the change may actually be consie.ered to assure the previously assumed margin of safety is availa'ile. Thus the previously accepted margins to safety are not reduced by these changes and it may be concluded that the proposed change does not involve a significant hazar It considerati..n.

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