ML20091K342

Tech Spec Change Request 148 to Licenses DPR-24 & DPR-27, Revising Logging Requirements & Clarifying Test Requirements in Table 15.4-1 Re Min Frequencies for Checks,Calibrs & Test of Instrument Channels

ML20091K342
Person / Time
Site:	Point Beach
Issue date:	01/17/1992
From:	Zach J WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091K343	List: ML20091K342 ML20091K351
References
CON-NRC-92-005, CON-NRC-92-5 VPNPD-92-029, VPNPD-92-29, NUDOCS 9201240129
Download: ML20091K342 (9)

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.U.S. NUCLEAR REGULATORY COMMISSION-Document Control Desk Mail: Station P1-137 Washington, D.C. 20555 Gentlemen DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATION CHANGE REOUEST 148 REVISION OF LOGGING REOUIREMENTS' AND CLARLFICATION OF A TEST REOUIREMENT IN-TABLE 15.4.1-1.

-POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 iIn accordance with the requirements of 10.CFR 50.4 and 50.90, JWisconsft Electric; Power Company (Licensee) hereby requests amendments toLFacility_ Operating _ Licenses DPR-24 and DPR-27 for

Point Beach' Nuclear Plant, Units 1 and-2 respectively, to incorporate changes to the plant's Technical Specifications.

Marked-up Technical Spacification pages,.the Safety Evaluation, andLthe Significant Hazards Consideration required.by 10 CFR. '

50.91(a)?are included in the enclosures;to~this change request.

Technical Specifications Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, an a Test of' Instrument- Channels" discusses the check,_ calibration, and test. requirements for forty-three different: instrument-channels. ;ItemsL9, 10, and 12 of this table, namely Analog Rod' Position, Rod' Position Bank Counters, and Steam Generator Flow Mismatch,-are: required to be checked each shift whenever the reactor-is:in a condition otherLthan refueling' shutdown. ;There are no shiftly check requirements for these three instrument channels-when the reactor is in a refueling shutdown, except,that-these channels must be checked prior to starting up if they-have not been checked during the previous shift.

Item 4 of this same table concerns the~ check, calibration, and test requirements.for Reactor Coolant Temperature. A portion of this item requires a monthly test of Overtemperature delta >f function when the reactor is in~a condition other than refueling shutdown. . If the-reactor is in a refueling shutdown, this  ;

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. monthly.testLdoes not'need to be performed t However, it is  :

required; prior:to' starting un if the:-test has not been performed during the1 previous month. The overpower delta T function is z

another portion of Item 4. The problem with overpower delta T is ,

that-the notation:ured in the table-does'not clearly define this

-item's-test requirements.. The actual- ter t requirements for this

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item are identical to those of Overtemptrature delta T, but the table.could be' interpreted to require the Overpower delta T function to be tested-monthly during all plant-conditions.

LWe propose to revise.the: check frequency-for Analog Rod Position,

' Rod Position Bank 1 Counters,-and Steam-Genorator Flow Mismatch.

-;These'three items should be; documented oncesper shift, except Lwhen-theiplant_.is in a cold-or refueling shutdown. . These items will becrequired to1be' checked prior to start-up if they have not been; checked'during the? previous chift.- This check frequency.

- will-be indicatedLby "S" -followed by the number corresponding to any associated; remarks,fif any, and finally "*****"Ein'the

" Check"Lcolumn

of. Table 15.4.1-1. The-five astorisks will >

correspond to the'folloting code description to be added to the bottom of Pages.1,'2, and-4 of. Table.15.4.1-1:  ;

"Not required during periods:of-cold and refueling-shutdowns but must be performed prior to starting up if it1has not been performed during the previous surveillance period."

= Additionally, we propose to add two' asterisks:following "(2)" in theitest' column for Item 4.of. Table 15.4.1-1. This'will indicate that' overpower delta 1T is required to be performed monthly except

'duringsperiodslof refueling shutdown, but it must be performed prior.to starting:upLif it has not been-performed during the previousLmonth. This will. ensure the. test. requirements-for "Overpoweridelta T are-identical-to-the! test requirements-for.

!Overtemperature delta-T.

. Table;15.4.1-1; " Minimum Frequencies'for. Checks, Calibrations, and Test of Instrument Channels" lists the periodicity of checks, '

calibrations, and tests'forfreactor and steamisystem

- instrumentation. -- The frequency of performing checks-of the

-instrumentation'is based on.onsuring'the safe operation of the plant. Calibrations are performed to ensure the presentation and acquisition of accurate plant information. - Testing is performed

.to ensure that the instrumentation continues to perform at its required' level.

The changes to this table that are proposed simply remove the requirement to' log three redundant parameters while the plant is in cold' shutdown and clarify the testing requirements for one

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January 17, 1992 Psge 3 item.- These changes are not safety significant and do not require immediate attention.

Finally,.the changos proposed in this Technical Specification change request do not require an environmental review. These amendments are excluded from a review because they meet the conditions specified in 10 CFR 51.2e..c.9..

Please contact us if there are any questions.

Sincerely,-

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Ja s J. Zach Vich President Nuclear Powcr

.' Enclosures copies to NRC Regional Administrator, Region III NRC Resident Inspector Public Service Commission of Wisconsin

. Subscribed and sworn to-before me thisl'!U day of hw_ , , n. 1992.

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Notary Public,-State of Wisconsin My_ Commission expires on5 E 94

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TEgilNICAL _ P.ECIPICATIOlLCJPEjLlU;QUPST Mi SAFETY EVALUAT191{

4 fi.iRODUCTIQN bisconsin Electric Powor Company (Licenson) has applied for amendments for racility Operating Licenson DPR-24 and DPR-27 for Point Duach Hucione Plant, Units 1 and 2. Thoso amondments propose to remove the Inquirements to check Analog Hod Position, Rod Position Bank Counters, and Steam Generator Flow Hismatch when the reactor is in cold shutdown. These amendmonts additionally propose to clarify tho test requirements for the overpower delta T function to ensure consistency with the toat requirements for the Overtomparaturo delta T function.

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Presently, Table 15.4.1-4, "Minirum Frequencico for Chocks, Calibrations, and Test of Instrument Channels," has difforont ,

check requirements for Analog Hod Position, Rod Position Bank Counters, and Steam Gonoratt.e Flow Mismatch, depending whether tbs-plant is in a cold or a refueling shutdown. In the Technical Specifications, colu shutdown is defincd as a condition when the reacter has a shutdown margin of at least one porcent delta k/k and a reactor coolant te'.tporaturo $200 degroos. The roactor is in a refueling shutdown condition when the reactor is subcritical by at least 5 percent delta k/k and reactor coolant temperaturo ,

is $140 degrees. Two major concerns during any r). ant condition are to be able to monitor for reactivity changes and for the presence of.h heat sink.

Analog Rod Poaltion and Rod Position Bank Counters are two indications used in the monitoring of rod position. Rod position monitoring is intended to alert operators to reactivity changes that could bo-taking placo. Those two indications do not nood to be monitored when the plant is in cold shutdown for the following reasons:

1. The operator is required, by proceduro, to verify that all control rods are fully inserted and that the reactor trip breakers and bypass breakers are open in order to entor a cold shutdown condition. This ensures that all control rods are on the bottom.. It also ensures that no rod motion can occur becaueo all the control Rod Drive Mechanisms (CRDMs) are doonorgized.

2. llaving all rods on the bottom is verified on a regular shift basis by monitoring the rod bottom lights when Rod Position Indicators aro energized.

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TSCR 148 - Safety Evaluation i Page 2 i

3. Source and Intermodlate Rango detectors are constantly nonitored to alert operators to any roactivity changos that may occur. Thoso paramotors are documented on the cold -

shutdown logs.

4. Analog Rod Position and Rod Position Dank Counters aro presently not required to be checked when the plant is in a refueling shutdown condition.

Steam Generator Flou Miamatch indicatos the difference betwoon the rate of feodwater flow into the steam generator and the rato of steam flow out of the steam generator. This indication provides an indication of the presence of a heat sink when the '

steam gonorator is being used as a heat sink for the primary syrtem. This indication 's not roquired to be monitored when the plant is in cold shutdown for the following reasons:

1. The Residual heat Removal System is required to be placed in operation prior to 6ntering cold shutdown. This system is the primary means of decay heat removal when the pl.nt is in a cold or refueling shutdowr4 condition. Paramotors associated with the Residual Heat Removal System are documented on the plant cold shutdown logs.

2. When the plant is in a cold or refueling shutdown condition, reactor coolant temperaturo is' loss than 200 degroos. This means that there can be no steam formation in the steam generator and, thus, no steam flow from the steam gonorator.

Thorofore, Steam Generator Flow Mismatch providos no useful indication when the plant is in either of those two plant conditions.

3. In order for a steam generator to be considered operable for decay heat removal, the Tachnical Specifications require two sources of water to that generator, water lovel indication uin the generator, a vont path to atmosphoro, and the reactor

-coolant.systom-filled and vented so that thormal convection cooling of the coro is possible.

When in cold shutdown, both steam generator lovel and pressure are-logged on a shiftly basis. Monitoring steam generator lovel providos the vator level indication required by the Technical Specifications, and steam generator pressure provides an indication of the presence of a vont path to atmosphere. Thoroforo, those two indications provide information concerning the operability of a steam generator for decay heat removal.

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TSCR 140 - Safety Evaluation l Page 3 The overtemperature dolta T and overpower delta T functions both l provido inputs for protective roactor tripe. Tho overtomporaturo delta T reactor trip providos core protection against a departure from nucleate boiling for all con.binations of pressure, power, coolant temperaturo, and axial power distribution. The overpower delta T reactor trip provents power density anywhero in the coro from exceeding lost of design power density.

Currently both the overtomparature und overpower delta T trips

.are testod monthly except when.the plant is in a refueling shutdown. This tost is then required to bo.porformed prior to starting up if it has not boon performed during the previous month. Tablo 15.4.1-1, Itom 4, is unclear in its notation i because it appears that the monthly test of overpower delta T function is still required to bo performed when the reactor is in Tofueling shutdown.. This can be clarified by making a simple administrativo change to the test frequency portion of Table l 15.4.1-1, Item 4. This will onsure that the test requirements  :

for tho ovorpower dolta T function are identical to the l requirements for the overtomporature delta T function.

CQiLC111 BION 11 In summary, with all control rods on the bottom, Control Rod Drivo Hochanisms doonorgized, and continuous monitoring of the Source and Intermediato Rango detectors, it is not necessary to monitor Analog Rod Position and Rod Position Bank Counters when the plant is in cold shutdown.

Additionally, it is not necessary to monitor Steam Gonorator Flow Hismatch when the reactor is in cold shutdown because paramotors associated with the Residual llont Removal System are monitored.

This system is required to bo placed in operation prior to ontoring cold shutdown. It is also tho. primary means of decay heat removal when the reactor is in a cold or a refueling shutdown. Steam generator level and pressure are also monitored when the plant is in cold shutdown, providing additional indications of the prosence of a boat sink.

Finally, the chango proposed to the test'roquirements for tho-Overpower delta T function is. simply an administrativo chango to clarify the requirements. This will ensure that both tLo Overpower delta T and Overtemperature delta T functions have the same test requirements.

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TECllNICAL_HPECIFICATIOli CjlARGILELQUEST lin "lio SIG111FICAllT llAZARDJi_ CME 1El(ATICIP' In accordance with the requirements of 10 CFR 50.91(a), Wisconsin Electric Power company (Licensoo) has evaluated the proposed changea to tho Technical Specificettions against tha standards of 10 CFP 50.92 and has datormined that the operation of Point Beach lluclear Powar Plant Units 1 and 2 in accordanco 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 thia conclusion are as follows:

1. Operation of this facility under the proposed Technical Specification chango will not create a significant increase in the probability or consequences of an accident previously evaluated. T1.is amendment only removes the requiremont to log Analog Rod Position, Rod Position Bank Counters, and Steam Generator Flow Mismatch when the plant is in cold Shutdown, While in cold shutdown, control rods are fully 1, sorted, the rod power supply is doonorgized, and the reactor trip and bypass breakers are open, ensuring no rod motion. Additionally, the operator is required to monitor Source and Intermediato Rango detectors, as well as rod bottom lights when Rod Position Indicators are energized. Thesa requirements ensure that the plant is constantly being monitored for any reactivity changos.

The presence of a heat sink is ensured by monitoring the paramotors associated with the Residual lleat Removal System.

This system is required to be in operation when the plant is in cold shutdown, and the associated paramotors are monitored on cold shutdown logs. Additionally, Steam Generator Lovel and Pressure are monitored while the plant is in cold shutdown. Those two paramotors provido indications concerning the operability of a steam generator for decay heat removal.

The proposed change to the test frequency for the overpower delta T function is sirply an administrativo change to clarify any confusion associated with the notation. This change will ensure that the test requiremonta for the overpower delta T and overtemperaturo delta T functions are identical. Since there is no physical change to the facility, its systems, or its operation, an increased pr;bability or consequences of an accident previounly evaluated cannot occur.

e TSCR 140 No Significant Hazards Consideration Pago 2

2. Operation of this facility under the proposed Technical Specification chango will not create the possibility of a now or differont kind of accident from any accident previously avaluated. This amondment renovoo the requirement to log the throo paramotors on a onco-per-shift basis when the plant is in cold shutdown. The roanon that thoso paramotors are monitored la to ensure that the operator can detect any reactivity changen, an wall as ensure the prononce of a heat nink.- Monitoring Sourco and Intermodlate Rango detectors and rod bottom lights when the Rod position Indicators are onorgized,'along with paramotors associated with the Ronidual Heat Homoval Syston.,

are sufficient to moot those requiremonto. Stoam Gonorator Lovel and prosauro are also monitored and can provido additional indications concerning the operability of a atoam generator for docsy heat removal.

The proposed chango to the tost frequency for the overpower delta T fur.ction la simply an administrative chango to clarify any confusion annociated with the notation. This .

chango will ensure that the test requirements for the overpower delta T and overtemperaturo dolta T functions are

• identical. Thoro is no physical chango to the facility, itn oystems, or its operation. Thus, a now or different kind of accident cannot occur.

3. Operation of this facility ander the proposed Technical Specification change will not create a significant reduction in a margin of safoty. Under this proposed .

amendment, Analog Rod Position, Rod Position Dank Countora, and Steam Generator Flow Hismatch are not required to be ,

logged when the plant is in cold shutdown. Those paramotors aro monitored to ensure the prosonce of a heat sink and the swift detection of any reactivity changes. The proponco of a heat sink is ensured by monitoring the paramotors associated with the Residual Hoat Removal System. This system is required to be in operation when the plant la in t cold shutdown. Steam Gonorator Lovel and Proasure are also monitored, and provide indications concerning the operability of a steam generator for decay heat removal.

Prior to placing the plant in cold shutdown, the operator, by proceduro, must ensure that all control roda are fully insorted and thnt the reactor trip and bypass bronkors are open. This ensures th6t there can bo no rod motion. In order to detect any roactivity changes, Source and Intermsdiate Rango detectorn are monitored, as well as the

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TSCR 148 No Significant Hazardo Connidoration Page 3  ;

l rod bottom lights when the Rod Position Indicators are onorgized. Monitoring of thoso paramotors lo sufficient to ensure the prosonce of a heat sink and the swift detection of any reactivity changes, Thus, monitoring Analog Rod Position, Rod Position Bank Counters, and Steam Gonorator Flow Hismatch is redundant and is not required when the plant is in cold shutdow".

The proposed change to the tee' ~ , "

delta T function is sim,tiv a4 so <'n/uency for the strativo ovorpower chango to ,

clarify any confusion ase>p. pry with the notation. . This i change will ensure that the e..st requirements for *ho l Overpower dolta T and .Over.torporaturo delta T functions are identical. Since this amo;.;mont does not chango the '

facility, its systems, or its operation, a significant reduction in a margin of natoty cannol occur.

Based on tho above discunnion, Wisconsin Electric Power Company (Licensoo) concludes that the operation of Point Beach Nuclear .

t Plant, Unita 1 and 2 in accordance with the proposed changes doen not result in a significant hazards consideration.

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