ML20116N409
| ML20116N409 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/16/1992 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-92-134 NUDOCS 9211240003 | |
| Download: ML20116N409 (4) | |
Text
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Wisconsin fElectnc POWER COMPANY 231 W Michigan. Po Box 2046 Mdwoukee # $3201
- A)2202345 VPNPD 35 4 i
NRC-9 2-13 4 i
November 16, 1992 D cument Control Desk U.S. NUCLEAR REGULATORY COMMISSIC9 hail Station P1-137 Washington, DC 20555 i
Gentlemen:
DOCKETS50-26G AND 50-301 PUMP AND VALVE JEC"? ICE TEST PROGRAM PUMP AND VALVE RELIEF REOUESTS/ COLD SHUTDOWN JUSTIFICATIONS l
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 1 Your letter dated May 28, 1992, transmitted Inspection Report 92008 (DRS) regarding the Point Beach Nuclear Plant Inservice Test (IST)
Program.
Paragraph 2c of that report recommended that we submit a relief request to address the fact that the Point Beach Nuclear Plant IST Program does not specifically_ include all plant compo-nents which are required to achieve a cold shutdovn condition.
a Rather, our IST Program only requires'the inclusion of those components which are necessary to achieve cold. shutdown under accident conditions, which we consider to fall under the accident mitigation requirements of ASME Section XI.
j.
Although only the scope-statement for valve inservice testing l
(ASME Section XI-1986, IWV-1100, " Scope").specifically refers-to compenents required for achieving cold shutdown,'we interpret the scope statement for pumps (ASME Section XI-1986, IWP-1100, "dcope")
l to imply thin-requirement as well.
We note that, in more recent revisions to the. Code which app]v to the inservice testing of-pumps and valves (ASME OMa-1988, Parts 6'and 10, and later revisions),
both pump and valve subsections outlining program scope' require the F
inclusion of components required to achieve-and' maintain the cold shutdown condition.
Consequently,.the enclosed relief _ request has been written to apply to both pumps and valves, and has been assigned a dual reference number (PRR-22/VRR-36) so that_it is-included'within our IST Program with F th punp relief requests and j
valve relief requests.
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a Document Control Desk November 16, 1992 Page 2 In addition to Relief Request PRR-22/VRR-36, at this time we are also submitting an additional Cold Shutdown Justification (CSJ-35) to document the need for an extended stroke testing frequency for two component cooling water valves, CCW-LW-63 and CCW-LW-64.
As discussed in CSJ-35, quarterly stroke testing of CCW-LW-63 and CCW-LW-64 would require removal of both units' gas strippers from service, which would result in an undesirable increase in reactor coolant radioactivity levels.
Sincerely,
(/v /
Bob Link Vice President Nuclear Power 39 Enclosure ec:
NRC Resident Inspector i
NRC P J onal Administrator, Region III Adelo DiBiasio, Brookhaven National Laboratory i
J
RELIEF REQUEST NO. PRR-22/VRR 36 SYSTEM:
Non System Specific COMPONENTS:
Non Component Specific y
FUNCTION:
Not Applicable SECTION XI REOUIREMENTS:
This subsection provides the rulas and requirements for inservice testing to assese operational readiness of certain Class 1, 2,
and 3 valves (and their actuating and position indicating systems) in light-water cooled nuclear power plants, which are requirc to perform a specific function in shutting down a a
reactor to the cold shutdown condition in micigating the consequences of an accident or in providing overpressure protection (IWV-1100, " Scope").
ALTERNATE TESTING:
The Point Beach Nuclear Plant Inservice Tesc (IST) Program includes components (pumps and valves) uhich are required to perform a specific function in shutting down a reactor to the cold shutdown condition only where those components are utilized under accident conditions. Components which support achievement of cold shutdown under non-accident conditicas, and which are not required to achieve cold shutdown following an accident, are not required to be included in the Point Beach Nuclear Plant IST Program.
BASIS FOR RELIEF:
The Point Beach Nuclear Plant Final Safety Analysis Report (F3AR), Chapter 14, " Safety Analysis," evaluates the safety aspects of either Unit 1 or Unit 2 of the plant, demonstrates that either or both units can be operated safely, and shows that exposures from credible accidents do not exceed the guidelines of 10 CFR 100.
Given that these evaluations 4
demonstrate that the Point Beach units can be operated safely and do not go beyond the plant achieving a hot shutdown condi-tion in any scenario, specifica)1y requiring the inservice testing of components which are required to achieve cold shut-down under non-accident conditions is unwarranted, and does not provide any increase in the level of program quality or safety to the public.-Consequently, relief may be granted under either 10 CFR 50.55a(a) (3) (1), 10 CFR 50.55a(a) (3) (ii), or both.
STATUS:
9 Submitted to the NRC for review and approval November 16, 1992.
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4 COLD SHU2DOWN JUSTIFICATION CSJ-35 4
c I
SYSTEM:
Radwaste Cooling Supply and Return Valves COMPONENTS:
CCW-LW-63 and CCW-LW-64 DRAWING:
PBM-230
.I These normally open valves may be shut to isolate non-essential, l
non-class piping and components associated with the radioactive 1
waste processing system from safety-related sections of the Unit 2 component cooling water-(CCW) system.
Stroke testing theseLyalves on a quarterly basis would force the j
shutdown of both units' gas strippers, which is undesirable when a unit is at power due-to the resultant increased coolant activity-levele.
The increase in gaseous coolant activity would cause a corresponding increase in airborne radioactivity levels-and personnel exposure should the reactor coolant system be j
vented for any reason before returning the gas strippers to service.
Consequently, stroke testing will'br pr,rormed during I
Unit 2-cold ~ shutdowns of sufficient length, as - scribed in ASME l
OMb-1989, Part 10, Subsection 4~.3.2.2(c), "Ene.;ising Require-ments," when losa of the gas strippers has less impact on coolant gaseous radioactivity. levels.
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