ML20126G167
| ML20126G167 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/24/1992 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Link R WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 9301040096 | |
| Download: ML20126G167 (3) | |
Text
- - - _
w/Kb (O l
,, [...=(h w<m o w u.
/
+
Nucu An nEGulA10nY COMMisslON r
.m 2
uwwi un h
-l 799 Hoont'vitt stO AO A
G L. E #4 ( L L Y N 4 L L tNoll (40537 s,...../
DEO 2 4 tW2 Docket No. 50-301 Wisconsin Electric Power Company AllN:
Mr. R. E. Link Vice President Nuclear Power 231 West Michigan Street - P379 Milwaukee, WI 53201
Dear Mr. Link:
This confirms the granting of a Temporary Waiver of Compliance (IWOC) for Point Beach Nuclear Plant (PBNP), Unit 2, from the provisions of Technical Specification 15.3.0,
- Limiting Conditions for Operation, General Considerations", and Section 15.3.3, " Emergency Core Cooling System, Auxiliary Cooling Systems, Air Recirculation fan Coolers, and Containment Spray", for a duration of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Oral approval for this waiver was provided at about 9:40 p.m. on December 21, 1992, during a telephone confarence between our respective starts and members of NRR. On December 22, 1992, we received your letter requesting the TWOC. A copy of your letter is enclosed, point Beach, Unit 2, was in Mode 1 at 99% power. Technical Spet;ification Section 15.3.3.A.3.a allowed one residual heat removal (RilR) punip to be out o'l
'ervice, provided the pump was restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Technical Specification 15.3.0 specified that if the above condition could not be met for a critical unit the affected unit shall be placed in the hot shutdown condition within three hours.
On December 21, 1992, you orally informed the NRC that the PBNP Unit 2, Train "A" RilR pump was removed from service, and declared inoperable, at 12:18 a.m., on December 21, 1992, to perform required testing, which revealed that the RilR pump "A" seal leaked in excess of Technical Specification 15.4.4.lV limits and had to be repaired.
You further informed the NRC that due to problems encountered during the maintenance and testing of the pump you-believed that the time required to restore the pump to service would exceed the allowed 24-hour time period.
You requested an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before the unit would be required to comply with the Technical Specification requirement to be placed in a hot shutdown condition.
This waiver was requested to avoid an unnecessary thermal cycle on the unit which would result during a unit shutdown.
I understand that before and during the effective period of time that this waiver of compliance was to be in effect, Point Beach Nuclear Plant had taken and would continue to take the following compensatory and corrective actions:
31005v h*$08M M58do:
1
DE0 2 4 W Wisconsin Electric Power Company 2
1.
All maintenance, testing, and surveillances were suspended on the Unit 2 safeguards systems. This included both emergency diesel generators which supply power to the safeguards buses in both units following a loss of offsite AC power to the buses.
2.
System lineup checks, including a verification of the electrical system lineups, had been perfortned to ensure that Train B" of the RHR system and the safety injection system remained operable.
3.
Train "B" PJiR pump was tested as required by Technical
$3ecification 15.3.3 to ensure operability when it was discovered t1at the Train "A" R}{R pump was inoperable.
We evaluated your oral request, preliminary written evaluations, and your subsequent written request and supporting documentation and determined that they adequately supported your request for a temporary waiver of compliance.
Compensatory measures were taken by the personnel of Point Beach Nuclear Power Plant to ensure the operability of the remaining train of the RilR system.
Only one train of RHR is required following any design basis accident.
Based on the low probability of a design basis accident-requiring RHR occurring during the waiver period and having the "B" RHR train and other emergency core cooling systems capable of placing and maintaining the unit in a safe shutdown conditlon, the Deputy Director of the Division of Reactor Projects, with concurrence from HRR, and mycelf, granted the requested relief on December 21, 1992, at about 9:40 p.m, Subsequently, you infornied us that pump repairs had been completed sooner than expected and RHR Train "A" was declared operable at 12:09 a.m., on December 22, 1992. This was within the 24-hour time period of the Technical Spectifications and therefore this waiver of compliance was not invoked because it was not needed.
Sincerely, path N
A. Bert Davis Regional hJministrator P-
Enclosure:
As Stated MLettached Df stribution
- l 1
pgc 2 4 W Wisconsin Electric Power Company 3
Dillr!hu1193 cc w/ enclosure:
G. J. Maxfield, Plant Manager DCD/DCB(RIDS)
OC/LIOCB Resident inspector, Rill Virgil Kanable Chief Boiler Section Cheryl L. Parrino, Chairman Wisconsin Public Service Commission Robert M. Thompson, Administrator WI Div of Emergency Govt.
Anthony Mendf ola, Technical Assistant, DRP, 1/11, llRR T. E. Murley, f1RR J. 'i. Partlow, f(RR J. W. Roe, t1RR J. fl. liannon fiRR R. t. Wharton, tARR J. Lieberman, OE R. W. Defayette, Elc, Rlll J.11. Sniezek, ED0
I
!)EC-22-921UE 10:39 WIELECTRIOPOWERCO.
FAX WJ. 2213594 P.01
%.nw to nu,maiat mt,mo 7cn l* **"
- f.a -
l Wisconsin w
l Electnc
,. ggyw (p ti, y a
c-POWER COW'ANY y
swe a 231 w eAc gn o t% rm u,me.u g3v ru e a
r V1'NPD-9 2 -3 7 9 14RC-92-145 Ot4cenber 22, 1992 i
Hr. A. Dert Davia, Regional Administrator U.H. NUCLEAR REGULATORY COMMISSION. REGION III 799 Roosevelt Road Glen Ellyn, IL 60137 Onar Hr. navies REQES.T EOR TEMEQEMiLt!Alvrn or CwfifANCE RERuVAluMEhEREMQYAL PUMP OPERABILTTX EOlNT BEACli_t{UCLEAR PLANT, UNIT 2_
The purpono of thin letter is to document the basis for the request-from Winconsin Electric Power company, licensee for the Point Deuch Hucioar Plant Unit 2, for a Regional Waiver of Compliance from the requirements of Point Deach-Nuclear Plant Technical Specification Section 15.3.3.A.3.a for a 12-hour-period.
A 12-hour porlod was requented to allow nufficient time to restorn the Train A Residual-IIoat-Removal, (RHR) pump to an operable status following the dia-covery of excessive anal leakage during routino testing. =The requented vaiver was verbally approved by acabers of your_ staff at 2141 on December 21, 1992.
The pump was subsequently-returned to an operabic status within the allowed cutage time-specified in -
the Technical Specification Limiting Condition of Operation - (LCO).
REqlL1REMENT IQB VMICll A WAIVER WAfi,JEQQES,TEQ The Point Beach Technical specifloationo Gection 15.3.3, " Emergency-Coro Cooling System, Auxiliary Cooling Systems, Air Recirculation -
Fan Coolora, and. Containment Spray,a Specification A. 3, a, -'allowa up to.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during power operation)'.1one of two Residual Heat Removal (RHR_
If the pump is not restorod-to cervien within-the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period,.the-reactor is.placod in hot ehutdown.- Tho basis of the ' specification =is to provido a _ liinited time relaxation from the singic-failure criterion for the RHR pumps --
whilo ' assuring, -with high ro11 ability,1that the.- safety systen vill -
function properly if required to:do so; and.n11ovo sufficient time
~
l l <1 to effect repairn using cafe and proper-proceduros.
l w w e ausm a tem cm e ns
=
=
-- =
l DEC-22-02TUE16:39 91 ELECTRl010WER CO.
FAX 10. 2213594 P. 02 Mr. A. Bort Davis i
December 22, 1992 Page 2 l
CL11CNMTMICElLIdlE11921tD11LLTilfLSITMAT10ll At 0018 on Deccaber 21, 1992, the PDNP Unit 2, Train A RHR pump, P-10A, van removed f rom acrvice and declared inoperabic in order to perform Inocrvico Test 1T-04, "bov llead Safety Injection Dunps and Valves (Monthly)." This tont in performed in accordance w2th the requiremonto in the ASME Boiler and pressure Ve, soc 1 Code, Scotion XI, " Rules for Inocryice Inspection of Nuclear power plant Uyntems and Componnntu." The test in parformed to monitor RHR pump and valvo performanco and verify operability.
During the manen of this test, the pump seal was found to be leaking.perfor-seal loakago stabilized at approximately one-half gallon per minute.
The maximum Inakage from the RER nyctem allowed by Technical
$pocification 15.4.4.IV.D in 2 gallons per hour.
This limits the off-alto radiological consequences of leakage from the R!fR system when oporating in the containment nunp recirculation modo following a design banin accident.
The Train D RRR pump rotating asuunbly and nealo voro replaced during Unit 2 maintenance and refueling outage completed on November 17, 1992.
Extensive tanting of the refurbished punp was perforned in both the injection modo (uuction from the Refueling Water Storage Tank) and residual heat removal riodes following the replacemont, prior to returning the pump to snrvico.
No problomn vara noted at that time.
Since ocal perforcance was acceptable prior to this refurbishment, a decision van madn to replaco the precent rotating acocably and seals with those removed -from the pump during the refueling and maintenance outage.
Thin replacement activity van expected to be completed by approximately 1900 on Docomber 21, 1992, with subsequent post-maintenance tonting to demonstrate operability expected to bn completod by prior to expiration of the 24-hour tco allowed outage timo.
At approximately 2100 on Deccaber 21, 1992, it did not appear that testing of the pump and returning the pump to an operablo status could be completod-prior to expiration of the LCo.
However, testing and any emergent work necessary to correct' possible problems discovered during. testing vara expoeted to be able to be completed within an -additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore,- a Temporary Waiver of Complianco f.vom the requirements of-Technical Specification 15.3.3. A.3.a for a porlod L of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> was requented to allow the return of the pump to service.-
The replacomont of the RHR pump rotating ausembly and seals was completed and the pump testod satisfactorily.
The Train B IurR pump -
Van declared operable at 0009 on December 22, 1992.
This is within
.the 24-hour LCO allowed by tho-Technical Specificationc.
nf.
M c-22-92 TE 10:40 WI ELECTRIC KMER C0.
FAX H0, 2213594 P.03 Hr. A. Hort Davis December 22, 1992 Page 3 e
We had previously discuosed thin situation and the potential for our regucnt for a temporary valver, with the NRC Ronident Innpoca tor, Mr. Nick Jackiv, and other members of the NRC Region III and HRR staf f a at approxinately 1430, on December 21, 1992.
3 C2HITNAAIREt_MEASVRKS compennatory noasures were taken to assure the operability of Train B of the RHR systems during the requested valver pericd.
All maintenance, testing, and surveillancou were suspended on thu Unit 2 safeguards systema.
3hla includes both emergency diesel generatora which supply power to the cafoguards bunen in both units following a loco of of f-uite AC power to the busos.
Sycten lineup chocks, including a verification of the electri-cal nystoa lineupa have boca performed to ensure Train U of the RHR system remaina operable.
The Train D RHR pump was tected to ensure operability whnn it was discovered that the Train A RHR pump van inoperable.
This totting in required by Technical Specification 15.3.3.A 3.a.
EMEIY_GEBIGEAEJdNAyTENTIAL 00HEQVfECJJi The RHR syntem operatoc in the injection mode following a large-break 14cn of Coolant Accident (botA), in the containment nunp recirculation modo following a-LOCA to ensure long-term cooling of the reactor coro, and in the normal ERR cooling mode of_ operation following Steam cenerator Tube pupture_
Break (HSLD) Accidento, as well as norma (ScTR): and Hain steam Line' l decay.heaturemoval:during.
ohutdown and cooldown.
System doni of the RHR systou la needed during.gn is ouch that only one train cach of1thoco nodes of operation.
Compensatory meacurcs, as doacribed above, are being taken to ensure.that one train of the RHR synten romains operable to fulfill these functions.
We have reviewed the prolininary Probablistic' Rick Assessment (PRA) for PBNP to quhntify'the rick associated with the operation"of PBNp Unit ~2 with one train-of RER inoperable, including continued opera-tion for an additional-12 houra in excons of the time allowed by l'
Technical Specification 15.3.3. A.3.a.
Ono train'of RHR inoperabic results in an overall increase in the coro damage frequency,by 83%,
regardiens of the outago time.
Operation with one train is allowed-for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-by the Technical Specifications.-
Operation for an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> beyond the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit results in an overall T-g g
-m4
-a~g-
,p w-g f
,1
L
!>EC-2242 M 10h11 WI Elf 0TR10 F0ER 00.
FM in 2213594 P.04 Mr. A. nort uaviu Docettber 22, 1992 Page 4 core damage f requency of approximately 0.141.
The overall increaso in risk associated with operation 1or ihe additional 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period reques.ted by this temporary waiver in a small fraction of thn overall rial JPfiT I l'1CAU91 LIQ 2.JRLC_ DiWATIO LLDL% IILiialWii The requested time period, 12 hourn, for the Waiver was expected to be sufficient to allow us to couplete repairs and tenting on tho Unit 2 Train A W(R pump and return it to operablo status.
This chort duration also tu conniutent with maintaining overall nyotem uvailability an high as porcible.
14GUITJfAITJMMDfLffdCIDUM10H We have avaluated this temporary extension of the Lc0 allowed out-nge timo for the RHR punsp against the ctandards of 10 CFR 50.92 (c and have dotorminer! that the operation of the FDNP Unit 2 in accor-)
dance with the temporary change involves no uignificant hazards consideration.
Our evaluation and basin for this determination follown.
Operation of a f acility in accordance with a proposed chango does not involve a cignificant barards consideration if it doen not:
Involve a oignificant increase in t.he probability or a.
consoquences of an accident previously evaluated.
An inoperable R101 pump is not an initiating event for any accident evaluated in the PRNP Final Safety Analysis Report (Ff> AR).
An RHR punp out of service for a chort extension of the pronently allowed outage time, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of Technical Specification 1b.3.3. A.3.a vill not increace, the probability of an accident previously evaluated.
Operation with an inoperable RHR purp for a short period of tina may result in a slight increase in the connaquencen of accidents previounty evaluated.
For examplo, in the OYont of a large-break Loss of Coolant Accident (LOCA), a fatlure of the one operable RHR pump would inhibit the long-term cooling of the reactor core.
Likewise, the titeam Generator Tubo Rupturn Accident and the Hain 6tnam Lino Dreak Accident analyzed in the FSAR assumo that the unit in placed on RHR cooling within approximately six honra of tho. accident initiation, thua termi-nating any releano of radioactive teaterial to the attnosphero.
Failure of the operablo FJtR pump following a stean generator tube rupture vould provent placing the reactor on RRR cooling, resulting in an increase in the duration of any radioactive reinase to the atmocphere and, theratore, the potential u
['EC-22 42 TUE 10:41 Kl ELECTRIC POWER C0.
FAX la 2213594 P.05 Hr.
A.
Dort Davis December 22, 19'32 Pago b consequences of the accident.
HoVover, cornpencatory muasurec have been taken to ensure the operability of the remaining train of the PJIR cystem, thereby ensuring oho train RHR 10 availablo following a design basin event to perform its function as analyzed in the TSAR.
Only one train of RHR is required fo11oving any design basic event.
Thoroforo, operation of the PDUP Unit 2 for additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with only one operablo train of RHR will not algnificantly increace the probability of any accident previounly analyzed.
b.
Create the pousibility of a new or dif ferent kind of accident from any accident previously evaluated.
One train of the PJ1R cystem romains available to perform its function as analyzod jn the FSAR.
only one train of the RHR syctem is required to perform all analyzed functions.
There is no change to cystem deuign or function of the RHR nycten, or t he operation of PBNP due to the inoperable PHR train.
There-fore, the ponuibility of a new or different kind of accident f rom any accident previounly evaluated is not created.
c.
Involve a nignificant reduction in a margin of safety.
PhMP Unit 2 will continue to be operated, at all times, in accordance with itn design, procedures, and prescribed oporating limitations.
Therefore, a reduction in a margin of cafety will not occur.
Therefore, operation of PEllP Unit 2 in accordance with this requented tonporary Vaiver from the conditionn of Technical Specification 15.3.3.A 3.a involven no significant hazards connideration.
~
IRVJ RONMrNTE conStqtigtiers operation of PBUP Unit 2 under the conditionn of the requested waiver frot our 1icense requiremonto donc not result in changon to the inntallation or use of the facilitics or couponentn an doneribed in 10 CrR 20, " Standards for Protection Against Radi-at lon," increancs or changes in the types of offluents that may be releaned off-nite will not occur, nor will thero be an increase in individual or cumulative occupational radiation expecure, opera-tion of the unit during the requested waiver period recults in no significant hatards.
Therefore, this request catinfies the categorical exclusion requirements of 10 CFR 51.22 (c) (9).
An environmental accessment or environmental impact staternent required.
is not I
4
I>E6-2242 TUE 16:a2 WI El.E6fR1010WER (C.
FAX in 2213594 P. 06 Mr. A. Dert Onviv December 22, 1992 Pago 6 FTAtL_NQUrlCATIQll Wo vill notify the approprjatn State of Wisconcin of ficials of the requented vaivor by copy of this lotter in accordance with 10 CFR 50.91 (b).
SWERLM COMtiV!11 CAT 10HalHD APPI(QYM.S The PBNP Manager's Supervisory Staff (on-site review commit. tee) met and discussed thic issue at. 1330, on December 21, 1992, and concurred with the decision to rsquest this waiver.
An informational notification van also made to NRR and Region III staff at approximately 1420 on December 21, 1992, to discuss thic situation and the expected need for a frota our licenso require-monts.
We received vorbal approval of this request for a waivor at 2141 on December 21,
- 1992, Forney and other members of Region III and NRR staff.duriieg our telephono c approval was contingent upon the submittal of our request in thic That letter and tnhing the compensatory action described above.
If you havo any questions or desito additional information, pleaso -
contact us.
Sincoroly, f
Oh NL Bob I, ink
/.IrlA/f Vico President Nuclear Power rcx/jg l
NRC Document Centrol Desk cci NRC Resident Inspector Assistant Director for Reactor Projects, NRR Public Servico Commission of Wisconsin
+
)
4 f
v P
WTw f4 7