ML20127H422
| ML20127H422 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/14/1993 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20127H426 | List: |
| References | |
| CON-NRC-93-008, CON-NRC-93-8 VPNPD-93-011, VPNPD-93-11, NUDOCS 9301220325 | |
| Download: ML20127H422 (7) | |
Text
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A W!sconsin Electnc
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POWEC COMPANY
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NUCLEAR REG ~ULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:
plCEKTS _50- 266 ANDJ1)-1gJ.
TICHNICrWHEggJylqATJ,qN CHANGE REQUEST 152 EEACIO.IL COOLANLO1EHIETELLIMITS jlQINT BMCJi_RECJMR PLMLT - UNLTS 1 AND ;L In accordance with the requirements.of 10 CFR'50.59(c).and
.10-CFR 50.90, Wisconsin Electric Power Company (Licensee) requests amendments to Facility Operating Licenses DPR-24 and-DPR-27'_for Point Beach Nuclear Plant,. Units'I and 2, respectively. _These amendments serve to clarify reactor coolant chemistry limitations and actions to be taken if the-limits are exceeded.
DESCBillTIQH OF CURRENT - LIQJiNJE COjipITION __
Technical Specification Section 15.3.1.E,." Maximum Reactor Coolant Oxygen and Chloride and Fluoride Concentration for. Power. Opera-t tion,_" specifies the concentration limits for the subject contami-nants in-the-reactor coolant.
The present= specifications define limits for each contaminant' individually and specify actions.to be taken when the concentration limit for oxygen in ccmbination with fluorides cr chlorides is exceeded.
No' action is specified for.
when the limits on any one contaminant'are exceeded.
This speci-fication could be interpreted that exceeding oxygen, chloride, or fluoride limits individually req 2 ires-placing a unit in hot shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />,.
as required by' Technical Specificat. ion Section 15.3, " Limiting Conditions for Operation," Specifications 0.A and_0.B..'Speci-fication 15.3.1.E.3-allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to correct the condition when-
, oxygen concentration limits are o)-ee.'ed in combination with chloride or fluoride concentratior
.its being. exceeded prior to-shutting down a unit.
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Document Control Desk January 14, 1993 Page 2 DIERIPITON OE._FRGP_QSIJLGAliGE E
We are proposing a change to Technical Specification Section 15.3.1.E to separate Specification 15.3.1.E.2 into two L
specifications, 15.3.1.E.2 and 15.3.1.E.3, defining chloride and fluoride limits individually.
Specification 15.3.1.E.3 is then renumbered 15.3.1.E.4 and allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to correct an out-of-specification chemistry condition wnen any one of the limits on L
oxygen, fluoride, or chloride concentrations in the reactor coolant are exceeded individually.
The bas 3s for Specification Section 15.3.1.E have also been clarified as to the required actions for exceeding a limit.
Technical Specification pages with the proposed changas are included as Enclosure 1.
DASll.MD JUSTIFICATLQ11 As explhined in the basis of the existing specifications, oxygen, chloride, and fluoride concentrations in the reactor coolant are maintained within the established limits to assure the functional integrity of the reactor coolant system under all operating
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conditions.
Since an out-of-specification chemistry condition can be corrected, the intent of the specification is to allow a reasonable period of time to correct an out-of-specification condition recognizing the time-dependent nature of any adverse g.
affects arising from oxygen, chloride, or flucride concentrations k
in excess of the limits.
The interpretation of the existing specifications which requires invoking the conditions of Specification 15.3.0, which would require placing the affected unit
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in hot shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of discovery of the out-of-Specification condition, ignores the time-dependent nature of any adverse affects.
The proposed specifications recognize the time-dependent nature of potential adverse affects of out-of-g specification chemistry, thereby meeting the intent of the y
specifications as described in the basis.
Our safety evaluation supporting these changes is included as Enclosure 2.
3 We have reviewed these proposed changes in accordance with the requirements of 10 CFR 50.91 and have determined that operation of the Point Beach Nuclear Plant in accordance with the proposed 3
changes does not result in a significant har.ards consideration.
Our analysis against each of the standards la 10 CFR 50.92 is L
contained in Enclosure 3.
This proposed amendment involves a change to a requirement with respect to the installation or use of a facility component located
-b within the restricted area as defined in 10 CFR 20.
We have determined that the proposed amendments involve no significant increase in the amounts of and no significant change in the types u
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. Document Control Desk January 14, 1993
.Page:3 of'any effluents'that may be released off-site.-
There is no significant increase in individual cumulative occupational radiation exposure.
We have determined that the proposed-amendments involve no significant hazards-consideration.
Accordingly, these proposed amendments meet the categorical exclusion requirement of 10 CFR 50.22(c)(9) from environmental-reviews.
Therefore, we have determined that,-in accordance with:
10 CFR 50.22(b), no environmental assessment or environmental impact statement need be prepared in connection with these proposed amendments.
While the proposed changes are not deemed to be safety significant,_
they-clarify the requirements contained in Technical Specification Section 15.3.1.E.
We request that the_ proposed change be made effective-45 days following issuance of the amendments.
If you have any_ questions concerning the proposed changes, please contact us.
Sincerely,l.,
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Bob Link Vice President Nuclear Power TGM/jg cc:
NRC Regional Administrator, Region III NRC Resident Inspector L.
L. Smith, pSCW Subscribed and s orn before me on 14% ay of gum
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SAFETY EVALUATION
-REACTOR COOLANT.;IIEMISTRY Lilillg H
l Technical Specification Section 15.3.1.E,
" Maximum Reactor Coclant oxygen and Chloride and Fluoride Concentration for Power Operation," defines the maximum allowed concentration of oxygen, chlorides, and fluorides in the reactor-coolant under all
-l operating conditions.
As documented in the basis for this Specification, maintaining oxygen, fluoride, and chloride concentrations within established limits insures the functional integrity of reactor coolant system materials under all normal-operating conditions.
The adverse affects arising from oxygen, chloride and fluoride concentrations in excess of specified y
limits, material degradation due to corrosion, and.other j
mechanisms are time-dependent.
The degradation occurs slowly over time and, therefore, a reasonable period of time to correct the out-of-specification condition is acceptable, l
The present epecification controls oxygen, chloride, and fluoride p
concentrations individually, as well as oxygen in combination L
with either chlorides or fluorides.
A strict interpretation of-Specification 15.3.1.E would allow continued operation for a
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when an out-of-specification condition for oxygen concentration in combination with' chlorides or fluorides occurs.
Exceeding the concentration limits for any one of the contami-nants individually would require entry into Specification 15.'3.0, l
" General Considerations."
This specification directs placing the reactor into hot shutdown within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and cold shutdown within
-l 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Thus, the-time-dependent nature-of the degradation J
mechanisms is not specifically addressed for_ cases whereLany one-o of the contaminant-limits is exceeded.
The proposed revision to Specification Section115.-3.1.E will-
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-allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to correct an out-of-specification 1 chemistry:
1 condition with respect to oxygen, chlorides, or fluorides. - If' the-out-of-specification condition is not corrected within the.
24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the plant would be brought to hot shutdown.-
If the condition is not corrected in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />!from the time.of dis-covery, the reactor is brought to cold shutdown for long-term corrective action.
The 24 and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed for operation at:
l-power and hot shutdown, respectively,-are consistent with ther present specifications.
The 8 and 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> periods specified1for
.l reaching hot and cold shutdown, respectively, are: consistent-with normal plant evolutions.
l-L The adverse effects of an out-of-specification chemistry condition are time-dependent.
The material condition of the' reactorLvessel and internals is monitored by existing inspection programs and procedures which are. expected to detect,any l-
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.A de' gradation regardless of the cause.
Corrective actions will not immediately return the:out-of-specification chemistry-of the reactor coolant-to within normal limits.-
Since an out-of-
.spacification condition.is not an immediate hazard and programs-l are in place to detect any possible degradation, a reasonable period of time should be allowed to return the condition to normal while maintaining plant operation.
The 24-hour period proposed for allowing continued operation while correcting an out-of-specification oxygen, chloride, or fluoride condition is a reasonable period of time and is consistent with the basis-for the present specifications.
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=w 4-NO_ SIGtLUTCANT HAZARDS DETERMINATIQ11 REACTOR CQOLANT CHEMISTRY LIMITS In accordance with the requirements of 10 CFR 50.91, we have evaluated the proposed changes to Technical Specification IS.3.1.E, " Maximum Reactor Coolant Oxygen and Chloride and Flucride Concentration for Power Operation," against the standards in 10 CFR S0.92 and have determined that the proposed anendments do not present a significant hazards consideration.
A proposed amendment does not result in a significant hazards ~
consideration if operation of the facility in accordance with the propoued amendment does not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Create the possibility of a_new or different type of accident from ary previously evaluated.
3.
Involve a significant decrease in a margin of safety.
Our eva]uation against each of the criteria and the basis for the no significant hazards determination follows.
Criterion 1
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Operation of the Point Beach Nuclear Plant in accordance with the l
proposed license amendment does not result in a significant increase in the probability or consequences.of an accident previously evaluated.
The proposed amendment assures that timely corrective action is taken for an out-of-specification reactor coolant-chemistry L
condition.
Control of oxygen, chloride, and fluoride contamL-nants helps insure the long-term integrity of the reactor coolant pressure boundary, fuel clad, and reactor vessel internals.-
Degradation caused by an out-of-specification chemistry condi. tion is time-dependent and therefore does not present an immediate
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- safety concern.
Any degradation will be detected by existing
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inspection programs and: procedures.
It is appropriate to allow a reasonabic, though limited periodlof time, in which to correct the condition while maintaining the plant operating.
Fuel damage.
and loss of coolant accidents, including a steam generator tube L
rupture, are_the principal accidents involving reactor coolant system materials analyzed in1the updated Final Safety Analysis l
Report'(FSAR).
Reactor coolant chemistry is not analyzed. asia I
contributing. factor to these events.
Therefore, the probability-or consequences of any accident previously evaluated will not significantly increase.
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GILL.9Ek9.D Z The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment does not result in or from a physical change to the facility cr a significant change in its operation.
Corrective action will be taken expeditiously to correct any out-or-specification chemistry condition.
Therefore, operation of the facility in accordance with this amendment cannot result in a new or different type of accident than any presently analyzed.
Crit 911gn_1 The proposed amendment does not involve a significant reduction in a margin of safety.-
Controlling oxygen, chlorides, and fluorides within specified limits insures the functional integrity of the reactor coolant system material under all operating conditions.
Degradation due to out-of-specification chemistry conditions is a slow, time-dependent process.
The out-of-specification conditions do not present an immediate concern as to the integrity of the reactor coolant system materials and the fuel cladding.
A limited period of time to correct the condition, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, will not cause significant reduction in the margin of safety, This analysis demonstrates that the proposed amendments to the Point Beach Nuclcar Plant Technical Specifications do not involve a significant increase in-the probability or consequences of a previously evaluated accident, do not create the possibility of a new or different type of accident than any previously evaluated, and do not involve a significant reduction in a margin of safety.
Therefore, operation of the Point Beach Nuclear Plant in accor-f dance with the proposed amendment does not involve a significant hazards consideration.
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