ML20129C065
| ML20129C065 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/19/1996 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20129C070 | List: |
| References | |
| VPNPD-96-069, VPNPD-96-69, NUDOCS 9609240084 | |
| Download: ML20129C065 (5) | |
Text
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Wisconsin Electnc POWER COMPANY 231 W Michgon, PO Box 2046. MAcukee.WI 53201-2046 (414)221-2345 VPNPD-96-069 September 19,1996 D#nment Control Desk U5 :UCLEAR REGULATORY COMMISSION Man Station PI-137 Washington,DC 20555
Dear Sir / Madame:
DOCKETS 50-266 AND 50-301 EXIGENT TECHNICAL SPECIFICATION CHANGE REOUEST 194 LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM POINT BEACH NUCLEAR PLANT. UNITS I AND 2 In accordance with the requirements of 10 CFR 50.59, 50.90, and 50.91, Wisconsin Electric Power Company (WE) requests amendments to Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant, Units I and 2, respectively. The proposed amendments to the Technical Specifications provided by this submittal revise Section 15.3.15. " Overpressure Mitigating System," and Section 15.3.1," Reactor Coolant System." The Basis for Section 15.3.15 is also being revised consistent with the subject amendments. In addition, changes are being made to the Technical Specifications nomenclature to rename the " Overpressure Mitigating System" as the " Low Temperature Overpressure Protection System (LTOP)." This change is being made to be (msistent with the current nomenclature in use at Point Beach and in use by the NRC staff. Marked-up Tect real Specifications pages, a safety evaluation, and a no significant hazards consideration are enclosed. Also enclosed is our Calculation No. 96-0182, Revision I which determined the acceptable LTOP setpoint for Point Beach, in Licensee Event Reports 93-003-00 and 96-003-00, we reported that administrative requirements were to be imposed on operation of reactor coolant pumps and safety injection pumps, respectively, during various plant conditions where LTOP is required to be operable. While the LTOP system remains operable under these administrative controls, these controls place conditions on system operation that are more restrictive than those presently required by the Technical Specifications. Therefore, this TSCR to implement these administrative requirements in the PBNP Technical Specifications is desired prior to the cooldown of Point Beach Unit 2 for its annual maintenance and refueling outage that is scheduled to begin on October 5,1996. We believe that this submittal is timely and could not have been avoided and thus meets the criteria of 10 CFR 50.91 for processing as an exigent change. As such, we request timt this change be processed as an exigent Technical Specification Change Request and be issued before October 5,1996. I DESCRIPTION OF CURRENT LICENSE CONDITION Technical Specifications Section 15.3.15, " Overpressure Mitigating System," specifies the limiting conditions for operation of the overpressure mitigating system when the reactor coolant system temperature is less than i the minimum temperature for performance of the inservice pressure test as defined in Technical Specifications l Figure 15.3.1-1,"Heatup Limitations." Section 15.3.15 also requires that one high pressure safety injection pump I
be demonstrated inoperable whenever the temperature of one or both reactor coolant system cold legs is less than
- or equal to 275'F by verifying that the motor circuit breakers have been removed from their electrical power supply i circuits or by s crifying that the discharge valves from the high pressure safety injection pumps to the reactor i coolant system are shut and that power is removed from their operators. ,
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e l Documerit Control Desk l September 19,1996 l Page 2 l
l l Technical Specifications Section 15.3.1.A.5, " Reactor Coolant System," includes the requirement that when in l the hot shutdown condition that the reactor coolant system temperature should be maintained greater than the I
minimum temperature for performance of the insenice pressure test as dermed in Technical Specifications l Figure 15.3.1-1. This section further states that the requirements of Specification 15.3.15 apply if the temperature i is to be reduced to less than this temperature.
! DESCRIPTION OF PROPOSED CHANGES l Technical Specifications Sections 15.3.1.A.5 and 15.3.15 are being revised to s; ate that the temperature below i which LTOP is required to be enabled is 355'F.
Technical Specifications Section 15.3.15.B.1 curratly requires that when the temperature of one or both reactor coolant svstem cold legs is less than or equal to 2757 that one high pressure safety i* jection pump shall be demonstrated inoperable. Point Beach LER 96-003-00, dated July 19,1996 reported that this Technical Specifications Limiting Condition for Operation (LCO) was nonconservative and that one high pressure safety injection pump should be rendered inoperable whenever the LTOP system is required to be enabled by Specification 15.3.15.A.I. Section 15115.B.1 is being revised to correct this nonconsenative condition by requiring one high pressure safety injo i n pump be rendered inoperable at RCS temperatures ofless than 355 F.
Point Beach LER 93-003-00, dated April 19,1993, reported that because of the difference in pressure between i
the location of the reactor coolant .ptem pressure transmitters and the reactor vessel beltline, administrative restrictions on operation M Mw temperatures with multiple reactor coolant pumps nmning were implemented to ensure that ASME Code %ction XI, Appendix G safety margins are not exceeded. Section 15.3.15.B.3 is being added to implement a LCO restricting operations with more than one reactor coolant pump nmning to reactor coolant system cold leg temperatures of greater than 125'F.
Editorial changes to Technical Specifintions Section 15.3.15 are being made to change the nomenclature to rename the " Overpressure Mitigating bystem" as the " Low Temperature Overpressure Protection System."
BASIS AND JUSTIFICATION 1
1 NRC Branch Technical Position RSB 5-2 provides guidance for establishing the temperature below which LTOP is required to be operable during heatup and cooldown conditions. The enclosed calculation performed 15 WE determined this temperature to be 355 F. Operation with LTOP enabled ensures that the margins of safety : f l ASME Code Senion XI, Appendix G will not be exceeded when reactor coolant system temperature is less than
! 355*F.
l l The design basis of the LTOP system assumes a worst case mass input transient of one high pressure safety l injection pump discharging to the reactor coolant system u hile the system is in a water solid condition with pressure relieved by one power operated relief valve. Hence, whenever LTOP is required to be enabled by Specifications Section 15.3.15. A.1, no more thy. nne high pressure safety injection pump shall be operable. The i temperature that LTOP is required to be enabled u 355*F, which prmides a greater margin of safety with respect to ASME Code Section XI, Appendix G over the present Technical Specifications temperature requirement (275*)
for ensuring that no more than one high pressure safety injection pump is operable. Operation with one safety injection pump out of senice up to this temperature does not decrease the margins of safety for any presiously analyzed accident. l
- Because of the difference in pressure between the location of the reactor coolant system pressure transmitters and the reactor vessel beltline while reactor coolant pumps are running, administrative restrictions on operation at low temperatures with multiple reactor coolan pumps running were implemented in 1993 to ensure that ASME Code ;
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i 4 A bocumen't Control Desk September 19,1996 Page 3 Section XI Appendix G safety mrHns are not exceeded. The enclosed calculation of LTOP setpoints performed by WE determined that with one reactor coolant pump running, the present LTOP setpoint of 425 psig provides acceptable margins as specified in Appendix G of the ASME Code for the Point Beach reactor vessels. Our
- calculation also determined that in order to maintain acceptable margins with respect to the ASME Code Appendix G, reactor coolant temperature must be greater than 125*F in order to run two reacsor coolant pumps with the present LTOP setpoint of 425 psig. Therefore, Technical Specifications Section 15.3.15.B.3 is being i I added to implement a LCO restricting operations with more than one reactor coolant pump running to reactor coolant system temperatures of greater than 125*F.
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We have determined that the proposed amendments do not involve a significant hazards consideration, authorize :
a significant change in the type.s or total amounts of any effluent release, or result in any significant increase in ,
individual or cumulative occupational exposure. Therefore, we conclude that the proposed amendments meet the requirements of 10 CFR 51.22 (c) (9) and that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared.
Pierc ,;,ntact us if you have any questions regarding this submittal.
Sincerely, ;
Link Vice President
- Nuclear Power JRP Attachments cc: NRC Regional Adminis;rator l NRC Resident inspector Public Senice Ccmmission of Wisconsin i
Subscribed and sworn to before me on this 1944 day of sal #x 1996.
A \Lt r_i l No- (public, Satelf Wisconsin I
i My commission expires in .d 7-9 L 1
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1 TECHNICAL SPECIFICATIONS CHANGE RZOUEST 194 i SAFETY EVALUATION INTRODUCTION j 1
Wisconsin Electric Power Company (Licensee) is applying for amendments to Facility Operating Licenses I DPR-24 and DPP.-27 for Point Beach Nuclear Plant, Units 1 and 2. The proposed changes impose more l stringent limiting conditions for operation of the Low Temperature Overpressure Protection System in Technical Specifications Section 15.3.15. Technic il Specifications Section 15.3.1.A.5 is also being revised, consistent with the revised Section 15.3.15.
EVALUATION i
NRC Branch Technical Position RSB 5-2 provides guidance for establishing the temperature below which LTOP is required to be operable during heatup and cooldown conditions. We have determined this !
temperature to be 355T for Point Beach. Operation with LTOP enabled ensures that the margins of safety of the ASME Code Section XI, Appendix G will not be exceeded during low temperature operation.
l The design basis of the LTOP system assumes a worst case mass input transient of one high pressure safety injection pump discharging to the reactor coolant system while the system is in a water solid l condition with pressure relieved by one power operated relief valve. Hence, whenever LTOP is required to
! be enabled by Specifications Section 15.3.15.A.1, no more than one high pressure safety injection pump l shall be operable. When the reactor coolant system'is not cooled and vented to the atmosphere, the
- temperature below which LTOP is required to be enabled is 3557, which provides a greater margin of safety with respect to Appendix G of the ASME Code Section XI over the present Technical Specifications temperature requirement (275T) for ensuring that no more than one high pressure safety injection pump is operable. Operation with one safety injection pump out of service up to this temperature does not decrease the margins of safety for any previously analyzed accident.
It has been determined that with one reactor coolant pump running, the present LTOP setpoint of 425 psig provides acceptable margins as specified in Appendix G of the ASME Code Section XI for'the Point Beach reactor vessels It has also i,een determined that in order to maintain acceptable margins with respect to the ASME Code Appendix G, reactor coolant temperature must be greater than 1257 in order to run two reactor coolant pumps with the present LTOP setpoint of 425 psig. Therefore, Technical Specifications Section 15.3.15.B.3 is being added to implement a LCO restrict ing ooerations with more than one reactor coolant pump running to reactor coolant system temperatures ofgreater than 1257. This prosides acceptable ASME Section XI, Appendix G safety margins for the Point Beach reacter vessels and greater margins of safety over the present Technical Specifications.
l i CONCLUSIONS t
- The proposed revisions provide the same or greater margins of safety over the present Technical
! Specifications and ensure the safe and reliable operation of Point Beach Nuclear Plant, i
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TECHNICAL SPECIFICATIONS CHANGE REOUEST 194 N,LQSIGNIFICANT HAZARDS CONSIDERATION 1
We have evaluated these proposed amendments in 'accordance with the requirements of 10 CFR 50.91(a),
against the standards of 10 CFR 50.92, and have determined that these modifications will not result in a significant hazards consideration. A proposed amendment will not involve a significant hazards consideration ifit does not (I) involve a significant increase in the probability or consequences of an accident prcviously evaluated, (II) create the possibility of a new or different kind of accident from any j l accident previously evaluated, or (Ill) involve a significant reduction m a margm of safety. .
- 1. The proposed changes will explicitly define the temperature at which LTOP is required to be enabled in l accordance with NRC guidance, increase the safety margin of the LTOP system by raising the i temperature at which one high pressure safety injection pump is required to be rendered inoperable, and l ensure that required safety margins are maintained by imposing a restriction on the operation of
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multiple reactor coolant pumps at low temperatures. The consequences or probability of a previously evaluated accident will, therefore, not significantly be increased.
i 11. The underlying purpose of the LTOP system is to prevent the pressure of the reactor vessel from L exceedmg the allowable limits as defined by 'ASME Code Section XI, Appendix G at any given reactor coolant system temperature.' Since this purpose remains unchanged, a new or different kind of accident cannot be created.
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! - III. The proposed changes impleavent administrative controls that are more restrictive than those required i by the present Technical Specifications in order ensure that the margins of safety previously evaluated for the LTOP system are maintained. It has been determined that the proposed changes will provide acceptable margins as specified in Appendix G of the ASME Code Section XI. Therefore, these changes do not involve a significant reduction m a margm of safety.
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