ML20134P735

Requests Enforcement Discretion from Specific Pbnp TS Requirements Re Inoperability of One Train a Svc Water Pump, P-32A & Unit 1 Train a Component Cooling Water pump,1P-11A

ML20134P735
Person / Time
Site:	Point Beach
Issue date:	02/20/1997
From:	Dante Johnson WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PBL-97-0061, PBL-97-61, NUDOCS 9702260098
Download: ML20134P735 (7)

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J Wisconsin Electnc  !

POWER COMPANY Point Beach Nuclear F1ont (414) 755-2321 i 6610 Nuclear Rd., Two Rivers, WI 54241  !

PBL 97-0061 1

February 20,1997  !

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i Document Control Desk j U.S. NUCLEAR REGULATORY COMMISSION i Mail Station PI-137 Washington, DC 20555 Ladies / Gentlemen:

DOCKETS 50-266 AND 50-301 REOUEST FOR ENFORCEMENT DISCRETION SERVICE WATER AND COMPONENT COOLING WATER REOUIREMENTS POINT BEACH NUCLEAR PLANT. UNITS I AND 2 Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, hereby requests enforcement discretion from speci6c Point Beach Nuclear Plant Technical Speci6 cation requirements related to the inoperability of one Train A service water pump, P-32A, and the Unit 1 Train A component cooling water pump,1P-11 A. This request is made in accordance with the guidance contained in NRC Inspection Manual, Part 9900: Technical Guidance, " Operations - l Notices of Enforcement Discretion." Point Beach Nuclear Plant Units 1 and 2 are presently shut down. Unit 2 is shut down and defueled with recovery in progress from the engoing refueling and ,

steam generator replacement activities. Unit I had been operating at 90% pow at the time of the j discoven' of the conditions described in this request. Unit I was shut down in accordance with Technical Speci6 cation requirements and is presently being maintained at approximately 1050 psig,380 F primary system pressure and temperature with decay heat being removed through the steam generators and secondary systems.

Reauirementt's) For Which Discretion is Reauested

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j Technical Specification 15.3.3.C.2 requires that during power operation, an inoperable component cooling water pump must be 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 />. If this cannot be satis 6cd, the reactor shall be placed in the hot shutdown condition. If the pump cannot be restored 4 I

to an operable status within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in cold shutdown.

I Technical Speci6 cation 15.3.3.D.2 requires that during power operation, an inoperable service j water pump must be 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 />. If this cannot be satisfied, both l reactors shall be placed in the hot shutdown condition within six hours, and in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

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PBL 97-0061 February 20,1997 Page 2 We are requesting enforcement discretion from the requirements of Technical Specifications 15.3.3.C.2 and 15.3.3.D.2 to allow Point Beach Nuclear Plant Unit I to stay in a hot shutdown condition. We believe maintaining Unit 1 in a hot shutdown condition, pending

. repairs of the IP-11 A component cooling water pump, will reduce shutdown risk and provide an overall safety benefit.

Enforcement discretion is requested until 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on February 21,1997, to allow time to return the inoperable component cooling pump to an operable condition. Should the component cooling water pump be returned to operable status prior to meeting the requirements described in Technical

! Specification 15.3.3.D and administrative restrictions contained in DCS 3.1.7 for the senice water

, pump, we will proceed to cold shutdown. Should it be detennined necessary to proceed to cold J shutdown, an additional 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> is requested, from the time of this determination, to cool down to cold shutdown conditions in a safe and orderly manner.

Additional discussions will be held with NRC staff at approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on February 21, 1997, to commun cate the status of repairs to the component cooling water pump and service water pump. If an extension of the enforcement discretion duration is required and warranted, it will be requested at that time.

Circumstances Surrounding The Situation Point Beach Nuclear Plant, Unit I component cooling water pump 1P-11 A was declared inoperable on February 17,1997, at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />. An operability determination had been performed in 1994 on 1P-11 A as a result of the discovery of defects on the pump impeller. During a recent review of that operability determination, it was decided that the determination did not include sufficient information to conclude that the pump was operable.. The pump was taken out of senice and disassembled to verify the existence and extent of the defects.

Technical Specification 15.3.3.C.2.a allows this pump to be inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the redundant pump is operable. The impeller defects were not repairable within this time frame.

The review of operability determinations that discovered this particular condition was being performed as a result ofissues identified by Wisconsin Electric and the NRC staff and was associated with Unit 2 startup commitments identified in our December 12,1996, letter. This review was being perfomied to verify the operability of required structures, systems and components at the Point Beach Nuclear Plant.

Senice Water Pump P-32A, one of three train A senice water pumps, was declared inoperable at 1558 hours0.018 days <br />0.433 hours <br />0.00258 weeks <br />5.92819e-4 months <br /> on February 17,1997. P-32A was experiencing high upper motor bearing vibration.

Technical Specification 15.3.3.D and an administrative restriction contained in DCS 3.1.7,

" Service Water Pump Operability," allow a required senice water pump to be inoperable for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to initiating shutdown of the operating unit (s). The senice water pump was not returned to an operable condition within this time period. Investigations have not yet determined the cause for the high vibration.

PBL 97-0061

, February 20,1997 Page 3 Because we were unable to return these pumps to an operable status within the time periods specified, Unit I reactor shutdown was initiated at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on February 18,1997. The unit was placed in hot shutdown at 2138 hours0.0247 days <br />0.594 hours <br />0.00354 weeks <br />8.13509e-4 months <br /> on February 18,1997. This action met the requirements of Technical Specifications 15.3.3.C.2 for the component cooling water pump and Technical Specification 15.3.3.D.2 for the service water pump for placing the unit in hot shutdown.

Technical Specification 15.3.3.C is in potential con 0ict with requirements for decay heat removal contained in Technical Specifications 15.3.3.A.3, which contains requirements related to the residual heat removal system. Component cooling water provides cooling to the residual heat removal heat exchangers during post-accident conditions and for shutdown cooling. With Train A of the component cooling water system inoperable due to the inoperable pump, Train A of the residual heat removal system is also not operable. If a residual heat removal loop is not being relied upon for decay hea'. removal, Technical Specification 15.3.3.A.3 requires the reactor to be maintained at greater than 350 F so both steam generators and the secondary system are available for decay heat removal. The requested enforcement discretion is consistent with continued operation at hot shutdown in accordance with Technical Specification 15.3.3.A.3.

The Point Beach Nuclear Plant Manager's Supersisory Staff (on-site nuclear safety review committee) has recognized the inconsistency between Technical Specification 15.3.3.A.3 and 15.3.3.C and acknowledge a license amendment may be warranted. While preparing this request for enforcement discretion, it was evident to us that a Technical Specification change was impractical because we expect to return to compliance with the existing license requirements in so short a period of time that a license amendment could not be issued before compliance is restored.

. However, an evaluation of these Technical Specification provisions will continue and , if determined to be appropriate, a change request will be developed and submitted to resolve this apparent inconsistency.

Safety Basis For The Reauejit This request is made in accordance with the guidance contained in NRC Inspection Manual, Part 9900: Technical Guidance, " Operations - Notices of Enforcement Discretion." Point Beach Nuclear Plant Units 1 and 2 are presently shut down. Criterion B.2 of this guidance states:

"For plants in the shutdown condition, the NOED is intended to reduce shutdown risk by avoiding testing, inspection, or system realignment that is inappropriate for the particular plant conditions, in that it does not provide an overall safety benefit, or may, in fact, be detrimental to safety in the particular plant condition."

As discussed below, operation of Point Beach Unit 1, in accordance with the cited Technical Specification requirements for component cooling water and service water, does not provide an overall safety benefit, and may be detrimental in that certain transients may provide additional risk under the stipulated Technical Specification conditions.

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, PBL 97-0061 February 20,1997 Page 4 Point Beach Nuclear Plant Technical Speci6 cations require redundancy of decay heat removal methods during all shutdown conditions. Under the present condition, only one train of residual heat removal is available for removing decay heat from the reactor. Redundant and diverse means are provided through the reactor coolant loops, steam generators and secondary systems. Under cold shutdown conditions, the reactor is also maintained solid by procedure. That is, primary j pressure is not being maintained with a steam bubble in the pressurizer.

Under these cold shutdown conditions, loss of the operable component cooling water loop results in the loss of decay heat removal until the primary reactor coolant system heats up suf6ciently to l allow heat transfer through the steam generators and secondary systems. In addition, the reactor coolant pump needs to be secured as a result of a lack of component cooling water. Under water solid conditions, this temperature increase results in expansion of the wate. which may result in a pressure excursion challenging the power-operated Micf valves (PORV) used as low temperature overpressure protection (LTOP). This challenge a W climinated by nnintaining the reactor at a temperature above the LTOP enable setpoint and with pressure controlled by a steam bubble in the pressurizer.

Additionally, station voltage is subject to greater variation because in addition to Unit I being out of service, both Point Beach Unit 2 and the Kewaunce Nuclear Plant are in refueling outages. This is an unusual situation and is a factor in assessing the safety basis for keeping the unit in hot shutdown. Normally, cooldown would be conducted using the residual heat removal system.

ContinuH cooldown with a single residual heat removal train would require at least one reactor i coolant pump operating. As reactor coolant density increases during the cooldown, the reactor coolant pump load increases. This could potentially reduce station bus voltage resulting in loss of the reactor coolant pump if the undervoltage setpoint was reached. This would not normally occur if the cooldown was on residual heat removal or if one of the three nuclear units was in service.

By maintaining the reactor above cold shutdown and above 350 F as specified in Technical Specification 15.3.3.A.3, redundancy of decay heat removal is maintained under all anticipated conditions, and the pctential consequences related to the loss of the operable component cooling water pump are mit4 gated. The reactor is maintained in an analyzed condition with decay heat removed through the steam generators.

In addition, safety systems, including safety injection, safety injection accumulators, and the steam-driven auxiliary feedwater pump, remain available to perform their design basis function for mitigating the consequence of potential accidents, as analyzed in the Final Safety Analysis Report (FSAR).

Basis For No Unreviewed Safetv Ouestion or Significant flazards Consideration As defmed in 10 CFR 50.59, a proposed change results in an Unreviewed Safety Question (USQ);

1) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased,2) if a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created, or 3) if the margin of safety as defined in the basis of any technical speci6 cation is reduced.

PBL 97-0061

, February 20,1997 Page 5 As defined in 10 CFR 50.91, a change involves no significant hazards consideration if the change

1) does not involve a signi6 cant increase in the probability or consequences of an accident previously evaluated,2) does not create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) does not involve a signi6 cant reduction in a margin of safety.

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Operation in accordance with the proposed enforcement discretion does net result in an Unreviewed Safety Question nor a Signi6 cant liazards Consideration. The proposed disvetion ensures the plant is operated as analyzed and as described in the safety analysis report. Structures, systems and components relied on for decay heat removal function are not being alterej by the proposed  ;

condition; and will be operated as analyzed and designed in accordance with approved procedures. l Redundancy of decay heat removal will be maintained. In addition, the potential for transients related to the failure of a residual heat removal train, when relied on as a means of decay heat removal, is climinated. Therefore, the probability or consequences of previously analyzed accidents do not increase, the possibility of an accident or malfunction of a different type is not l created, nor is a margin of safety reduced. l The health and safety of the public is not impacted by operation in accordance with the provisions I of the requested enforcement discretion.  ;

1 Environmental Consequences We have determined that operation in this condition does not involve a significant hazarJs I consideration, authorize a significant change in the types or total amounts of any efflucat release, or !

result in any significant increase in individual or cumulative occupational radiation exposure. l Therefore, we conclude that no environmental impact results. )

l Comnensatory Measures l During the duration of the enforcement discretion, the following compensatory measures were or I will be taken:

. Evaluations were performed which demonstrated the adequacy of two senice water pumps to provide the required post-accident cooling load under the condition of one unit defueled and the other at power. This demonstrates that under the worst case single failure with pump P-32A inoperable, senice water will perform its design basis function.

. Non-essential senice water loads assumed to be isolated in the above calculation in Unit 2 were isolated and danger tagged. This ensures the assumptions in the above evaluation are maintained. l 4

PBL 97-0061

, February 20,1997 Page 6

• Point Beach Nuclear Plant has the capability to cross-connect the Unit I and Unit 2 component cooling water systems should the system in one unit fail. Operations personnel have been directed to review the abnonnal operating procedure governing this c'.olution to ensure that they are familiar with the actions necessary to cross-connect the systems should a loss of the operable Unit 1 pump occur prior to restoring the redundant pump to an operable condition.

Auxiliary Operators are walking down the component cooling system to ensure they are familiar with all valve locations for valves that are required to be operated to perform the cross-connect.

. Plans were fmalized on February 19,1997, to replace the inoperable Unit I train A component cooling water pump with the Train B pump from Unit 2. This will ensure a pump is available from each train if cross-connection is necessary, e Status boards were updated to indicate the protected status of the Unit 1 Train B and Unit 2 Train A component cooling water pump to ensure these pumps are maintained operable. Signs have also been placed on the pumps to indicate this status.

. Work crews are being cautioned about the protected status of the aforementioned pumps.

. The combustion turbine-generator (G05) was tested on February 19,1997. This test verified the availability and operability of G05 as a source of power to the station and as a  ;

supplemental means to maintain station voltage should grid voltage become a concern affecting equipment operability with both Point Beach units shut down.

• Discussions were held with Wisconsin Electric System Control on the moming of February 20,1997. These discussions emphasized the need for prompt action and infonning the station should grid voltage become a concern. Subsequent discussions will occur at least daily during the period of the requested enforcement discretion.

Lustification For Duration Of Non-Compliance Enforcement discretion is requested from the cited Technical Specification requirements until 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on February 21,1997, to allow time to return the inoperable component cooling water pump to an operable condition. The enforcement discretion duration requested is based oa the estimate of tim time it will take to replace the inoperable Unit 1 Train A component cooling water pump with the Train B pump from Unit 2. This work is expected to take a minimum of three to four shifts worked around the clock. Allowing for contingencies,2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on February 21,1997, provides for a high probability that the replacement evolution will be successful while being performed in a safe manner.

e PBL 97-0061

, , February 20,1997 Page 7 Summary OfCommunications And Approvals The PBNP Manager's Supervisory Staff (on-site nuclear safety review committee) met and discussed this enforcement discretion action on February 19,1997. The Manager's Supervisory Staff concurred with the decision to request this enforcement discretion, and with the content of this request.

Discussions were held with NRC Region 111, Point Beach resident inspectors, and Projects staff on February 19,1997, at approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />. Verbal approval of this request was received at approximately 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />.

If you have any questions or require additional information, please contact us.

Sincerely, Douglas F. Johnson Manager, Regulatory Services & Licensing cc: NRC Regional Administrator, Region ill NRC Resident inspector i

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