ML20207D569

Safety Evaluation Supporting Amends 186 & 191 to Licenses DPR-24 & DPR-27,respectively

ML20207D569
Person / Time
Site:	Point Beach
Issue date:	03/01/1999
From:	NRC (Affiliation Not Assigned)
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ML20207D567	List: ML20207D562 ML20207D569
References
NUDOCS 9903100009
Download: ML20207D569 (5)

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• 4 UNITED STATES j

NUCLEAR REGULATORY COMMISSION 2

WASHINGTON, D.C. 'm *1

.....,d SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.186 TO FACILITY OPERATING LICENSE NO. DPR-24 AND AMENDMENT NO.191 TO FACILITY OPERATING LICENSE NO. OPR-27 WISCONSIN ELECTRIC P( VER COMPANY POINT BEACH NUCLEAR PLi JT. UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301

1.0 INTRODUCTION

By letter dated September 28,1998, the Wisconsin Electric Power Company (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License No. DPR-24 for Point Beach Nuclear Plant, Unit 1, and Facility Operating License No.

DPR 27 for Point Beach Nuclear Plant, Unit 2. The proposed amendments would clarify the notation definition of "R" in TS Table 15.4.1-1, " Minimum Frequencies for Checks, Calibrations, and Tests of instrument Channels," and add a new frequency "A."

2.0 EVALUATION 2.1 Backaround The proposed change would involve a revision to the notation "R" used in various columns in TS Table 15.4.1-1 to specify a required suweillance frequency. The notation "R"is currently defined as a frequency of "Each refusi;ng interval (but not to exceed 18 months)." The j

proposed change would redefine "R* as a frequency of "Each refueling interval (18 months),"

consistent with NUREG 1431, Rev.1, " Standard Technical Specifications, Westinghouse Plants," (STS). In addition, a new notation "A"is propcsed to be used to designate an annual 12-month frequency and would be defined as " Annually (12 months)" for instrumentation surveillance frequencies remaining on an annual frequency. This new frequency,"A," would i

replace the current calibration frequency of "R" for TS Table 15.4.1-1 Item 29, " Emergency Plan Radiation Survey Instruments," and item 43, " Volume Control Tank Level."

The proposed changes are necessary to clarify that the provisions of TS 15.4.0.2, which allows up to a 25% extension of surveillance frequency, apply to the "R" and "A" frequency requirements. The proposed changes are consistent with STS Fection SR (surveillance requirement) 3.0.2, which states that, "The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as i

measured frorn the previous performance or as measured from the time a specified condition of the Frequency is met.... If a Completion Time requires periodic performance on a "once 9903100009 990301 PDR ADOCK 05000266 i

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[r per... basis, the above Frequency extension applies to each performance after the initial performance...." The changes are necessary because the Unit 1 operating cycle (cycle 25) is currently scheduled for 15 months, which would allow Unit 1 to operate until October 1999.

Without application of the 25% extension interval, the TS Table 15.4.1-1 required surveillances l

for Unit 1 would fall due in August 1999, since the TS-required surveillances were last '

j performed in February 1998. Wisconsin Electric would like to avoid an unnecessary plant shutdown in the peak summer month of August 1999 to perform the currently required -

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surveillances. In addition, Wisconsin Electric is currently planning to implement 18-month.

cycles for both Polm Beach units, and would like the proposed change to clarify that the i

j refueling interval is 18 months and that the provisions of TS 15.4.0.2 apply to the frequencies -

i specified in TS Table 15.4.1-1.

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2.2 Evaluation of Prooosed Chanaes l

i The proposed change to the definition of notation "R" in TS Table 15.4.1-1 is intended to clarify l

that the refueling interval is 18 months and that the provisions of TS 15.4.0.2, which allows a 25% extension of surveillance frequency, can be applied, and is consistent with the wording and s

allowances contained in STS. The licensee conducted instrument drift studies for calibration of i

instruments contained in TS Table 15.4.1-1 that perform safety functions, including providing l

the capability for safe shutdown. The purpose of these studies was to ensure appropriate l

safety limits and functions would be met if the 25% extension of surveillance interval (18 months plus the TS 15.4.0.2 allowable 25%, or 22.5 months) was applied to the instrumentation contained in TS Table 15.4.1-1. The drift studies and corresponding calculations determined that the magnitude of the instrument drift, for instrumentation affected by drift, that could occur over a 22.5-month interval was bounded by the uncertainty allowances used in determining j

safety system setpoints.

l In addition, calibration data from surveillance records were reviewed for the instrumentation l-contained in TS Table 15.4.1-1. The purpose of this review was to determine the impact that L

an increase of 25% (i.e., to a total of 22.5 months) in the surveillance frequency would have on instrument availability. This review identified that as found and as left data has not exceeded

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acceptable limits for the calibration intervals except on rare occasions. Because of the very l

small percentage of failures that are detected on the current surveillance intervals and because 1 -

of system redundancy, Point Beach has concluded that the change in the surveillance

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frequency will have a small impact, if any, on system availability, with the exception of those j

items noted below.

The new notation "A" proposed to be used to designate an annual 12-month frequency was necessary because the licensee's surveillance record review identified that instrumentation included in TS Table 15.4.1-1 Item 43, " Volume Control Tank Level," and Item 29, " Emergency Plan Radiation Survey Instruments," would not support a possible surveillance interval up to 22.5 months. As a result Wisconsin Electric determined that these items should remain on their current annual calibration frequency, and has introduced the new notation "A" to incorporate this requirement. Since Point Beach has historically operated on a nominal 12-month cycle, the annual frequency is consistent with past operations.

A program to monitor instrumentation and control prevenhva maintenance, correcue maintenance, and surveillance test histories is in place at Point Beach (nuclear pmcedure NP -

8.3.5, " Machinery History - Instrumentation and Control"). The program currently requires a

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. semiannual and annual review of instrumentation and control _ histories important to safety. The i -

intent of this program is to identify any adverse trends in instrument and control machinery -

performance and ensure appropriate corrective actions are implemented.

h The use of the allowance to extend surveillance intervals by 25% can also result in a significant safety benefit for surveillances that are performed on a routine basis during plant operation.

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t This safety benefit is incurred when a surveillance interval is extended at a time that conditions a

are not suitable for performing the surveillance. Examples of this include transient plant :

i operating conditions or ccnditions in which safety systems are out of service because of l

ongoing surveillance or maintenance activities. In such cases, the safety benefit of allowing the b

use of the 25% allowance to extend a surveillance interval would likely outweigh any benefit derived by limiting the intervals to the presently interpretable 18 months. The limitation of TS _

15.4.0.2 is based on enginet ring judgment and the recognition that the most probable result of any surveillance being performed is the verification of conformance with the surveillance requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

The proposed change to the definition of the "R" notation for TS Tab!e 15.4.1-1 clarifles that the

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refueling interval ic 18 months and that the 25% surveillance frequency extension allowed by TS 15.4.0.2 can be app!ied. The change was supported by licensee instrument drift studies and swveillance record reviews and is consistent with STS. Instrumentation that would not i

support the surveillance frequency extension was retained at an annual surveillance frequency, consistent with past plant operations. Therefore, the proposed change is acceptable to the i

staff.

The proposed addition of the "A" notation to TS Table 15.4.1-1 and the change in calibration frequency for Item 29, " Emergency Plan Radiation Survey Instruments," and item 43, " Volume Control Tank Level," from "R" to "A"is consistent with past plant operations and is i

1 administrative. Tiierefore, the proposed changes are acceptable to the staff.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Wisconsin State official was notified of the proposed issuance of the amendments. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

These amendments change surveillance requirements. The staff has determined that the amendments involve no significant increase la the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously -

published a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding (64 FR 4162).

= Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

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5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commiss(on's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the pubsc.

Principal Contributor: C. Lyon Date: March 1, 1999

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March 1, 1999' Mr. Michael B. Sellman Senior Vice President and Chief Nuclear Officer Wisconsin Electric Power Company 231 West Michigan Street Milwaukee WI 53201

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 -ISSUANCE OF AMENDMENTS RE: CLARIFICATION OF TECHNICAL SPECIFICATION 4

TABLE NOTATION DEFINITION (TAC NOS. MA4325 AND MA4326)

Dear Mr. Sellman:

The Commission has issued the enclosed Amendment No. 186 to Facility Operating License No. DPR-24 and Amendment No. 191 to Facility Operating License No. DPR-27 for the Point Beach Nuclear Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TS) in response to your application dated September 28,1998.

i These amendments clarify the notation definition of refueling interval,"R,"in TS Table 15.4.1-1,

" Minimum Frequencies for Checks, Calibrations, and Tests of instrument Channels," and add a new annual interval, "A."

A copy of our related Safety Evaluation is also enclosed. The notice of issuance will be included in the Commission's biweekly Federa/ Register notice.

j-Sincerely...

Original signed by:

4 Beth A. Wetzel, Senior Project Manager Project Directorate Ill-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301

Enclosures:

1. Amendment No.186 to DPR-24

2. Amendment No.191 to DPR-27

3. Safety Evaluation cc w/encls:

See next page DISTRIBUTION: See attached page DOCUMENT NAME: G:\\P D31 \\W PDOCS\\PTB EAC H\\AMDA4325...

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