ML20236A033

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Forwards Revised Tech Spec Page to 890224 Application for Amends to Licenses DPR-24 & DPR-27,consisting of Tech Spec Request 128,per NRC 890301 Request.Clarification of motor- Driven Auxiliary Feedwater Pump Start Provided
ML20236A033
Person / Time
Site: Point Beach  
Issue date: 03/03/1989
From: Fay C
WISCONSIN ELECTRIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236A035 List:
References
CON-NRC-89-29 VPNPD-89-132, NUDOCS 8903160285
Download: ML20236A033 (3)


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Wisconsin

'Electnc POWER COMPNn'

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231 W MacNgon, Po. Box 2046, Mawaukee. WI 53201 (414)221 2345 VPNPD-89-132 NRC-89-29 i

March 3, 1989

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Nuclear Regulatory Commission Document Control Desk Mail Station P1-137 Washington, DC 20555 Attention: Mr. Warren Swenson, Project Manager PWR Project Directorate III-3 i

Gentlemen:

l DOCKET NOS. 50-266 AND 50-301 MODIFICATION OF TECHNICAL SPECIFICATION REQUEST 128 CLARIFICATION OF MOTOR-DRIVEN' AUXILIARY FEEDWATER PUMP START FOLLOWING INSTALLATION OF AMSAC POINT BEACH NUCLEAR PLANT On February 24, 1989, Wisconsin Electric Power Company, licensee.for the Point Beach Nuclear Plant Units 1 and 2, submitted a license amendment application for Facility Operating Licenses DPR-24 and DPR-27, which requested a revision of the plant Technical Specifications.

The purpose of the revision is to clarify an existing specification by defining a permissible bypass condition.

The specification is Item 3.b " Auxiliary Feedwater" of Table 15.3.5-3,

" Emergency Cooling."

The change will be necessitated by the installation of the ATWS mitigating system actuation circuitry (AMSAC) at Point Beach, which will bypass the " Trip of both main feedpumps starts motor driven pump" auxiliary feedwater actuation when reactor power is less than 40%.

On March 1, 1989 we received a call from Mr. Warren Swenson of your staff regarding this proposed revision.

He was concerned that the NRC safety evaluation report (SER) on the Point Beach AMSAC design, which j

was dated August 4, 1988, specified that the AMSAC C-20 permissive signal will be set to disable AMSAC below 40% reactor power.

After resolution of this concern, we explained that the permissive would be set at 40% reactor power as derived from the turbine first stage impulse pressure.

However, to account for the possibility of instrument setpoint error or drift, we had included a 10% tolerance in the setpoint and therefore specified the bypass condition as reactor power less than 44%.

Mr. Swenson explained that having a Technical Specification setpoint that did not match the parameters approved by s903160285 890303 ADOCK0500g6 DR

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" the NRC in the SER would' necessitate further justification by the licensee and would lengthen the NRC staff review time for the change.

Accordingly, we agreed.to modify our change request.

A revised proposed Technical Specification page is attached.

Mr. Swenson also.noted that although the AMSAC installation has.been approved in the NRC SER, it is still necessary that.the licensee provide its analysis concerning the issue of no significant hazards.

We have conducted this evaluation and have determined, as specified in 10 CFR 50.92,.that the proposed amendment would not:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated, or (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated, or (3)

Involve a significant reduction in a margin of safety.

Our conclusion.of no significant hazards consideration is based on the following elements.

First, the specific change requested in this license amendment request amounts to an administrative clarification of an existing specification.

As such, the change, of itself, does not have any impact upon the plant systems, structures or components and therefore cannot have any impact on the significant hazards consideration standards listed above.

The need for this clarification of'the specification results from the proposed installation of an AMSAC at the Point Beach Nuclear Plant.

This installation was mandated by the NRC in its regulations at 10 CFR 50.62.

The NRC has previously determined in the statement of consideration promulgated with the significant hazards consideration rule (48 FR 14864) that a change.to make a license conform to changes'in the regulations, where the change results in very minor changes to facility operations, is not likely to involve significant hazards considerations.

Wisconsin Electric has previously provided to the NRC detailed descriptions of the AMSAC. proposed.for installation at the Point Beach Nuclear Plant.

This information was provided with our letter dated April 23, 1987 and was clarified in' correspondence dated December 30, i

1987 and March 3, 1988.

In these submittals we provided descriptions A

which demonstrated that the AMSAC equipment would have the quality and reliability necessary to perform its intended function while minimizing the potential for ransients that may challenge the existing plant safety systems.

This will be accomplished by using instrumentation and logic hardware which are separate and diverse from that used in the reactor trip system.

The power supplies for AMSAC are also independent and diverse from the reactor protection system power supplies.

Provisions are included in the AMSAC design for maintenance and testability using output bypass switching.

We have committed to a complete end-to-end test of the system during each refueling outage and testing of those portions of AMSAC that can be tested at power,

4 Document Control Desk' Malch.3, 1989 PageL3 such as the bistables, time delays and logic relays, on a semiannual basis.

These testability provisions and periodic surveillance will provide assurance that the AMSAC is available to reliably perform its intended function.

We have noted that the only safety-related interface of the AMSAC.will l

be between the AMSAC and the auxiliary feedwater system.

Isolation at j

this interface will be achieved using electrical isolation devices j

that have been qualified and tested to Class lE electrical equipment requirements.

We previously have concluded that these provisions in the AMSAC design and installation provide reasonable assurance that this system'does not involve an unreviewed safety question, as defined in 10 CFR 50.59, and therefore can also conclude that the AMSAC installation and this proposed license amendment does not present a significant hazard consideration.

As mentioned previously, the NRC staff has concurred in these i

conclusions and an NRC SER approving the AMSAC installation at the 1

Point Beach Nuclear Plant was provided with Mr. David H. Wagner's letter dated August 4, 1988.

As previously noted, the nature of the modification requires that these license amendments be approved and issued prior to the Point Beach Nuclear Plant 1989 refueling and maintenance outages during which the' final modification work is currently scheduled.

The Unit 1 outage is scheduled to begin March 31, 1989.

Without approval prior to beginning the outage, enough time may not'be available to complete the modification and the implementation will be delayed by one year.

1 Very 6tv g,/,yours, r7 y C.

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Ny Vice President Nuclear Power pgy pg Subscribed and sworn to before me o

this J M day of 4/n M, 1989 LOlS J.

HUBERT

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i Notary Pu p c, State of W1 cons 0i My Commission expires:

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Copies to NRC Regional Administrator, Region III, l

NRC Resident Inspector

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