ML20236A120
| ML20236A120 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/13/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236A123 | List: |
| References | |
| CON-NRC-87-101 VPNPD-87-425, NUDOCS 8710220044 | |
| Download: ML20236A120 (4) | |
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WISCONSIN CtflC powtR COMPAyY
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i VPNPD-87-425 NRC-87-101:
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'lii October 13, 1987 y
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v CERTIFIED MAIL
'i U.
S. NUCLEAR REGULATORY COMMISSION Document Control Desk
]
Washington, D.
C.
20555 I
Gentlemen:
DOCKETS 50-266 AND 50-301 l
TECHNICAL SPECIFICATION CHANGE REQUEST 113
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MONITORING OF STEAM GENERATOR PRESSURE DURING REFUELING POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 i
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In accordance with the requirements.-of.10 CFR'50.59.and 50.90, Wisconsin Electric Power Company (Licensee)-hereby submits.an
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application for amendments to Facili_ty. Operating Licenses J
DPR-24 and DPR-27 for. Point Beach. Nuclear Plant, Units:1 and 2.
These amendments-incorporate a change'.which clarifies'the requirements for testing of the. steam-generator. pressure-channels during refueling shutdowns.
Technical Specification Table 15.4'1-1, " Minimum Frequencies:
for Checks, Calibrations'and Test of Instrument Channels,"
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which lists the requirements for. testing these instruments is-l l
attached and contains the proposed changes identified by a i
margin bar.
Technical Specification 15.3.1.B.2.,
" Pressure Temperature-Limits," specifies that the steam generators are not,to be pressurized above 200 psig whenever.the. steam generator: vessel i
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s NRC Document Control Clerk october 13, 1987 Page 2 I
temperature is less than 70 degrees F.
Surveillance specified j
in Table 15.4.1-1, Item 25, currently requires that, during i
cold or refueling shutdown, a channel check be performed each shift and a channel test be performed each month for each steam.
generator pressure channel anytime the steam generator vessel temperature is less than 70 degrees F.
The intent of the surveillance is to provide operators the means to ensure that pressurization of the steam generators conforms to the limits established in Technical Specification 15.3.1.B.2 under all circumstances.
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Two problems' exist with the requirements of Item 25.
First, it is not practical for operators to determine when the steam generator vessel temperature is less than 70 degrees F, since the vessel is not instrumented for temperature.
Second, the monthly test requirement only verifies that the steam generator pressure channels are operable by injecting a test signal which verifies that the alarm and trip initiation (safety injection actuation) functions are operable.
When the plant is in either the cold or refueling shutdown condition, the low-pressure alarm is in constant alarm (steam generator pressure is always less than the alarm setpoint) and automatic safety injection is unnecessary (the plant is already shut down and cooled down).
Since the monthly test does not improve the operator's means of monitoring the steam generator pressure during periods when the limits of Specification 15.3.1.B.2 could be violated, the test is unnecessary.
The proposed amendments address each of the problems described as follows.
A steam generator pressure channel check of at least one channel per steam generator each shift will be required anytime the plant is in the cold or refueling shutdown condition and the steam generator can be pressurized.
For consistency with other monthly instrument test requirements, the monthly test of steam generator pressure channels will not be required during periods of refueling or cold shutdown.
Our proposed change revises the reference note asterisks from three to two on Item 25 of Table 15.4.1-1 for the monthly test frequency.
The note with three asterisks is also changed to reflect the proposed requirement.that one pressure channel per steam generator be checked per shift anytime the plant is in the cold or refueling shutdown condition and the steam generator could be pressurized.
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NRC Document Control Desk October 13, 1987 Page 3 As required by 10 CFR 50.91(a), we have evaluated this change in accordance with the standards specified in 10 CFR.50.92 to determine if the proposed change constitutes a significant hazards consideration.
As stated in 10 CFR 50.92, a proposed amendment involves no significant hazards consideration if operation of the facility in accordance with 3
the proposed amendment would not (1) involve a significant
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4 increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or l
different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
The proposed change simply eliminates the requirement to I
perform the monthly test of the steam generator pressure channels during periods of refueling shutdown.
This is
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consistent with other instrumentation test requirements and is j
allowable because the automatic safety injection associated with this instrumentation is not required when the plant is in l
a refueling or cold shutdown condition.
The Technical i
Specifications require that the steam generator pressure channels be tested prior to startup if they were not tested l
during the previous two weeks.
The monthly test requirement I
does not improve the operator's means of monitoring the steam generator pressure during periods when the limits of Technical Specification 15.3.1.B.2 could be violated.. The amendment will, therefore, not cause an increase in the probability or-consequences of an accident previously evaluated.
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The change also conservatively modifies the surveillance requirement to conduct a steam generator pressure channel check l
each shift.
As amended, a check must be performed whenever the plant is in a cold or refueling shutdown condition and the steam generator can be pressurized.
This surveillance requirement compensates for the lack of a direct indication of l
steam generator temperature.
Thus, no new or different accident from any previously evaluated accident can be created.
l Lastly, a significant reduction in a margin of safety is not applicable to this change.
The change'both clarifies surveillance requirements and specifies' conservative conditions in which to perform the surveillance.
The margin of safety is, therefore, not decreased.
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~f NRC Document Control Desk October 13, 1987 Page 4 We have enclosed a check in the amount of $150 for the application fee prescribed in 10 CFR 170.
Please do not hesitate to contact us if you have any questions concerning this request.
Very truly yours, 4
,f[v l C. W.
Fa Vice President Nuclear Power Enclosure (Check 144324) 1 Copies to NRC Regional Administrator,' Region III
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NRC Resident Inspector R.
S.
Cullen, PSCW Subscribed and sworn to before me this 13B day of S TJ m 1987 j
1 D
l Notary Public, State of Wisconsin My Commission expires f!27 f90 l
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