ML20236S359

Forwards Licensee Responses to 10CFR21 Notification Re Potential Violation of Component Cooling Water Containment Isolation Function,Per 871106 Request

ML20236S359
Person / Time
Site:	Kewaunee, Point Beach, 05000000
Issue date:	11/16/1987
From:	Wigginton D Office of Nuclear Reactor Regulation
To:	Jocelyn Craig Office of Nuclear Reactor Regulation
References
NUDOCS 8711250097
Download: ML20236S359 (1)

Text

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~ November 16,- 1987 i

Distribution: l Docket File e EJordan i NRC'& LoEa1 PDRs JPartlow J PDIII-3 r/f ACRs (10) l GHolahan Gray File PKreutzer j KEPerkins l TQuay  !

OGC-Bethesda l MEMORANDUM FOR: John Craig, Chief {

Plant Systems Branch <

Division of Engineering and Systems Technology l I

FROM: David L. Wigginton, Acting Director 'l Project Directorate III-3 Division of Reactor Projects III/IV/V and Special' Projects l L I

SUBJECT:

POTENTIAL VIOLATION OF COMP 6NENT COOLING WATER CONTAINMENT  ;

ISOLATION FUNCTION IDENTIFIED BY WESTINGHOUSE IN A  !

10 CFR PART 21 NOTIFICATION l I l In a memorandum dated November 6,1987, on the above subject, you requested j that project managers for a number of plants solicit information concerning  !

the 10 CFR Part 21 notification. Two plants !Kewaunee and Point Beach) in my l Project Directorate were affected by this notification. Please note that the '

response from Kewaunee to this Part 21 notification was submitted on July 20, 1987. A copy of that response was supplied to PSB. . However, an additional copy is enclosed for your review.

A copy of Wisconsin Electric Power Company!s response dated' June 25, 1987, has  ;

already been supplied to Mr. R. Anand. 'An additional copy is also enclosed i for your information.

'Or@M1 fin &Aen, t David L. Wigginton, Acting Director Project Directorate III-3 Division of Reactor Projects III/IV/V and Special Projects

Enclosures:

As stated cc: R. Anand Office: LA/P IIN3.

U PM/PDIIJ-3dJ./

h PD/PDIII-3 .

l Surname: PKreutzer TQuay/DWagner/rl-1 'DWigginton Date: 11/ (/87 11/j(f/87 11//6/87 8711250097 B71116 26 DR ADOCK O

- Enclosure 4

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N- REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS:

f' ACCESSION NDR:S?^?C60400 - DDC.DATE: 87/06/25 NOTARIZCD: NO DOC KC'T

'- FACIL:50-266 Point Beach Nuclear Plant, Unit 1, Wisconsin Electric 0500026/

50-301 Point Beach Nuclear Plant, Unit 2, Wisconsin Electric 050007.C.

AUTH NAME AUTHOR AFFILIATION FAY,C.W. Wisconsin Electric Power Co.

RECIP.NAME RECIPIENT AFFILIATION WAGNER,D. Document Control Branch (Document Contrel DesI-

SUBJECT:

Discusses'V70618 Itr from Westinghouse which notified NRC of rftportable item per 10CFR21 associated w/previously recommended mod to component cooling water sys. Mods &

analysis consistent w/870619 recommendations.

DISTRIBUTION CODE: IE19D COPIEC RECEIVED: LTR E N C L ,,/._ SIZE: b _

TITLE: Part 21 Rept (50 DKT)

NOTES:

RECIPIENT COPIUC RECIPIENT COPIEL ID CODE /NAME LTTR ENCL ID CODE /NAME LTTR ENCL PD9 7 14 1 0 PD3-3 PD 1 3 (WAIEIERM 1 1 AEOD/DSP/TPAE 1 i INTERNAL: AEOD/DOA 1 1 ARM TECH ADV 1 3 NRR CRUTCHFIELD 1  :

NRR VARGA,5 1 1 NRR/ DEST /Al*C 1 1 i NRR/ DEST / ADS 1 i NRR/DLPG/ GAD 1 1 NRR/DOEA/EAH 2 1 NRR/DOEA/GCB 1 1 NRR/DRI5/VIF 2 1 NRR/PMAS/ILRb 1 )

REC FILE 0: 1  ? RES DEPV G1 1 RES/DE/E1D 'l 3 RGN) 1 1 RGN2 1 S RGN3 1 3 RGUS 1  :

RGN4 1 1 EXTERNAL; INPD RECORD CTR 1 1 LPDR 1 .

NRC PDF 1 1 NSIC SILVER,E 1 1 I

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I Wisconsin Electnc eow cor..~

23 W V;CmGAN P o BOY 204f, f/sLWAUkEE Wl53201 i414 277 2545 VPNPD-87-280 NRC-87-66 June 25, 1987 NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D.C. 20555 Attention: Mr. Dave Wagner, Project Manager Division of Reactor Projects, Directorate III-3 Gentlemen:

DOCKET NOS. 50-266 AND 50-301 COMPONENT COOLING WATER SYSTEM CONTAINMENT ISOLATION CAPABILITY l

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 On Jur4 18, 1987, in a letter from Mr. W. J. Johnson to Mr. Carl Berlirer , Westinghouse Electric Corporation notified the NRC of a reportable item pursuant to 10 CPR Part 21 associated with a previously recommended modification to the component cooling water system (CCWS). In a letter to Mr. R. C. DeYoung dated July 13, 1984, Westinghouse had reported on a potential overpressure condition in the CCWS designed by Westinghouse.

Each affected utility was notified by letter of this potential overpressure condition and recommendations were made for plant modifications.

In our 1984 review of these recommended modifications, Wisconsin Electric determined that implementation of the proposed modifications could have led'to a violation of the containment isolation requirements for the Point Beach Nuclear Plant. We informed Westinghouse of this concern.

To address the original overpressurization concern, we considered the alternative action mentioned in the original Westinghouse notice. Specifically, we have completed a  ;

modification to the CCWS which replaced the surge tank relief valves with higher capacity valves and reduced the setpoint of these relief valves. We also performed an analysis which O

-frF0706040s 870625 PDR ADOCK 05000266 \ m.

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Document Control Desk June 25, 1987 i Page 2 i

demonstrated that the stress levels resulting from the postulated overpressurization event are acceptable and do not adverse 3y affect the operability of the components in the CCWS.

The modifications and analysis have been completed on both Point Beach units and are consistent with the recommendations contained in a June 19, 1987 letter from Westinghouse regarding this most recent NRC notice.. These actions have been discussed with Mr. Dave Wagner, the Point Beach Project Manager, and Mr. I Richard Hague, the Senior Resident Inspector.

1 Please contact us if you have questions concerning our actions in this regard.

Very truly yours, l

. 's, i.'n I C. W. Fay Vice President Nuclear Power Copies to NRC Regional Administrator, Region III NRC Resident Inspector l

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Enclosure REGULATORY INFORMAT!ON DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:BSO7?RO5eV"' DOC.DATE: 87/07/20 NOT AR I ZED: NO DOCKET

• FACIL:50-305 Kewaunec Nuclear Power Plant, Wisconsin Public Servic 05000305 AUTH.NAME AUTHOR AFFILIATION ROPSON,D.J. Wisconsin Public Service Corp.

HINTI,D.C. Wisconsin Public Service Corp RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 87-OO6-OO:en 870618, Westinghouse notified util that removal of internals from relief valve could violate containment integrity design basis.Util evaluation showed notification did not apply to plant.W/870720 Itr.

DISTRIBUTION CODE: IE19D COPIES RECEIVED: LTR _f ENCL _j SIZE:

TITLE: Part 21 Rept (50 DKT)

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE /NAME LTTR ENCL ID CODE /NAME LTTR ENCL ED3-3 LA 1 0 PD3-3 PD 1 1 UUAYD 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 ARM TECH ADV 1 1 NRR CRUTCHFIELD 1 1 NRR VARGA S 1 1 NRR/ DEST /ADE 1 1 NRR/ DEST / ADS 1 1 NRR/DLPG/ GAB 1 1 NRR/DOEA/EAD 1 1 NRR/DOEA/GCB 1 1

' NRR/DRIS/VIB 1 1 NRR/PMAS/ILRB 1 1 REG FILE 01 1 1 RES DEPY GI 1 1 RES/DE/EIB 1 1 RGN1 1 1 RGN2 1 1 RGN3 1 1 RGN4 1 1 RGN5 1 1 EXTERNAL

INPO RECORD CTR 1 1 LPDR 1 1 NRC PDR 1 1 NSIC SILVER,E 1 1 I

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On June 18, 1987, while the plant was operating at 100% power, Westinghouse Electric Corporation notified Wisconsin Public Service Corporation (WPSC) of a 10 CFR 21 item with regard to Westinghouse supplied Component Cooling Water System (CCWS).

Due to a recommendation made by Westinghouse, WPSC removed the internals from the relief valve on the CCW surge tank, in July of 1984. Westinghouse made the recommendation to prevent the possible overpressurization of the CCWS during a J leak in a reactor coolant pump thermal barrier. Upon reevaluation of their recommendation, westinghouse determined that the removal of the valve's internals could result in a violation of the containment integrity design basis for some plants, including Kewaunee.

WPSC immediately began evaluating the applicability of the June 18, 1987 10 CFR 21 notification with the assistance of Westinghouse and Fluor Engineers, Inc.,

the KNPP architectural engineering firnt. This evaluation determined that the Part 21 notification did not apply to the Kewaunee Plant. Therefore, no further corrective action was required.

This event is being reported by WPSC in response to the 10 CFR 21 report sent to the NRC by Westinghouse.

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J Description of the Event .

On June 18, 1987, while the plant was operating at 100% power, Westinghouse l Electric Corporation notified Wisconsin Public Service Corporation (WPSC) of a 10 CFR 21 item with regard to Westinghouse supplied Component Cooling Water Systems (CCWS) [CC).

i On June 12, 1984, Westinghouse notified WPSC that a leak of reactor coolant into the CCWS through one of the reactor coolant pump thermal barriers [HX] could result in the overpressurization of the CCWS. One of the recommendations made by Westinghouse to resolve this concern was to remove the internals from the relief valve [RV) on the CCW surge tank [TK]. The pressure relief valve on the i CCW surge tank was originally designed to provide overpressure protection for the tank. Westinghouse indicated that due to the design of the CCW system, there is a potential to overpressurize the lower elevation piping should the CCW surge tank pressure approach the relief valve setpoint. Removing the internals would open the system to the atmospheric pressure and prevent it from I overpressurizing. After WPSC reviewed and approved this proposed change, it was implemented in July of 1984 Westinghouse's June 18, 1987, 10 CFR 21 notification stated that when the relief valve internals were removed, the CCWS became an open system outside contain-ment. They further stated that this might be in violation of the design basis of some plants, including the Kewaunee Plant.

Westinghouse f urther advised WPSC that the containment isolation [JM) design and licensing bases for KNPP should be evaluated since credit may have been taken in the original design basis for a closed system outside of containment .

WPSC immediately began evaluating the applicability of the 10 CFR 21 notifica-tion with the assistance of Westinghouse and Fluor Engineers, Inc., the KNPP l architectural engineering firm.

Cause of the Event I

As noted in Westinghouse's June 18, 1987 10 CFR 21 notification opening of the CCWS outside of containment would have resulted in a violation of design basis for the Point Beach Nuclear Power Plant. Subsequently, Westinghouse identified this as a potential concern for plants that implemented the above mentioned modifications. Therefore, on June 18, 1987, Westinghouse initiated a 10 CFR 21 l

l l report which identified the Kewaunee Plant as a potential candidate of concern.

This report is being supplied to respond to those concerns.

WA mA. LEAR D,0VL.,08Y CCametWJoss N' UCENSEE EVENT REPORT (LER) TEXT CONTINUATION ovioyo me-e*

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Kewaunee Nuclear Power P1 ant a p;o ;o ga;3 50 j 5 s 17 n 10 l 6 -

nIn I1 or 0 l3 Analysis of Event The original design basis for the CCWS assumed a closed system outside of containment as one of the two barriers required to maintain containment integrity. When the internals were removed from the CCW surge tank relief valve, the system was no longer closed outside of,c M ainment. As a result, the CCWS containment penetrations were evaluated to determine if 6 double barrier still existed.

The evaluation determined that the modified'CCWS configuration continues to meet .

l the requirements for a closed system inside containment; thereby, providing one of the two required barriers. This was verified by comparing the CCWS design to the nine criteria for a closed system in containment supplied in section 3.5 of ANSI /ANS 56.2-1984.

l For the CCW supply lines (penetrations 32N, 32E and 39) the second barrier is I

the CCW pump [P) discharge pressure, which is higher than the containment design pressure of 46 psig. In the event of a leak in the closed system, this higher pressure will cause CCW to leak into the containment atmosphere.

For the CCW return lines (Penetrations 33N, 33E and 40) the second barrier are the motor operated valves outside containment, CC-612A, CC-6128 and CC-653, respectively.

Therefore, the modified CCWS configuration, which is open outside containment,

! maintains the original KNPP double barrier design basis requirements for con-l tainment integrity.

l This event is not required to be reported in accordance with 10 CFR 73. However, it is being supplied to respond to the concerns raised by Westinghouse's June 18, 1987, 10 CFR 21 report.

Corrective Actions Upon notification from Westinghouse, WPSC immediately began evaluating the CCW system design and licensing bases. The analysis included an evaluation against the nine (9) criteria of ANSI /ANS 56.2-1984~for closed loop system inside containment and a comparison of the double barrier configuration against the original licensing basis. The analysis has proven that the original design bases have been maintained. Therefore, no further actions are necessary.

Additional Information a

Equipment Failure: None Similar LERS: None Related Information:

1. Letter from E. P. Rake, Jr. (Westinghouse Electric Corp.) to R. C. DeYoung (NRC),

transmitting Part 21 report on CCWS overpressurization, dated July 13, 1984.

2. Letter from W. J. Johnson (Westinghouse Electric Corp.) to Mr. Carl Berlinger

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