NPL-97-0484, TS Change Request 199,consisting of Application for Amends to Licenses DPR-24 & DPR-27,removing Requirement in TS to Perform Containment Integrated Leak Rate 60-months from Previous Test

TS Change Request 199,consisting of Application for Amends to Licenses DPR-24 & DPR-27,removing Requirement in TS to Perform Containment Integrated Leak Rate 60-months from Previous Test

ML20210M506
Person / Time
Site:	Point Beach
Issue date:	08/14/1997
From:	Dante Johnson WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20210M513	List: ML20210M515 NPL-97-0484, TS Change Request 199,consisting of Application for Amends to Licenses DPR-24 & DPR-27,removing Requirement in TS to Perform Containment Integrated Leak Rate 60-months from Previous Test
References
NPL-97-0484, NPL-97-484, NUDOCS 9708210438
Download: ML20210M506 (9)

Text

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Wisconsin

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POWER COMPANY Point Beach Nuclear f%nt (414) 755-2321 6610 Nuclear Rd., Two Rtvers. WI 54241 NPL 97 0484 10 CFR 50.4 10 CFR 50.90 August 14,1997 Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station Pl-137 Washington, D.C. 20555 Ladies / Gentlemen

DOCKETS 50-266 AND 50-301 TECIINICAL SPECIFICATIONS CIIANGE REOUEST 199 CONTAINMENT INTEGRATED LEAK RATE TEST POINT HEACII NUCLEAR PLANT. UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.4 and 10 CFR 50.90, Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant Units 1 and 2, hereby requests amendments to Facility Operating Licenses DPR-24 and DPR-27, respectively. The proposed amendments will remove a requirement in the plant Technical Specifications to perform a Point Beach Nuclear Plant Unit 2 4

containment integrated leak rate 60-months from the previous test. The proposed changes will also I update the Specifications and bases to reflect the implementation of the Containment Integrated Leakage r

Rate Test Program as approved by Amendments 169 and 173, to DPR-24 and DPR-27,'espectively.

The 60-month test interval presently specified in Technical Specifications Section 15.6.12,

" Containment Leakage Rate Testing Program," Specification A.1, was allowed as a one time exception to the testing intervals endorsed in Regulatory Guide 1.163, " Performance Based Containment Leak Test g,

Programs." This exception allowed a one-time extension of the interval by approximatel; one year to an.

facilitate the planning and execution of the Unit 2 steam generator replacement outage. The exception E, '

also facilitated the transition of the containment leakage rate test regime from Appendix J, Option A, as previously implemented by the Technical Specifications to a leakage rate test program as allowed by g

Appendix J, Option B, as approved by Amendments 169 and 173.

g Due to the extension of the Unit 2 outage beyond its originally planned duration, a full pressure Type A S

test was performed on the Unit 2 containment in early 1997. This test was successful, demonstrating the Unit 2 containment continues to function as designed. The results of the test are maintained for inspection onsite in accordance with 10 CFR 50, Appendix J, Option B,Section IV. This test fulfills the requirement of Technical Specificadons 15.6.12.A which implements a containment integrated leakage rate test program as allowed by 10 CFR 50, Appendix J, Option B and fulfills the purpose of TS 15.6.12.A.I. Therefore, the test requirement specified in Technical Specifications 15.6.12.A.1 is no i/

l longer necessary and can be deleted. Performing the test as presently required would result in two full 970821043e 970814 pDR ADOCK 050 26 mws fm., c,y %N

NPL 97-0484 Page 2 pressure tests within approximately 6 months. This exceeds the periodicity required by 10 CFR 50, Appendix J, Option B, and the PBNP Containment Leakage Rate Test Program.

The additional changes requested are administrative in nature. The proposed changes correct inconsistencies introduced into the Technical Specifications with the approval of Amendments 169 and 173 to Operating Licenses DPR-24 and DPR-27, respectively.

A description of changes, modified Technical Specifications pages with the proposed changes indicated, a safety evaluation and determination of no significant hazards are included as attachments.

We have determined that the proposed amendments do not involve a significant hazards consideration, authorize a significant change in the types or total amounts of effluent release, or result in any significant inctease in individual or cumulative occupational radiation exposure. Therefore, we conclude that the proposed amendments meet the categorical exclusion requirements of 10 CFR 51.22(c)(9) and that an environmental impact appraisal need not be prepared.

The previous Unit 2 containment integrated leak rate test was performed on October 1,1992. Therefore, we request that the proposed amendments be reviewed and approved prior to October 1,1997. This will

' ensure that we remain in strict compliance with our Technical Specifications. If you have any questions or require additional information, please contact us.

I Sincerely, esg@@ o Douglas F. Johnson Manager, Regulatory Services & Licensing cc: NRC Regional Administrator, Region III NRC Resident Inspector Public Service Commission Attaclunents Subscribed and swom before me on this j v 4 day of Nuw ,1997.

a Yku - (L4 Y/$wni

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Notary Public, SYate of Wisconsin My commission expires 8/go/qr .

Attachm:nt to NPL 97-0484

- Attachment 1 Description of Changes

- Technical Specifications Change Request 199 Containment Integrated Leakage Rate Test Point Beach Nuclear Plant Units 1 and 2 Wisconsin Electric Power Company, licensee for the Point Beach Nuclear P1 ant, is requesting amendments to DPR-24 and DPR-27 for Units 1 and 2, respectively. The purpose of the proposed amendments is to eliminate a containment integrated leak rate test requirement for Unit 2 that is no longer required due to successful _ completion of the test in advance of the expected schedule and to correct inconsistencies in the Technical Specifications and Bases introduced by the approval of Amendments 169 and 173 to DPR-24 and DPR-27 respectively. A description of the present requirements and proposed changes, along with the reason for the change follows.

1. The Bases for Technical Specification 15.4.4 states in part (page 15.4.4-7):

"The purpose of the leakage tests of the isolation valves in the containment purge supply and exhaust lines is to identify excessive degradation of the resilient seals for these valve."

l Proposed change:

l Delete this sentence.

Reason for change:

The test requirements for these valves are no longer explicitly specified in the Technical Specifications. The test requirements and their bases are now controlled by the Containment Leakage Rate Testing Program as required and defimed by Technical Specification 15.6.12. This change is administrative only and should have been accomplished with the issuance of Amendments 169 and 173. Removal of this bases statements does not change the requirement or purpose of performing the required test.

2. The Bases for Technical Specification 15.4.4, Reference (5) is to FSAR Section 6.2.3.

Proposed change:

Delete this reference.

Reason for change:

l w _-____-__

Attachment to NPL 97-0484 Page 2 FSAR Section 6.2.3 contains a design evaluation of the Safety Injection systems including leakage from the systems during the during the long-term recirculation phase operation post-accident. Sys leakage limits were removed from Technical Specification 15.4.4 by Amendments 169 and placed in the Containment Leakage Rate Testing Program. Therefore, deleting this referenc an administrative inconsistency in the Specifications introduced by these amendments. Deletion o the reference does not change the meaning or intent of any Technical Specification requirement.

3. Technical Specification 15.4.2.B.2 presently states:

" Containment isolation valves will be tested in accordance with Technical Specification 15.4.4 instead of Section IWV-3420, Valve Leak Rate Test."

Proposed change:

Revise this Specificetion to read:

" Containment isolation valves will be tested in accordance with the Containment Leakage Rate Testing Program."

Reason for change:

Containment isolation valve test requirements were removed from Technical Specifications Section 15.4.4 and relocated to the Containment Leakage Rate Testing Program as def'med in Specifica 15.6.12. The relocation was approved with Amendments 169 and 173. This requirement should been updated with the amendments. Therefore, this proposed change is administrative corrects an inconsistency introduced with the previous amendments.

4. Technical Specitications 15.6.12.A.1 presently states:

"A program shall be established to implement the leakage rate testing of the containm by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exe This program shall be in accordance with the guidelines contained in Regulatory Guide 1.16

" Performance-Based Containment Leak-Test Program," dated September,1995, as modified the '

following exceptions:

l. The interval between the 1992 Unit 2 Type A test and the next Unit 2 Type A test shall be 60 months."

Proposed change:

Revise this Specification to read:

"A program shall be established to implement the leakage rate testing of the containm by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exe J

Attachment to NPL 97-0484 Page 3 This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163,

" Performance-Based Containment Leak Test Program," dated September,1995."

Reason for change:

The requirement for a one-time Type A test interval of 60 months was added to the Specifications with Amendment 169 and 173 to DPR-24 (Unit 1) and DPR-27 (Unit 2), respectively. The previous test requirements for the Point Beach Nuclear Plant as defined by the Technical Specifications permitted the Type A containment integrated leak rate test to be performed at reduced pressure (< P ).

In order to imnlement the new testing program as defined by Technical Specification 15.6.12 and Regulatory Guide 1,163, a full pressure test is required. Without a full pressure test, the maximum Type A test interval is 48 months. Since the previous Unit 2 type A test was a reduced pressure test performed in the Fall of 1992, testing in accordance with Regulatory Guide 1.163 would have required a Type A test during the Fall 1996 refueling outage, Wisconsin Electric, requested and received approval for a one-time extension of this test interval to 60-months. This would require testing during the then planned fall 1997 refueling outage.

The purpose of this extension was to remove the Type A test requirement from the steam generator replacement outage begun in the Fall of 1996 such that WE resources could focus on the safe replacement of the steam generators in Unit 2, and to allow additional time to adequately plan for a i full pressure test of contaimnent required to implement Option B. Because of the unforeseen extension of the Unit 2 outage, a full pressure test was successfully performed during the Spring of 1997. This test fulfilled the Regulatory 1.163 requirements as implemented in the Technical Specifications. Therefore, the intent of the Technical Specifications 15.6.12.A.1 has been met. This requirement is no longer needed and can be deleted.

If the requirement were not deleted from the Specifications, compliance would result in performance I

of a second Type A test approximately 6 months after the previous successful test. Performance of this test greatly exceeds the regulatory requirements and would present an unnecessary challenge to the containment pressure boundary without a commensurate increase in safety. In addition, due to the delay in the startup of PBNP Unit 2, an outage is no longer scheduled for the Fall of 1997.

- Compliance with the existing Technical Specification requirement would require an unnecessary shutdown of Unit 2.

_a

Attachment to NPL 97-0484 Page 4 Attachment 2 Safety Evaluation Technical Specifications Change Request 199 Containment Integrated Leakage Rate Test Point Beach Nuclear Plant Units 1 and 2 Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant Units I and 2, is requesting amendments to operating licenses DPR -24 and DPR-27, respectively. The purposes of the amendments is to implement changes to the Technical Specifications.

The proposed changes eliminate inconsistencies in the Technical Specifications and Bases introduced with the approval of Amendments 169 and 173 to DPR-24 and DPR-27, respectively. Amendments 169 and 173, as evaluated in the NRC Safety Evaluation Report dated October 0 1996, replaced specific l containment system leakage rate test requirements in the Technical Specifications with a Containment Leakage Rate Testing Program as defined in Technical Specification (TS) 15.6.12, conforming to 10 CFR 50, Appendix J, Option B, and in accurdance with the guidelines in Regulatory Guide 1.163, "Perfonnance-Based Containment Leak-Test Program."

Point Beach Nuclear Plant (PBNP) Technical Specification 15.4.2.B, defines requirements and exceptions for implementation of the Inservice Testing and Inservice Inspection Programs as required by 10 CFR 50.55a. TS 15.4.2.B.2 specifies that testing of containment isolation valves be performed in accordance with Technical Specification 15.4.4 instead of the ASME Code requiremsnts.

Amendments 169 and 173 removed the specific containment isolation valve test requirements from Technical Specification 15.4.4. The specific test requirements were replaced by a Containment Integrated Leakage Rate Testing Program. The Program, required by TS 15.6.12, conforms to 10 CFR 50, Appendix J, Option B, requirements and Regulatory Guide 1.163. Therefore, reference to TS 15.4.4 in TS 15.4.2.B.2 should have been replaced with a reference to the " Containment Leakage Rate Testing Program" at that time. This proposed change is consistent with Amendments 169 and 173  ;

as evaluated in the staff s October 9,1996, Safety Evaluation. This change is administrative only, correcting an inconsistency introduced with the previous amendments and is therefore, acceptable.

A bases change has also been proposed consistent with Amendments 169 and 173 which will eliminate a discussion of the purpose for testing the containment purge supply and exhaust lines and remove a reference to FS AR Section 6.2.3. The testing requirements are no longer explicitly defined in the Technical Specifications. The testing requirements and bases are defined in the Containment Leakage Rate Testing Program. Removal of this discussion from the Bases does not change the meaning or intent of any Specification. In addition, FSAR Section 6.2.3 is not longer applicable to Technical Specifications 15.4.4 with the relocation of the test requirements to the Containment Leakage Rate Testing Program. These changes are administrative only, supported by previous staff safety evaluations and are therefore acceptable.

1

_________J

i .' Attachment to NPL 97-0484 Page 5 Technical Specification 15.6.12.A.1 was added w the Specifications with Amendment 169 and 173 to DPR-24 (Unit 1) and DPR 27 (Unit 2), respectively. This requirement is a one-time exception to Regulatory Guide 1.163 periodicity requirements for the Unit 2, Type A, containment integrated leak rate test.

Prior to the approval of Amendments 169 and 173, the containment integrated leak rate test requirements for the Point Beach Nuclear Plant as defined by the Technical Specifications permitted the Type A containment integrated leak rate test to be performed at reduced pressure (< P ). In order to implement the r cw testing program as defined by Technical Specification 15.6.12 and Regulatory Guide 1.163, a full pressure test is required. Without a full pressure test, the maximum Type A test interval allowed by l

Regulatory Guide 1.163 is 48 months. Since the previous Unit 2 type A test was a reduced pressure test performed in the Full of 1992, testing in accordance with Regulatory Guide 1.163 would have required a Type A test during the Fall 1996 refueling outage. Wisconsin Electric, requested and received approval with Amendinents 169 and 173 for a one-time extension of this test interval to 60-months. This would require testing during the then planned fall 1997 refueling outage, by October 1 1997, 1 The purpose of this extension was to remove the Type A test requirement from the steam generator 3 replacement outage begun in the Fall of 1996 such that WE resources could focus on the safe replacement of the steam generators in Unit 2, and to allow additional time to adequately plan for a full pressure test of containment required to implement Option B. Because of the unforeseen extension of the Uni t2 outage which would subsequently result in a delay of the planned 1997 outage into 1998, a full pressure test was successfully performed during the Spring of 1997. This test fulfilled the Regulatory 1.163 requirements. Therefore, the intent of the Technical Specifications 15.6.12.A.1 has been met. The results of this test are maintained onsite at the Point Beach Nuclear Plant in accordance with 10 CFR 50, Appendix J, Option B,Section IV.

If this requirement were not deleted from the Specifications, compliance would result in' performance of a second Type A test approximately 6 months atler the previous successful test. Performance of this test greatly exceeds the regulatory requirements and would present an unnecessary challenge to the containment pressure boundary without a commensurate increase in safety. In addition, due to the delay in the startup of PBNP Unit 2, an outage is no longer scheduled for the Fall of 1997. Compliance with

- the existing Technical Specification requirement would require an unnecessary shutdown of Unit 2, placing the plant through unne:essary shutdown, cooldown and startup transients. Since the test is not

, . necessary to demonstrate conformance with NRC and industry standards and requirements, and a successful test was performed within the periodicity required by the Specification, this TS requirement has been satisfied. Deleting the requirement from the Specifications is not detrimental to the performance of the containment safety function and eliminates potential risks associated with placing the units through unnecessary transients. Therefore, this change is acceptable.

Issuance of amendments approving the proposed changes eliminate inconsistencies within the Specifications. The Specifications, as amended continue to ensure the affected structures, systems and components perform as designed and analyzed and are therefore acceptable.

, Attachment to NPL 97-0484 Page 6 :

Y ,

l. Attachment 3 Determination of No Significant Hazards Technical Specincations Change Request 199

- Containment Integrated Leakage Rate Test Point Beach Nuclear Plant Units 1 and 2 Wisconsin Electric Power Company, licensee for the Point Beach Nuclear Plant, has evaluated the proposed amendments in accordance with the requirement of 10 CFR 50.91(a)(1), against the criteria in 10 CFR 50.92, and has determined that the operation of the Point Beach Nuclear Plant in accordance with the proposed amendments involves no significant hazards consideration. The evaluation against each of the standards in 10 CFR 50.92 follows:

1. Operation of the Point Beach Nuclear Plant in accordance with the proposed amendments will not result in a significant increase in the probability or consequences of an accident previously evaluated.

The proposed administrative changes correct discrepancies in the Technical Specifications introduced as a result of Amendment x 69 to Operating License DPR-24 for Point Beach Nuclear Plant Unit I and Amendment 173 to Operating License DPR 27 for Point Beach Nuclear Plant Unit 2. -These changes correct references to containment isolation valve testing in the Specifications and Bases.

These amendments were evaluated as acceptable in a safety evaluation dated October 9,1996.

Therefore, these changes do not result in an increase in the probability or consequences of any accident previously evaluated I-The Point Beach Nuclear Plant Unit 2 containment was tested and found acceptable within the maximum interval defined by a one-time Technical Specifications requirement. Subsequent testing will be performed in accordance with the approved testing program defined by Tecimical

- Specifications 15.6.12. Therefore, the Technical Specification requirements are met.' These requirements are established to ensure the containment performs and is maintained as designed and assumed in the safety analyses. The removal of the one-time specific periodicity requirements for the Unit 2, Type A containment integrated leak rate test does not result in a significant increase in the probability or consequences of any accident previously evaluated.

2. Operation of the Point Beach Nuclear Plant in accordance with the proposed amendments will not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes to the Technical Specifications do not change the requirements for the Point Beach Nuclear Plant containments to perform as designed and evaluated in the safety analyses. Test requirements in the Technical Specifications continue to meet the standards evaluated and approved by the NRC to ensure the containments continue to perform as designed and analyzed.

. Administrative discrepancies in the Specifications and bases are also corrected. Therefore, no new or '

different kind of accident from any accident previously evaluated is created. ,

ej

" '? Attachment to NPL 97-0484 Page 7

3. Operation of the Point Hench Nuclear Plant in acenrdance with the proposed amendments does not involve a significant reduction in a margin of safety.

The proposed changes to the Technical Specifications ensure consistency with Amendment 169 to Point Beach Nuclear Plant Unit i Operating License DPR-24 and Amendment 173 to Point Beach Nuclear Plant Unit 2 Operating License DPR-27. Testing of the Unit 2 containment has been performed within the maximum time limit allowed by the one-time test requirement of Technical Specification 15.6.12. Testit.c requirements continue to meet NRC requirements and ensure the containment continues to operate as designed and analyzed. Administrative corrections to the Specifications and bases ensure consistency with previously approved amendments. Therefore, a margin of safety is not reduced.

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