NPL-99-0086, Documents Commitment Change Which Is to Discontinue Actions Contained in Util Ltr Dtd 970613,after NRC Approval of LAR & Lower Containment Leak Rate Limit Is Implemented. Change Is Acceptable IAW Applicable Plant Procedure
| ML20207B163 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/24/1999 |
| From: | Kaminskas V WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NPL-99-0086, NPL-99-86, NUDOCS 9903080024 | |
| Download: ML20207B163 (3) | |
Text
.
Wisconsin Electnc POWER COMPANY Point Beoch Nuclear Plant (920) 755-1321 6610 Nuclear Rd.. Two Rivers, WI 54241 NPL 99-0086 10 CFR 50.71 February 24,1999 U. S. Nuclear Regulatory Commission i
Document Control Desk Mail Stop Pl-137 Washington, D.C 20555 Ladies and Gentlemen:
DOCKETS 50-266 AND 50-301 NOTIFICATION OF COMMITMENT CHANGE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 This letter is provided to document a commitment change that Wisconsin Electric (WE) is implementing at the Point Beach Nuclear Plant (PBNP). PBNP has evaluated this commitment change in accordance with the applicable plant procedure which complements the Nuclear Energy Institute's " Guideline for Managing NRC Commitments," Revision 2, December 19,1995, and has concluded that this change is acceptable.
Background Discussion of Commitments and Justification for Change:
In a letter from WE to the NRC dated June 13,1997 (reference NPL 97-0351), WE commited to take several actions. This letter provided information to supplement Technical Specification Change Request (TSCR) 192, which was a request to change sections of the Technical Specifications (TS) including TS 15.3.3 "ECCS, Auxiliary Cooling Systems, Air Recirculation Fan Coolers, and Containment Spray,"
TS 15.3.7 " Auxiliary Electrical Systems," and 15.5.2 " Containment," to resolve issues related to operation of the Service Water System.
The letter contained the below identifed commitments and provided additional details concerning the operability and operation of systems, structures, and components that impact control room ventilation and habitability:
(1)
Performance of monthly leakage inspections of accessible portions of the emergency core cooling systems (ECCS) outside containment that could contain recirculated fluid from i
the containment during a loss-of-coolant accident.
.*1 9903080024 990224 r pDR ADOCK0500g6
@)
T3 l
l
. - - -- -= -
- -~-
4-I NPL 99-00861
^
' February 24,1999 Page 2 t
n
. (2)' = Inspecting accessible, pressurized ECCS piping outside containment during quarterly l
- inservice testing.
(3)
Performance of the leakage reduction and preventive maintenance program tests for the ECCS during any cold shutdown outage of sufficient duration (about 5 days or longer) in which 6 months or more has elapsed since the previous testing.
- (4)
Performance of corrective action based on the results of these inspections and tests to ensure ECCS leakage remains as low as reasonably achievable.
(5)
Perfonnance of periodic inspections of the control room ventilation system to verify adequacy of material conditionc (6)-
Increased testing of the control room ventilation system filters to approximately 6-month
' intervals.
These commitments supplement and are in addition to PBNP license and Technical Specification j
requirements. The commitments were subsequently restated by the NRC in the cover letter transmitting
)
License Amendments 174 and 178, dated July 9,1997, and the corresponding Safety Evaluation, as additional' assurance that the assumptions made in the dose calculations would not be exceeded.' These i
amendments approved the Technical Specification changes proposed in TSCR 192. NRC approval was contingent on WE implementing the following license conditions (summarized for brevity): submitting
- a license amendment application by February 27,1998, that contains the proposed methods for compliance with GDC 19 " Control Room" dose limits under accident conditions based on system design and without reliance on the use of potassium iodide and/or supplied air breathing apparatus;
)
' implementing the proposed changes within two years of the date that the NRC approval for the proposed
- license amendment is granted; and operating the PBNP in accordance with its service water system analyses and approved procedures. The six commitments cited were not identified as a license condition.
Accordingly, PBNP submitted TSCR 204 " Control Room Habitability" on February 26,1998, to comply
. with the first license condition. TSCR 204 proposed that the commitments described above and j
. contained in NPL 97-0351 be discontinued after NRC approval of TSCR 204. Specifically, TSCR 204 1
stated, in part, " Implementation of the lower containment leak rate limit provider additional assurance
. that the predicted dose under the current large break loss of coolant analyses would be substantially lower. Therefore, we propose to discontinue the actions contained in Wisconsin Electric letter dated i
June 13,1997 (NPL-97-0351), after NRC approval of this license amendment request and the lower l
containment leak rate limit is implemented."
i t
t As documented in TSCR 204, administratively reducing the containment leak rate limit from 0.4 weight -
percent per day to 0.2 weight percent per day provides additional assurance that the predicted dose under
. the current large break loss of coolant accident would be substantially lower. Reduction of the design allowable leakage rate from containment is based on the use of this reduced leakage rate in analyses performed to show that the control room dose will remain within the limits of 10 CFR 50, Appendix A, GDC 19. ' The letter transmitting TSCR 204 included discontinuing the six compensatory actions once i:
~
' f.l 4
p l
4
,, - - L NPL 99-0086
~ February 24,1999.
Page 3
'this lower leak rate was adopted. WE is administratively adopting the lower leak rate now, therefore the compensatory action commitments identified above are being discontinued. The results of containment integrated leak testing performed in 1997 on each unit at 60 psig were well below the lower leak rate limit of 0.2 weight percent'per day (total leakage on each unit was approximately 0.1 weight percent per day).
Should you have any questions on this letter or require additional information, please contact me.
Sincerely, L
WP Vito A. Kaminskas.
- Manager, Regulatory Services & Licensing Point Beach Nuclear Plant MAW / tat cc:
NRC Regional Admimstrator NRC Project Manager NRC Resident Inspector PSCW
_ _ _ _ _ _ _ - _ _ _ _ _