ML20081E499

Forwards Final Rept,Response to 10CFR50 App R `Alternate Shutdown Capability,' Supporting Requests for App R Exemptions.Rept Includes Responses to Generic Ltr 81-12 & Evaluation of Component Spurious Operation

ML20081E499
Person / Time
Site:	Point Beach
Issue date:	10/26/1983
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, John Miller Office of Nuclear Reactor Regulation
Shared Package
ML20081E501	List: ML20081E499 ML20081E517
References
GL-81-12, TAC-11070, TAC-11079, TAC-11080, NUDOCS 8311020093
Download: ML20081E499 (3)

Text

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R $W POWER COMPANY 2J1 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE. WI 53201 October 26, 1983 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555 Attention: Mr. J. R. Miller, Chief Operating Reactors Branch 3 Gentlemen:

DOCKET NOS. 50-266 AND 50-301 APPENDIX R EXEMPTION REQUESTS ALTERNATE SHUTDOWN CAPABILITY POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated June 30, 1982, as supplemented on September 29 and October 11, 1982, Wisconsin Electric Power Company requested exemption from the separation requirements of 10 CFR 50, Appendix R, Section III, for certain areas of the Point Beach Nuclear Plant.

Discussions with the staff at a March 22, 1983 meeting in your offices in Bethesda and via telephone on March 25 and 31, 1983 resulted in revisions to the scope of the requested exemptions and preposed modifications. These scope revisions, which now include the provision of alternate shutdown capability for certain

! areas of the Point Beach Nuclear Plant, are described in our letter i dated April 28, 1983, as supplemented on May 31 and July 20, 1983.

l The enclosure to this letter provides a detailed evaluation of alternate shutdown capability for the Point Beach Nuclear Plant.

This evaluation includes consideration of all plant areas which contain safe shutdown required equipment. The enclosure includes l the identification of safe hot shutdown and cold shutdown required systems and components, an evaluation on component spurious operation, a description of modifications proposed to accommodate alternate shutdown capability, responses to Generic Letter 81-12 regarding requirements for alternate shutdown capability, and a description of a fire scenario which demonstrates the adequacy of equipment and manpower available to achieve safe plant shutdown.

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Mr. H. R. Denton October 26, 1983 During the evaluation of alternate shutdown capability, it was determined that the service water pump room and the residual heat removal pump zone do not meet certain specific requirements of Appendix R. Therefore:

1. In accordance with the provisions of 10 CFR 50.12, Wisconsin Electric requests exemption from the requirement of Appendix R,Section III.G.2.b, to separate redundant trains of safe shutdown equipment by a horizontal distance of 20 feet with no intervening combustibles for the service water pump rocm.

2. In accordance with the provisions of 10 CFR 50.12, Wisconsin Electric requests exemption from the automatic suppression system requirement of Appendix R,Section III.G.2.b, for the residual heat removal pump zone.

The technical bases for these exemption requests are provided in Section 6 of the enclosure to this letter.

Our April 28 letter requested exemptions from the three-hour fire barrier requirements of Section III.G.2.a and the automatic suppression system requirements of Section III.G.2.b of Appendix R for the auxiliary building. The supporting information for these exemption requests has been provided in various submittals between July 1977 and May 1983. In order to facilitate staff review of these exemption requests a concise description of the locations of safe shutdown systems and fire protection features within the auxiliary building is also provided in Section 6 of the enclosure.

Wisconsin Electric expects that proposed modifications which do not require plant shutdown will be completed nine months after the date of the staff's Safety Evaluation Report.

4 The alternate shutdown capability evaluation indicates that proposed modifications necessary to satisfy the requirements of Sectionc III.G.2 and III.G.3 which require plant shutdown are applicable to common safe shutdown system components. Per 10 CFR 50.48 (c) (3) and (c) (4) , these modifications are required to be completed during the first refueling outage of the affected unit commencing more than 180 days after staff approval.

The proposed modifications for Unit 2 could be required to be completed during the fall 1984 refueling outage dependent upon

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Mr. H. R. Denton October 26, 1983 the date of staff approval. Wisconsin Electric is already concerned that this would be an unachievable schedule considering the scope of thase proposed modifications. Wisconsin Electric believes that completion of Unit 1 related modifications during the spring 1985 refueling outage and completion of Unit 2 related modifications during the fall 1985 refueling outage would be achievable. Therefore, Wisconsin Electric requests that the schedular requirements of 10 CFR 50.48(c) (3) and (c) (4) be tolled accordingly.

Very truly yours, e

d c3 Vice Presid nt- uclear Power C. W. Fay Enclosure Copy to NRC Resident Inspector