ML20112H164

Forwards Rev 2 to Inservice Testing Program,Point Beach Nuclear Plant Units 1 & 2, as Part of Pump Relief Request 9.Requests That NRC Grant Interim Approval for Pump Relief Request

ML20112H164
Person / Time
Site:	Point Beach
Issue date:	03/28/1985
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, John Miller Office of Nuclear Reactor Regulation
Shared Package
ML20112H170	List: ML20112H164 ML20112H172
References
NUDOCS 8504020161
Download: ML20112H164 (3)

Text

WISCONSIN Electnc rowra coursur 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 March 28, 1985 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 INSERVICE TESTING PROGRAMS FOR PUMPS AND VALVES POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated January 16, 1984, Wisconsin Electric Power Company (Licensee) submitted the Point Beach Nuclear Plant, Units 1 and 2, pump and valve inservice test programs and associated relief requests. Subsequent to the above submittal, we have determined that one additional pump relief request is necessary to allow for an optimum testing program. Thus, we are hereby submitting pump relief request No. 9 for your review and approval. Pump relief request No. 9 is submitted in addition to the relief requests submitted in January 1984. All of the relief requests submitted January 1984 are still valid.

In a letter dated February 29, 1984 we committed to adding the reactor coolant vent system to the inservice test program and to providing you with an amended program. Thus, in view of our commitment, we have revised the program to include the applicable valves of the reactor coolant gas vent system and have attached the revised programs. This Revision 2 also includes minor changes of an editorial nature. These changes include correcting typographical errors and updating piping and instrumentation diagram coordinate locations to reflect current drawing revisions.

The attached inservice testing programs for Point Beach Units 1 and 2 were developed in compliance with the rules and regulations of 10 CFR 50.55a and Section XI of the ASME Boiler and Pressure Vessel Code, 1977 Edition through Summer 1979 Addenda.

These programs are for the 120-month interval, as stipulated in 10 CFR 50.55a (g) (4) (ii) . These programs are to replace in their entirety the previous submittals for pump and valve testing for 8504020161 850320 ~1-i PDR ADOCK 05000266 P PDR

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Mr. H. R. Denton March 28, 1985 both units. These new programs are submitted for your review.

The requested reliefs are submitted for your review and approval.

The reliefs requested and the bases for the reliefs are presented in Appendices " A" and "B" for the pump and valve testing programs, respectively. As discussed in the basis for each relief requested, we believe that conformance with the specific code requirement is impractical for the Point Beach facility and that pursuant to 10 CFR 50.55a(g) (6) the Commission is authorized to grant such relief.

On February 12, 1979, the Commission published in the Federal Register a notice concerning a revision to 10 CFR 50.55a which changed the basis for inservice inspection and testing requirements for safety class components of nuclear power plants.

The revised regulation requires that all nuclear power facilities meet, to the extent practical, the inservice inspection and testing requirements of Section XI of the ASME Boiler and Pressure Vessel Code, as specified in 10 CFR 50.55a(b) . Licensees were required at that time to update their inservice testing programs every 20 months.

Wisconsin Electric filed License Amendment Request Nos.

42 and 58 on February 17, 1977 and November 27, 1978 for Point Beach Nuclear Plant, Units 1 and 2, respectively, for Technical Specification changes necessitated by the revised inservice testing requirements, as required by the Code of Federal Regulations. To date, only certain portions of the requested license amendments have been reviewed and approved by the NRC.

The Technical Specification changes previously referenced stand in agreement with these revised programs and should be expedited. As we have previously stated, it is our position that approval of these outstanding Technical Specification change requests need to be completed prior to implementation of these new inservice testing programs. However, pursuant to your order transmitted by letter dated March 4, 1985, the subject inservice testing programs will be implemented in conjunction with the existing Technical Specification testing requirements.

Previously, we have estimated that program implementation could be accommodated within 90 days. This estimate was based upon receiving your approval of the relief requests and Technical Specification changes. However, without receiving approval of the Technical Specification changes, a significant amount of additional manpower is required to establish interim testing programs. The schedule impact of this additional effort is magnified by the n.anpower requirements associated with the Unit 1 Refueling 12 outage. This outage is concurrent with a large portion of the implementation period and represents a

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la Mr. H.'R. Denton March 28, 1985-major in-house effort due to the associated activities, including control rod guide tube split pin replacement. Thus, we'are requesting that you extend the implementation period to accommodate an August 1, 1985 implementation deadline.

During our review, it is possible that additional instrumentation may be needed to meet some requirements of the combined Technical Specification and inservice testing program.

These instrumentation. requirements should be identified early in the review process. If any instrumentation additions will delay the full implementation schedule, you will be notified as soon as this information becomes available.

. In view of your requirement for implementation based

on preliminary review, we are also requesting that interim approval for pump relief request No. 9 submitted with this letter also be granted.

Should you have any questions regarding the attached programs or require additional clarification or details, please contact us.

Very truly yours, h/

dd a Vice President-Nuclear Power C. W. Fay Enclosures Copy to NRC Resident Inspector

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