ML20071N652

Provides Addl Clarification of Requirement to Evaluate Common Cause Failure,Per 940606 Meeting W/Nrc Re Listed TS 15.3.7 Basis Paragraph Proposed in 940707 Addendum to TS Change Request 166 Submitted by

ML20071N652
Person / Time
Site:	Point Beach
Issue date:	08/01/1994
From:	Link B WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20071N656	List: ML20071N652 ML20071N657
References
CON-NRC-94-049, CON-NRC-94-49 VPNPD-94-071, VPNPD-94-71, NUDOCS 9408080108
Download: ML20071N652 (2)

Text

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Wisconsin l l lik>CtHC l POWER COMPANY 231 W Mchgan. Po Box 2046. Mawaukoo WI 53201-2046 (414)221 2345 l

VPNPD-94-071 10 CFR 50.4 NRC-94-049 10 CFR 50.90 August 1, 1994 1

Document Control Desk i U.S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 l

I Gentlemen:

DOCKETS 50-266 AND 50-301 ADDENDUM TO TECHNICAL SPECIFICATIONS CHANGE REOUEST 166 MODIFICATION TO TS 15.3.0-LIMITING CONDITIONS FOR OPERATION, 15.3.14-EIRE PROTECTION SYSTEM, 15.3.7-AUXILIARY ELECTRICAL SYSTEMS, AND 15.4.6-EMERGENCY POWER SYSTEM PERIODIC TESTS, POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 In letters dated May 26, 1994 and July 7, 1994, we submitted Technical Specifications Change Request 166 and an addendum, l respectively. This letter provides additional clarification of the requirement to evaluate common cause failure.

In a meeting with the NRC on June 7, 1994, NRC personnel stated ,

that appropriate consideration for common cause failure must be t included. The following Technical Specification 15.3.7 basis paragraph was proposed in the July 7, 1994 addendum:

l The LCOs for the standby emergency power supplies require the redundant standby emergency power supplies to be started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into these LCOs.

l If the standby emergency power supply.LCO is exited j within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the starting of the redundant standby emergency power supplies is not required. If ,

the LCO was entered due to a standby emergency power supply failure and the LCO was exited within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then an evaluation must be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into the LCO to show that the redundant standby ,

power supplies are not susceptible to a common cause failure or the redundant standby emergency power supplies  ;

must be started to prove that a common cause failure does not exist within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into the LCO. -

In continuing discussions with NRC personnel reviewing this change request, it was recommended that we add the further clarification that the common cause failure evaluation be completed as soon as possible within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into the LCO. Additionally, we ,

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would like to clar,1fy the references to "a common cause failure" to' I

9400000108 940001 PDR ADOCK 05000266 P PDR A suMthe ofhmwr umxv Corpratur

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Document Control Desk  ;

August 1, 1994  ;

Page 2 l make these references specific to the situation that caused the LCO entry by using the wording, "that failure by common cause." With the incorporation of these changes, this paragraph states:

The LCOs for the standby emergency power supplies require the redundant standby emergency power supplies I to be started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into these LCOs.

If the standby emergency power supply LCO is exited within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the starting of the redundant standby emergency power supplies is not required. If the LCO was entered due to a standby emergency power supply failure and the LCO was exited within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then an evaluation must be completed as soon as possible within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into the LCO to show that the redundant standby power supplies are not susceptible to that failure by common cause or the redundant standby emergency power supplies nust be started to prove that failure by common cause does not exist within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entry into the LCO.

This change is a further clarification of the standby emergency power LCO. The safety evaluation for the original Technical Specification change request (166) has been reviewed and determined to still be applicable for this clarification. A mark-up of the Technical Specification page (15.3.7-7) that includes this change is attached. This mark-up page supersedes the same numbered page in the previous submittals.

Please feel free to contact us if you have any questions.

Sincerely,

( / A.h33 /, -

t, Bob Link Vice President Nuclear Power Attachment CAC/jg cc: NRC Regional Administrator NRC Resident Inspector Public Service Commission of Wisconsin Subscrijedandswornbgforemeon this I day of k <Af 1994.

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