ML20077M375
| ML20077M375 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/10/1995 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-95-002, CON-NRC-95-2 VPNPD-95-005, VPNPD-95-5, NUDOCS 9501120339 | |
| Download: ML20077M375 (6) | |
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231 w Mchoon. PO Box 2046 umexAee.wi 53201 2046 (414)221-2345
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Document Control Desk U.S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:
DOCKETS 50-266 AND 50-301 REOUEST FOR ENFORCEMENT DISCRETION REACTOR MAKEUP WATER CONTAINMENT PENETRATION POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 Wisconsin Electric Power Company, licensee for Point Beach Nuclear Plant, requests enforcement discretion in order to restore the reactor makeup water system in Point Beach Nuclear Plant Units 1 l
and 2 to normal operation.
This request for enforcement discretion is made pursuant to the guidelines of Section VII of tha carotoe-ment policy (10 CFR Part 2, Appendix C).
REQUIREMENT FOR WHICH ENFORCEMENT DISCRETION IS REOUESTED The Limiting Condition of Operation.(LCO) defined by PBNP Technical Specification Section 15.3.6, " Containment System," Specification A.a) specifies containment integrity shall not be violated when a nuclear core is installed in-the reactor unless the unit is in cold shutdown.
Containment Integrity is defined in the PBNP Technical Specifications.
Integrity, in part, requires that all automatic i
containment isolation valves are operable or secured closed.
We are requesting enforcement discretion from the requirements of Specification 1S.3.6.A.a) to allow opening of the Unit 1, 1RC-508, an air operated automatic containment isolation valve for Reactor Makeup Water (RMUW).
We determined, during inservice stroke testing, that the valve is inoperable.
Enforcement discretion is requested to open the valve in order to perform diagnostic testing i
and repairs as needed to provide reactor makeup water to systems in j
containment.
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Document Control Desk January'10, 1995 Page 2 l
The equivalent valve in the Unit 2 RMUW system, 2RC-508, has been determined to be in a degraded condition, but remains operable.
Testing and corrective action to correct the degraded condition may render the valve inoperable for limited periods of time which would require us to secure the valve in the closed position.
Therefore, we are requesting that enforcement discretion from this requirement in order to correct the degraded condition.
The compensatory measures proposed in this request are contained in our Technical Specification Change Request 163, " Modifications to Section 15.3.6,
' Containment System'," dated November 23, 1993.
We request that enforcement discretion be granted or the proposed Technical Specification approved by January 13, 1995.
Regardless of the acceptability of this request for enforcement discretion, we request that processing of our proposed Specifications be expedited.
CIRCUMSTANCES SURROUNDING THE SITUATION On December 10, 1994, stroke testing of 1RC-508 and 2RC-508, reactor makeup water containment isolation valves for Units 1 and 2 respectively, was performed as required by the PBNP Inservice Test Program.
The shut stroke times for the valves exceeded the applicable IST program limits.
The valves were declared inoperable and secured closed until further analysis could be performed.
This analysis determined that the valves were capable of performing their containment isolation safety function and were therefore operable.
Subsequent testing was performed on December 12 and 13, 1994, to determine the cause of the degraded shutting time.
This testing confirmed that Valve 2RC-508 is degraded but still operable.
The results of the test performed on December 13, 1994, showed a significant degradation of 1RC-508 from the previous two tests and was only slightly less than the maximum allowed shut time defined in the Final Safety Analysis Report (FSAR).
Because of this degradation, it was determined that operation of 1RC-508 within the required times could not be asrured.
Valve 1RC-508 was declared inoperable and secured shut in accordance with the Technical Specification requirements.
COMPENSATORY ACTIONS i
When Valve IRC-508 is open, or if Valve 2RC-508 will be inoperable during testing or corrective maintenance, a dedicated operator will be stationed in continuous communication with the control room.
The dedicated operator wil) be directed to secure reactor makeup water flow through the penetration if a valid containment isolation signal
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is received.
a Document Control Desk January 10, 1995 Page 3 This action is consistent with our proposed Technical Specifications for containment isolation valves submitted to the NRC for review and approval by Technical Specification Change Request 163, "Modifica-tions to Section 15.3.6,
' Containment System'," and the provisions contained in NUREG 1431, " Westinghouse Improved Standard Technical Specifications."
This proposed change was submitted on November 23, 1993.
The proposed 2pecifications require in part that, if one valve in a penetration is inoperable, the penetration flow path must be isolated within four hours.
Isolation may be acco.nplished through closing and deactivating an automatic valve or closing a manual valve; use of a blind flange; or securing flow in the cystem with a check valve as the operable containment isolation valve.
The redundant operable isolation for the RMUW isolation is Check Valve RC-529.
By station-ing a dedicated operator to secure flow through the penetration, containment isolation is ensured.
Operating time with Valves 1RC-508 and 2RC-508 inoperable and open during the period of enforcement discretion will be minimized.
SAFETY SIGNIFICANCE AND POTENTIAL CONSEOUENCES Valves 1RC-508 and 2RC-508 are automatic, air operated containment isolation valves on the Unit 1 and Unit 2 RMUW systems respectively.
They are located outside containment on the Reactor Makeup Water (RMUW) supply to the PBNP containments.
RMUW is supplied to the Pressurizer Relief Tank and to standpipes which maintain a back pressure on the reactor coolant pump number two seal to ensure proper seal operation.
Redundant isolation for these penetrations is l
provided by 1RC-529 and 2RC-529, a check valve located inside each containment.
The redundant valves are tested in accordance with 10 CFR 50, Appendix J, local leak rate testing requirements.
There is no safety significance to operation with a dedicated operator stationed to ensure the RMUW penetration is isolated on a valid containment isolation signal.
The second containment isolation valve, RC-529, located inside containment is operable and will isolate the line upon the cessation of RMUW flow.
Operation of PBNP units with the respective RC-508 open but inoperable will be minimized.
Overall containment leakage remains within Technical Specification and 10 CFR 50, Appendix J limits.
l JUSTIFICATION FOR THE DURATION OF THE ENFORCEMENT DISCRETION Enforcement discretion is requested until issuance of the amendments proposed in our Technical Specification Change Request 163.
The proposed determination of no significant hazards was noticed in the Federal Register on January 19, 1994, at 59FR2875.
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Document Control Desk
' January 10, 1995 Page 4 Enforcement discretion is requested to allow opening of Containment Isolation Valve IRC-508 for' routine system operations and testing; and to correct the degraded condition on both valves.
Although operation of the valves in order to maintain reactor coolant pump standpipe level has not been required since the IRC-508 was declared inoperable, experience dictates that the frequency at which fill is required cannot be predicted.
PBNP Technical Specifications require containment isolation valves inoperable for reasons other than excessive leakage to be secured and maintained closed.
Because of this, we have been unable to perform diagnostic testing to determine the cause of the degrading shut time and the action necessary to return the valve to an operable state.
Enforcement discretion and the issuance of the proposed amendments will allow us to return the RMUW system to operation for testing, corrective action, and routine operation in a timely manner.
SIGNIFICANT HAZARDS CONSIDERATIONS We have reviewed this request for significant hezards considerations.
In accordance with 10 CFR 50.92, a significant nazards consideration is created if the requested action:
1.
Significantly increases the probability or consequences of an accident previously evaluated; 2.
Creates the possibility of a new or different type of accident; or 3.
Reduces the margin of safety.
Our evaluation is supported by the proposed no significant hazards consideration published in the Federal Register on January 19, 1994.
Our evaluation against each of the above criterion is summarized below:
criterion 1 Operation of PBNP in accordance with the provisions of this requested enforcement discretion does not result in a significant increase in the probability or consequences of any accident previously evaluated.
The RMUW containment isolation valves in both Units, RC-508 and RC-529, met acceptable local leak rate limits and are capable of performing their safety function of maintaining containment leakage less than the Technical Specification and regulatory limits.
A dedicated operator in continuous communication with i
the control room will be stationed any time Valve RC-508 is open l
I
Document Control Desk January'10, 1995 Page 5 and inoperable for system operation, diagnostic testing, and corrective action.
This dedicated operator will ensure that flow in the RMUW system is secured upon receipt of'a valid containment.
isolation signal.
Failure of a containment isolation valve is not an initiator for any accident that may result in the release of any radioactive substances to the containment or environment.
Therefore, there is not an increase in the probability or consequences of any accident previously evaluated.
Criterion 2 Operation of PBNP in accordance with the provisions of'this requested enforcement discretion will not create the possibility of a new or different type of accident than any accident previously evaluated.
Operation in accordance with this request will not result in a new or different type of accident since the penetration is capable of performing its containment' isolation function.
i criterion 3 i
operation of PBNP in accordance with the provisions of this requested enforcement discretion will not result in a significant reduction in a margin of safety.
Operation in accordance with this request cannot result in a significant reduction in a margin of safety.
Operation with a dedicated operator ensures that this penetration will continue to perform its containment isolation cafety function.
Therefore, a reduction in a margin of safety cannot occur.
ENVIRONMENTAL CONSEOUENCES We have determined that operation in this condition does not involve significant hazards consideration, authorize a significant change a
in the types or total amounts of any effluent release, or result in any significant increase in individual or cumulative occupational radiation exposure.
Therefore, we conclude that this request meets the categorical exclusion requirements of 10 CFR 51.22 (c) (9) ' and that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared.
STATE NOTIFICATION STATEMENT We will notify the Public Service Commission of Wisconsin and the appropriate State of Wisconsin officials of the requested enforcement discretion by copy of this letter in accordance with 10 CFR 50.91(b).
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..6 Document Control Desk January.10, 1995 Pagp 6
SUMMARY
OF COMMUNICATIONS AND APPROVALS The PBNP. Manager's Supervisory Staff (on-site nuclear safety review committee) met and discussed this issue on January 9, 1995, concurred with-the decision to request this enforcement discretion, and concurred with the content of this request.
If you have any questions or require additional information, please contact us.
Sincerely,
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Bob Link Vice President Nuclear Power TGM/jg cc: NRC Resident Inspector i
NRC Regional Administrator i
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