05000316/LER-1982-022, Requests LER 82-022/01T-0 Be Rescinded

Requests LER 82-022/01T-0 Be Rescinded

ML20073B898
Person / Time
Site:	Cook
Issue date:	04/04/1983
From:	Will Smith INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8304120597
Download: ML20073B898 (2)

LER-1982-022, Requests LER 82-022/01T-0 Be Rescinded

Event date:
Report date:
3161982022R00 - NRC Website

text

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tres INDIANA & MICHIGAN ELECTRIC COMPANY vst,,,

DONALD C. COOK NUCLEAR PLANT P.O. Box 458, Bridgman. Michigan 49106 (616) 465-5901 April 4, 1983 Mr. J. G. Keppler, Regional Administrator United States Nuclear Regulatory Commission Region III, 799 Roosevelt Road Glen Ellyn, Illinois 60137 Operating License DPR-74 Docket No. 50-316

Dear Mr. Keppler:

The purpose of this letter is to request that Licensee Event Report 316/82-022/01T-0 be rescinded. This request is based upon a conversa-tion between Mr. D. Wigginton of the Nuclear Regulatory Commission and myself regarding definition of the term " effective date" assigned to Technical Specification amendments.

The Licensee Event Report in question identifies a situation where the implementation of several amended Technical Specification paragraphs appeared to have been compromised due to the method of issuance of the amendments. On March 27,1982, Unit 2 Technical Specification Amend-ment No. 39 was received at the Plant with an effective date of March 11, 1982. At the time of receipt, the Plant staff believed that the effective date specified by the Nuclear Regulatory Comission was synonymous with the required / expected implementation date. Therefore, the Plant was in ap-parent, unavoidable violation of the Tech. Spec., as amended, upon receipt.

The referenced discussion with the Nuclear Regulatory Commission resulted in the understanding that the " effective date" of Technical Specification amendments represents the date that the amendment (s) may be placed into effect, but that actual implementation may allow a reasonable period of time following receipt of the amendment to provide for proper review, training and implementation. Further, it is understood that the NRC Resident Inspector should be kept apprised of planned implementation dates, if other than "immediate," in order to eliminate any confusion in regards to our intent versus the NRC's expectations. The Plant wishes to express appreciation for the NRC's efforts in clarifying this issue.

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m J. G. Keppler April 4,1983 Page Two

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A copy of the aforementioned Licensee Event Report is attached which fully describes the Plant conditions during the time period under discussion.

l Sincerely, LO 3

W. G. Smith, Jr.

Plant Manager WGS:frb cc:

J. E. Dolan R. S. Hunter M. P. Alexich R. F. Kroeger B. Germano E. R. Swanson/N. E. DuBry, R0:III R. C.- Callen, MPSC G. Charnoff, Esq.

J. M. Hennigan R. O. Bruggee, EPRI INP0 PNSRC J. F. Stietzel E. L. Townley D. Wigginton Dir., IE (40 copies)

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SUPPLEMENT TO LER 82-022/0 1T-0 EVENT DESCRIPTION AND PROBABLE CONSEQUENCES (10) h AMENDMENT 39 0F TECH. SPECS. WAS ISSUED ON MARCH 11, 1982. THIS AMENDMENT 1.'s WAS RECEIVED AT THE PLANT MARCH 27, 1982, AT WHICH TIME UNIT 2 HAD BEEN IN THE MODE 5 COLD SHUTDOWN CONDITION FOR ABOUT 16 DAYS AND 20 HOURS.

THE OPERATING PROCEDURES AND SURVEILLANCES IN USE FOR OPERATING IN MODE 5 DID NOT REFLECT THE CHANGES OF AMENDMENT 39 AS WE WERE UNAWARE IT HAD BEEN APPROVED AND ISSUED WITH AN EFFECTIVE DATE OF MARCH 11, 1982 UNTIL IT WAS RECEIVED ON SITE. ADDITIONALLY, AMENDMENT 39 CONTAINED MODIFICATIONS TO THE ORIGINAL SUBMITTAL REQUEST FOR TECHNICAL SPECIFICATION CHANGE ON WHICH WE HAD NOT RECEIVED PRIOR NOTIFICATION AND WERE NOT PREPARED TO IMPLEMENT INSTANTANEOUSLY. AS A RESULT OF THIS SITUATION THE FOLLOWING NONCONFORMANCES TO THE LATEST AMENDED TECHNICAL SPECIFICATIONS;. _..

OCCURRED DURING THE PERIOD'0F MARCH ~12,' 1982'TO MARCH 27, 1982:

3.1.2.3.b.

4.1.2.3.2, 3.5.3 - ACTION C, 4.4.1.1.2a & b, 4.4.9.3.la, c & e, AND 4.5.3.2.~ ~

AMENDMENT 39 TO THE TECHNICAL. SPECIFICATIONS WAS RECEIVED AT THE PLANT ~

ON SATURDAY, MARCH 27, 1982 AT ABOUT 1030 HOURS. ATpiATTIMETHEUNIT WAS IN MODE 5 AT A TEMPERATURE SLIGHTLY LESS THAN-152 F.

A FILL AND VENT OF THE REACTOR COOLANT SYSTEM WAS IN PROGRESS WITH A SUBSEQUENT HEAT-UP PLANNED. UPON RECEIPT OF AMENDMENT 39 AN EFFORT WAS MADE TO LOG THE APPLICABLE SURVEILLANCE REQUIREMENTS AND COMPLY WITH THE TECHNICAL SPECIFICATIONS. DUE TO THE COMPLEXITY OF THE AMENDMENT WE WERE yNSUCCESSFUL

. IN INSURING ALL ITEMS OF THE SPECIFICATION WERE COMPLIED WITH. EXCEPT AS NOTED BELOW THE REACTOR COOLANT SYSTEM WAS RAISED ABOVE 152 F REMOVING MOST OF THE REQUIREMENTS OF THIS AMENDMENT BY 1600 HOURS ON MARCH 27.

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FROM THAT PERIOD UNTIL WE ENTERED MODE 4 AT 2313 HOURS ON MARCH 28,.THE i

SURVEILLANCE.REQUIREMENTTOMgNITORREACTORCOOLANTSYSTEMTEMPERATURE T0. CONFIRM IT TO BE AB0VE 152 F WAS NOT ACCOMPLISHED AT THE FREQUENCY SPECIFIED.

DUE TO THE RCS TEMPERATURE BRIEFLY DIPPING BELOW 152 F DURING FILL AND

' VENT OPERATIONS ON MARCH 27, THE CHANNEL FUNCTIONAL TEST OF THE PORV ACTUATION CHANNELS FOR TECHNICALESPECIFICATION 4.4.9.3.14 WAS PERFORMED ON MARCH 28, 1982 AS WAS THE SURVEILLANCE REQUIREMENT OF 4.4.9.3.le2 TO DETERMINE THE PORY AIR TANK PRESSURE INSTRUMENTATION OPERABLE. THE ALARM SETPOINT FOR ONE OF THE AIR TANKS WAS FOUND TO BE 897 PSIG INSTEAD OF 900 PSI AND WAS ADJUSTED T0 THE CORRECT VALUE.

i A DETAILED STUDY OF THE TECHNICAL SPECIFICATIONS WAS STARTED ON MONDAY, MARCH 29, TO DETERMINE THE NECESSARY-PROCEDURAL CHANGES AND TO IDENTIFY NONCONFORMANCES WHICH HAD RESULTED. THIS REVIEW, ON APRIL 6, 1982, IDENTIFIED THE l

NONCONFORMANCES TO BE REPORTABLE.

AN "0PERATIONS STANDING ORDER" HAS BEEN ISSUED FOR BOTH UNITS WHICH PREVENT EITHER UNIT FROM BEING OPERATED ~

IN CONDITIONS WHERE THE SPECIFICATIONS ARE APPLICABLE UNTIL PROCEDURES i

CAN BE REVISED TO REFLECT THE REQUIREMENTS OF THIS TECHNICAL SPECIFICATION AMENDMENT.

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.THE EVENT DID NOT ENDANGER THE PUBLIC HEALTH AND SAFETY AS THERE WERE NO EVENTS THAT REQUIRED MITIGATION OF OVER-PRESSURIZATION EVENTS AT LOW

3 TEMPERATURE DURING THIS PERIOD.

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