ML17317A896

Forwards Overpressure Protection System Tech Specs & Check for $4,400.00.Believes These Specs Could Potentially Require Addl Reporting W/O Improving High Safety Level in Any Way

ML17317A896
Person / Time
Site:	Cook
Issue date:	01/23/1979
From:	Tillinghast J INDIANA MICHIGAN POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:00083A, AEP:NRC:83A, NUDOCS 7901260149
Download: ML17317A896 (16)

Text

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05 BC c I NTEBNAL: 0 PEG FILE 12 15 MATL ENGR BB 17 AD SYS/PBOJ I

19 BEAC SFTY BB 21 ZECH TA/EDO 02 NRC PDB 14 MECH ENG BB 16 BFAC SYS BB 18 ENGR BR 20 PLANT SYS 'BR OELD I:I 2

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0 REGULATE'NFOR>AAT ION DISTR I RUT IOIYSTE>>I (R I OS ACCESSION NBB:7901260149 DOC.DATF: 79/01/23 NOTARIZED-YES DOCKET 4g FACIL:50-315 Donald C.

Cook Nuclear Power Plant -l, Indiana 8 Mich 050003 l5 50-316 Donald C.

Cook Nuclear Power Plant-2, Indiana 8, Michi 05000316 AUTH ~ NAME AUTHOR AFF I LIATION TILLINGHAST,J.

Indiana

8. Michigan Power Co.

RECI P.NAME RECI P IENT AFFILIATION DENTON,H.R.

Office of Nuclear Reactor Regulation SUBJECT-Forwards Overpressure Protection System Tech Specs for each Unit of facility 8, check for 4,400.00.Believes these specs 0

could potentially require addi reporting w/o improving high safety level in any way.

DISTRIBUTION CODE:

AO.I OS C()PI ES RECEI VED-LTB ~ FNCL SI ZE: gQ TITLE: REACTOR VESSEL OVERPRESSURI ZATION DIST.

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INDIANA II MICHIGAN POWER COMPANY P. O. BOX 18 BO WLIN G G RE EN STATION NEW YORK, N. Y. 10004 January 23, 1979 AEP: NRC:00083A Donald C. Cook Nuclear Plant Unit Nos.

1 and 2

Docket Nos.

50-315 and 50-316 License DPR Nos.

58 and 74 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory COIImission Washington, D. C.

20555

Dear Mr. Denton:

This letter is in response to Mr. A. Schwencer's letter of August 28, 1978, wherein we were requested to submit Overpressure Protection System Technical Specifications for the Donald C.

Cook Nuclear Plant Units 1 and 2.

The attachments to this letter contain a complete set of proposed Technical Specifications for each unit of the Cook Plant.

The model Technical Specifications contained in Mr. Schwencer's letter were used as guidance in the preparation of these Technical Specifications.

However, our proposed Overpressure Protection System Technical Specifications are written in a revised format from that contained in Mr. Schwencer's letter.

This format better reflects the Overpressure Protection Systems that are available in the Cook Plant.

This is accomplished by the requirements to have certain equipment inoperable, restrictions on the startup of Reactor Coolant Pumps and the installed Overpressurization Mitigating System in accordance with our previous submittals on this issue.

Please note that no revisions to our current Specifications 3/4.1.2.3, 3/4.5.3 and 3/4.4.1 are necessary when the overpressure protection requirements are written in our proposed format.

We wish to point out that sufficient operating procedures are currently in use to alleviate the operability and surveillance concerns in Mr.

Schwencer

's letter.

The Overpressure Protection System Technical Specifications could potentially require additional reporting while in no way improving the already high level of'afety at the Cook Plant.

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s Mr. Harold R.

Denton AEP: NRC:00083A January 23, 1979 The Overpressure Protection System Technical Specifications have been reviewed by the PNSRC and the required membership of the AEPSC NSDRC.

The results of these reviews indicate that the subject Technical Specifications will not adversely affect the health and safety of the general public.

As indicated in Mr. Schwencer's letter, this is a Class III Amendment per the provisions of 10 CFR 170.22 and requires a payment of

$4,000.00 for Unit 1 of the Cook Plant, and a payment of $400.00 (Class I

Amendment) for Unit 2.

A check for $4,400.00 accompanies this submittal.

Very truly yours, JT:em nghas ice President Sworn and subscribed to before me this => day of January, 1979 in New York County, New York Notary Public cc:

(attached)

~A'iHi Ek tvARRY NCr1ARY fOt',llC, State of New York No.

41-4606'i'ualified in Queens County Certificrtte filed in New York County l onunrssion szprres trrrarch 30, 197$

L

Mr. Harold R.

Denton AEP:NRC:00083A cc:

R.

C. Callen P.

W. Steketee G. Charnoff R. Walsh R.

W. Jurgensen D. V. Shaller - Bridgman R. J. Vollen

OVERPRESSURE PROTECTION SYSTEMS 3 4.4.11 REACTOR COOLANT LOOPS NORMAL OPERATION LIMITING CONDITION FOR OPERATION 3.4.11 lhe reactor coolant pumps shall not be started whenever the 'RCS cold leg temperature is ( 188 F unless:

a)

Each steam generator shell side temperature is not more than 50oF above the corresponding RCS cold leg temperature, or b)

The RCS is not in a water solid condition APPLICABILITY:

MODE 5 SURVEILLANCE RE UIRFMENTS 4.4.11. Prior to the start of a reactor coolantpump in an idle loop the temperature of the steam generator shell side shall be verified to be not more than 50oF above the temperature of the RCS cold leg.

D::

C.

COOK - UNIT 1

3/4 4-41

OVERPRESSURE PROTECTION SYSTEtiS 3/4.4.12 OVERPRESSURIZATION jlITIGATING SYSTEM LIMITING CONDITION FOR OPERATION 3.4.12 At least one of the following overpressurization mitigating systems shall be OPERABLE:

a)

Two power operated relief valves (PORVs) with an activation setpoint of

< 435 psig, or b)

The RHR system safety valve with a liftsetting of

< 450 psig, or c)

A reactor coolant system vent

> 2 square inches APPLICABILIT; WHEN THE RCS IS WATER SOLID AND THE TEMPERATURE OF ONE OR tdORE OF THE RCS COLD LEGS IS < 188oF EXCEPT DURING NODE 6 ACTION:

a)

With one PORV inoperable and the RHR Safety Valve not available either restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a

2-square inch vent within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored to OPERABLE status.

b)

With both PORVs inoperable and the RHR Safety Valve not, available depressurize and vent the RCS through a

2 square inch vent within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored to OPERABLE status.

c)

In the event either the PORVs or the RHR Safety Valve or the RCS vent are used to mitigate a

RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.

The report shall describe the circumstances initiating the transient, the effect of the

PORVs, RHR Safety Valve, or vent on the. transient and any corrective action necessary to prevent re'currence.

d)

The provisions of Specification 3.0.4 are not applicable.

D.

C.

COOK UNIT 1

3/4 4-42

REACTOR COOLANT SYSTEM SURVEILLANCE RE UIREMENTS 4.4.12.1 Each PORV shall be demonstrated OPERABLE by:

.a)

Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation

channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required OPERABLE and at least once per 31 days thereafter when the PORV is required OPERABLE.

b)

Performance of a CHANNEL CALIBRATION on the PORV actuation channel at least once per 18 months.

c)

Verifying the PORV isolation valve is open at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the PORV is being used for over-pressurization protection.

d)

No additional Surveillance Requirements other than those required by Specification 4.0.5.

4.4.12.2 a)

The RHR Safety Valve shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by veri'fying that the RHR system suction is aligned to the RCS loop wtth the valves i'n the flow path open, b)

No by

4. 4.12. 3 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s*

additional Surveillance Requirements other than those required Specification 4.0.5.

The RCS vent shall be verified to be open at least once per when the vent is being used for overpressure protection.

Except when the vent pathway is provided with a valve which is locked,

sealed, or otherwise secured in the, open position, then verify these valves open at least once per 31 days.

D.

C.

COOK - UNIT 1

3/4 4-43

OVERPRESSURE PROTECTION SYSTEMS ECCS SUBSYSTEMS T Av

. < 200oF LIMITING CONDITION FOR OPERATION 3.5.6 Whenever the temperature of one or more of the RCS cold legs is

< 188 F, except where Surveillance Requirements prescribed by other Specifications are man-

dated, the following conditions shall apply:

a)

A maximum of one charging pump shall be OPERABLE.

b)

Both safety injection pumps shall be INOPERABLE.

APPLICABILITY:

MODE 5 DURING WATER SOLID OPERATION SURVEILLANCE RE UIREMENTS 4.5.6 At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one of the RCS cold legs is

< 188 F

demonstrate that all charging pumps and safety injection pumps, except those otherwise required to be operable, are INOPERABLE by verifying that the motor circuit breakers have been disconnected from their electrical power supply circuit.

D.

C.

COOK - UNIT 1

3/4 5-11

OVERPRESSURE PROTECTION SYSTEMS BASES 3/4 5.6 ECCS SUBSYSTEMS Tavg < 200 F

The limitation for a maximum of one charging pump to be

operable, both safety injection pumps to be inoperable and the Surveillance Requirements to demonstrate"the safety injection pumps and the other

~ charging pumps to be inoperable below 188oF during water solid operation, provides assurance that a mass addition pressure transient can be relieved by the operation of single PORV.

3 4.4.11 REACTOR COOLANT LOOPS The limitation of a maximum 50 F temperature difference between the Steam Generator shell si'de and the RCS cold legs during water solid operation upon startup of a reactor coolant pump in an idle loop provides assurance that a heat addition pressure transient can be relieved by the operation of a si.ngle

PORV, 3/4.4.12 OVERPRESSURIZAT ION MITIGATING SYSTEM The OPERABILITY of two PORVs, the RHR Safety Valve, or an RCS vent opening of 2 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are

< 188 F.

Each PORV or RHR Safety Valve has adequate relieving capability to protect the RCS from overpressurization when the transient is limited to either (1) the start of an idle RCS with the secondary water temperature of the steam generator

< 50 oF above the RCS cold leg temperature or (2) the start of a charging pump and its injection into a water solid RCS.

D.

C.

COOK - UNIT 1

B3/4 4-13

OW OVERPRESSURE PROTECTION SYSTEMS 3/4.4.11 REACTOR COOLANT LOOPS NORMAL OPERATION LIMITING CONDITION FOR OPERATION 3.4.11 The reactor coolant pumps shall not be started whenever the RCS cold leg temperature is

< 152 F unless:

a)

Each steam generator shell side temperature is not more than 50 F above the corresponding RCS cold leg temperature, or b)

The RCS is not in a water solid condition APPLICABILITY:

MODE 5 SURVEILLANCE RE UIREHENTS I

4.4.11 Prior to the start of a reactor coolant pump in an idle loop the temperature of the steam generator shell side shall be verified to be not more than 50 F above the temperature of the RCS cold leg.

D:

C.

COOK - UNIT 2 3(4 4 30

OVERPRFSSURF PROTECT'ION SYSTa~S 3/4.4. 12 OVERPRESSUR IZATION MITIGATING SYSTEM e

LIMITING CONDITION FOR OPERATION 3.4.12 At least one of the following overpressurization mitigating systems shall be OPERABLE:

a)

Two power operated relief valves (PORVs) with an activation setpoint of

< 435 psig, or

~b)

The RHR system safety valve with a liftsetting of

< 450 psig, or J

c)

A reactor coolant system vent

> 2 square inches APPLICABILITY'lHENTHE RCS IS INTER SOLID AND THE TEMPERATURE OF ONE OR tdORE OF THE RCS COLD LEGS IS < 152oF, EXCEPT DURING NODE 6 ACTION:

a)

With one PORV inoperable and the RHR Safety Valve not available either restore'the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a

2 square inch vent within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored 'to OPERABLE status.

b)

'llith both PORVs inoperable and the RHR Safety Valve not, available depressurize and vent the RCS through a

2 square inch vent within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored to OPERABLE status.

c)

In the event either the PORVs or the RHR Safety Valve or the RCS vent are used to mitigate a

RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.

The report shall describe the circumstances initiating the transient, the effect of the PORVs,RHR Safety Valve, or vent on the transient and any corrective action necessary'o'revent recurrence.

d)

The provisions of Specification 3.0.4 are not applicable.

D.

C'.

COOK - UNIT 2 3/4 4-3I

REACTOR COOLANT SYSTEtl SURVEILLANCE RE UIRENENTS 4.4.12.1 Each PORV shall be demonstrated OPERABLE by:

a)

Performance of a'HANNEL FUNCTIONAL TEST on the PORV actuation

channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required OPERABLE and at least once per 31 days thereafter when the PORV is required OPERABLE.

l bi)

Performance of a CHANNEL CALIBRATION on the PORV actuation

'channel at least once per 18 months.

c)

Verifying the PORV isolation valve, is open at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the PORV is being used for over-pressurization protection.

d)

No additional Surveillance Requirements other than those required by Specification 4.0.5.

4.4.12.2 a)

The RHR Safety Valve shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the RHR system suction is aligned to the RCS loop with the valves in the flow path open.

b)

No additional Surveillance Requirements other than those required by Specification 4.0.5.

4.4.12.3 The RCS vent shall be verified to be open at least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s*

when the vent is being used for overpressure protection.

Except when the vent pathway is provided with a valve which is locked,

sealed, or otherwise secured in the open position, then verify these valves open at least once per 31 days.

D.

C.

COOK - UNIT 2 3/4 4-32

OVERPRESSURE PROTECTION SYSTEMS ECCS SUBSYSTEl'lS T Av 200 F

LIMITING CONDITION FOR OPERATION 3.5.6 Whenever the temperature of one or more of the RCS cold legs is 152 F,

except where Surveillance Requirements prescribed by other Specifications are man-

dated, the following conditi.ons shall apply:

a)

A maximum of one charging pump shall be OPERABLE.

b)

Both safety injection pumps shall be INOPERABLE.

APPLICABILITY:

NODE 5 DURING l4ATER SOLID OPERATION SURVEILLANCE RE UIRENENTS 4.5.6 At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one of the RCS cold legs is

< 'b2 F

demonstrate that all charging pumps and safety injection pumps, except those otherwise required to be operable, are INOPEPABLE by verifying that the motor circuit breakers have been disconnected from their electrical power supply circuit.

D.

C; COOK - UNIT 2 3/4 5-11

OVERPRESSURE PROTECTION SYSTENS

e BASES 3/4 5 6 ECCS SUBSYSTEMS Tavg < 200 F

The limitation for a maximum of one charging pump to be

operable, both safety injection pumps to be inoperable and the Surveillance Requirements to demonstrate the safety injection pumps and the other charging pump'to be inoperable below 152 oF during water solid operation, provides assurance that a mass addition pressure transient can be relieved by the operation of single PORV.

3 4,4.11 REACTOR COOLANT LOOPS The limitation of a maximum 50 F temperature difference between the Steam Generator shell side and the RCS cold legs during water solid operation upon startup of a reactor coolant pump in an idle loop provides assurance that a heat addition pressure transient can be relieved by the operation of a single PORV.

3/4.4. 12 OVERPRESSUR IZATION f1ITIGATING SYSTEM The OPERABILITY of two PORVs, the RHR Safety Valve, or an RCS vent opening of 2 square inches ensures that the RCS will be protected from pressure transients

'which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are 152 F.

Each PORV or RHR Safety Valve has adequate relieving capability to protect the RCS from overpressurization when the transient is limited to either (1) the

'tart of an idle RCS with the secondary water temperature of the steam generator

< 50 oF above the RCS cold leg temperature or (2) the start of a charging pump and its injection into a water solid RCS.

D.

C.

COOK - UNIT 2 83/4 4-11