ML17319B404

Responds to 820505 Generic Ltr 82-10 Re post-TMI Requirements

ML17319B404
Person / Time
Site:	Cook
Issue date:	06/28/1982
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-02-03.B1, TASK-1.A.1.3, TASK-1.C.1, TASK-2-3.B1, TASK-2.D.1, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-RR, TASK-TM AEP:NRC:0678A, AEP:NRC:678A, GL-82-10, NUDOCS 8207020159
Download: ML17319B404 (12)

Text

ACCESSION NBR:

FACIL:50-315 50-316 AUTH. NAME HUNTER'S R. S.

REC IP. MANE DENTOMn H. R.

REGULATOR NFQRNATION DISTRIBUTION EN (RIDB )

8207020 1 59 DOC. DATE: 82/06/28 NOTARIZED:

YES DOCKET 0 Donald C.

Cook Nuclear Pouter Planti Unit fi Indiana 5

050003f5 Donald C.

Cook Nuclear Power Plant.

Unit 2i Indiana 8c 05000316 AUTHOR AFFILIATION Indiana 5 Michigan El e ctric Co.

REC IP IENT AFFILIATION Office o0 Nuclear Reactor Regulationi Director

SUBJECT:

Responds to 820505 Generic Ltr 82-10 re post-TNI requir ements.

DISTRIBUTION CODE:

A046S CQPIEB RECEIUED: LTR

~

ENCL l SIZE:

TITLE: Response to NUREG -0737/NUREG-0660 TNI Action Plan Rgmts (OL's)

NOTES:

REC IP IENT ID CODE/NANE ORB Of BC Of INTERNAL: ELD/HDS3 IE/DEP EPDS NRR/DE DIR 21 NRR/DE/ADNGE 23 NRR/DHFS/DEPY29 NRR/DL/ADL 16 NRR/DL/ADSA 17 NRR/DSI DIR 24 NRR/DBI/ADRP 26 NRR/DSI/AEB NRR/DSI/RAB ADGP 31 04 EXTERNAL'CRB 34 INPOUR J. STARNES NRC PDR 02 NTIB COP IEB LTTR ENCL 7

7.

0 f

1 1

1 1

1 1

1 f

1 1

1 1

1 1

1 1

1 1

1 10 10 1

1 1

1 RECIPIENT ID CODE/NAKE IE/DEP DIR 33 IE/DEP /EPLB NRR/DE/ADCSE 22 NRR/DHFS DIR 28 NRR/DL DIR 14 NRR/DL/ADOR 15 NRR/DL/ORAB 18 NRR/DS I/ADDPS25 NRR/DBI/ADRS 27 NRR/DBI/ETSB NRR/DBT DIR 30 NRR/DBT/ADT 32 RGN3 FENA-REP DIV LPDR 03 NSIC 05 CQPIEB LTTR ENCL 1

1 3

3 1

1 1

1 1

3 3

1 1

1 1

1 1

1 1

2 2

1 TOTAL NUNBER OF COPIES REGUIRED:

LTTR 54 ENCL 53

J'BQIR) tie" 8 N0ITUGIRTBIQ M0ITA<ROWN

'RnTAJUO3R 1 3)I;)DQ 83Y

Q3ZIRAT0M BnsdOXSS

3TAQ.OOQ VaroSOVOSB

RGN NOr883OOA

(!irOOOdO

>8 sncibni 1 finU Jnsl9 veioo9 vselvuN AooD

.3 bl noQ VZCOUJIDA'9 dlP()0080

>8 rnoibnl 9 dinU fnol9 veeo9 vrelvuN

>looO

.0 blsnoa dk8-OV MOITAIJI 9'9A ROHTUA 3NAM.HTUA

.oD vi rfael3 nc pirlviN 8 cnaibni

.8.R R3TNUH MOITAIJI "llh TN'9I9I 03R 3t'1AN.9I 03R vofvezia inoifclugeR vof vsoR vaelouM

%o evil%0

.R.H iMGTM3G IMT-faoq e r Of.-48 vfJ viveneQ dOVOQB of abnoqaeR:T33l HUB

~ ed'n erne 'TlUp 5'r

3SIB i

JON3

~

RTJ:G3VI3O3R 83I90O Bd(OA:3aoa NoiTUGIRTBIQ

( 'O) efmgR naI9 no ifvh INT OdbO-Q3RUMXWCVO" 03RUN of oenoqaeR;3JTIT

83TON 83I l03 JDN3 RTTJ 8

1 8

El Z

I k

k 1

l.

TN3I9 I33R 3HANX3Qua GI aC RIQ 93QX3I 8J93% l3QX3I RR 3BQQAX3GXRRN 8c'IQ Bdl.IQXRRN RXQ JQXRRM Ck RQQAXJQXRRN Bk GAROXJGXRRN c,B89QQAXIBQXRRM WR BRGAXIBGXRRN GBT3% I BGXRRN OC RIQ TBGXRRN 9C TQAXTBGXRRN CNQR VIG 93R-Am9 CO RG9J P.O OIBN 83I9DD JDN3 RTTJ r

O k

1 k

k 1

1' k

k 1

k Ok Ok 1

k TN3I 9I03R 3NANi3000 GI ia aG ke aR0 CBGHXGJ3

.'JANR3TMI BG93 I3Q%3I RIG 3GX RAN BF 3GMQ*%3QXrlRN E'RY93Q~BRHQXRRM hk JGAXJQXRRN ABGAXJQXRRN M

RIG IBQXRRN dR lRQAXIBQXRRN 63AXIBGXRRM QARX IBGXRRN kE: 9QGM,TBQXRRN QO 3JI'9 03R kC BRDA

JANR3TX3 83MRATB.g i09N GO RQ9 ORM BITN Cc'!

JQN3 4P.

RTTJ

'G3RIUMR 83 <900 30 R3GY>UN JATOT

INDIANA II MICHIGAN ELECTRIC COMPANY P. O.

BOX 18 BOWI.ING GRE EN STATION NEW YORK, N. Y. 10004 June 28, 1982 AEP:NRC:0678A Donald C. Cook Nuclear Plant Unit Nos.

1 and 2

Docket Nos. 50-315 and 50-316 license Nos.

DPR-58 and DPR-74 POST-TMI-REQUIREMENTS (GENERIC LETTER NO. 82-10)

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555

Dear Mr. Denton:

This letter and its Attachment respond to Mr. Eisenhut's Generic Letter No. 82-10 dated May 5, 1982.

Very truly yours, RSH/os R.

S. Hunter Vice President cc:

John E. Dolan Columbus R.

W. Jurgensen W. G. Smith, Jr.

Bridgman R.

C. Callen G. Charnoff Joe Williams, Jr.

NRC Resident Inspector at Cook Plant Bridgman BgP7020159

>>0~>~

PDR PDQCK 05000 P'DR

J' 1

OQ I '...;,JhL(.,

STATE OF NEW YORK )

COUNTY OF NEW YORK)

R. S. Hunter, being duly sworn, deposes and says that he is the Vice President of Licensee Xndiana

& Michigan Electric Company, that he has read the foregoing response to Generic Letter No. 82-10 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

R.

. Hunter Subscribed and sworn to before me this 2&-day of ~~no 1982 Notary Public 1UkTH1,EEN ARRI%'~TAIIY Pttttktc, Stein ot No. 41-4606792 Quetified in Queens County Ccsti(iceto lited in Hew York County Conu>>,ssron secures rnerctr 3V, 19'

],I

,r

'l J

Attachment to AEP:NRC:0678A Donald C.

Cook Nuclear'lant Unit Nos.

1 an) 2 Response'o Generic Letter No. 82-10

Attachment to AEP:NRC:00678A The necessary modifications to administrative procedures required to limit overtime in accordance with the NRC policy statement issued by Generic Letter 82-02 dated February 8,

1982 will be completed on or before October 1,

1982.

) Item I.A.1'.3.2 (Minimum Shift Crew)

All of the requirements for shift staffing set forth on pages 3

to 9 of NUREG-0737 will be met on or before July 1, 1982.

Item I:C.l (Revise Emer enc Procedures)

Although the schedule for Revised Emergency Procedures promulgated in NUREG-0737 required implementation by, the first refueling after.

January 1,

1982, we, understand that the NRC Commissioners are presently considering a revised implementation schedule for this Item under the topic of SECY 81-111 entitled "Re'quirements for Emergency Response Capabilities." It is apparent that NRC action on this document is, scheduled for June of 1982 at which time a revised implementation schedule will undoubtedly be published.

However~ it is our current plan to have all Unit 1 and 2 Emergency Procedures revised and issued for use prior to Unit startup following the scheduled Unit 1

and 2 refueling outages for mid-1983 and mid-1984, respectively.

II.D.1.2 (RV & SV Test Pro rams)

As required by this

Item, a

preliminary evaluation which demonstrates the capability of relief and safety valves to operate under

• expected operating and accident conditions was submitted to the NRC in our letter No. AEP:NRC:0585B dated April 7, 1982.

II.D.1.3 (Block Valve Test Pro ram)

Consumers Power Company has transmitted the EPRI report on the Block Valve Test Program o'n our behalf in a letter from Mr.

R.

C.

Youngdahl to Mr. H.

R.

Denton dated June 1,

1982.

,This fulfills our commitment for this Item.

Items II.K.3.30 & 31 (SB LOCA Anal sis)

Implementation of Item II.K.3.31 is dependent on fuel vendor implementation of Item II.K.3.30.

We will implement Item II.K.3.31 within one year following Item II.K.3.30 implementation.

III.A.1.2 (Staff in Levels for Emer enc Situations)

The requirements of the minimum Staffing Levels.for Emergency Situations, as suggested by the

NRC, has previously been addressed, in Table 12-1'ntitled",Donald C. 'ook Nuclear Plant Staffing for Radiological Emergencies" of our upgraded Emergency

Response

Plan for the Donald C; Cook Nuclear Plant, Unit Nos.

1 and 2 submitted to the NRC in our letter No. AEP:NRC:0308B dated January 26, 1981.

Table 12-1 was developed at the Plant as a

result of a

review of the manpower availability in response to a nuclear incident.

Several exceptions were taken to the NRC's suggested requirements and are listed below.

Functional Area NRC 30 min 60 min AEP 30 min, 60 min

'adiological Accident Assessment Offsite Survey Plant System Engineering Coze/Thermal Hydraulic I&C The suggested NRC requirements'ndicate that certain functions may be provided by shift personnel and that minimum manning of the unaffected Unit be limited to three peisonnel.

Our manning requirements, as listed in Table 12-1, allow foz two i'ndividuals from the unaffected Unit to assist in manning or augmenting the affected Unit (1 Control Room operator and 1 Auxiliary operator).

We have defined the time for reasonable "Capability for Additions"

~ as the time from which the individual is notified to the time he reports to the location indicated by the Shift Supervisor.

Thus, while we do not explicitly meet the suggested NRC requirements, we do meet overall total augmentation capability and believe that our levels of staffing are adequate to meet the needs of our Emergency Plan implementing procedures.

As

such, we request an exemption from the specific NRC requirements recommended to be implemented'y July 1, 1982.

'3 Item III.A.1.2 (U rade Emer enc Su ort Facilities)

Unit 1

We curren'tly plan to complete the physical installation of the modifications required by this Item by October 1,

1982.

However, the checkout and debugging time required to fully implement this Item is somewhat uncertain at this point.

As such, we believe that additional time, will be necessary.

We will be in a better position to ascertain how much additional time is necessary by the end of the upcoming scheduled Unit 1

refueling outage.

We will thus inform you of the status of this Item by September 15, 1982.

Unit 2 We will need an extension of the scheduled completion date.

This

'xtension request is based on the fact that the Unit 2 computer will not be delivered until late August and many of the physical modifications must be completed during the upcoming, Unit 2 refueling outage.

In

addition, the checkout and debugging time required to fully implement this item is somewhat uncertain at this tilne.

We. will be in a better position to ascertain how much additional time is necessary after the completion of the Unit 1 system.

We will inform you of the status of this item by January 15, 1983.

Item III.A.2.2 (Meteorolo ical Data)

This Item is basically concerned with three subjects:

(1)

Meteorological Measurements

Program, (2)

Class A

Dose Assessment Capability, and,(3)

Class B Dose Assessment Capability.

The requirement in Generic Letter 82-10 is that "Complete modifications" be done by the "recommended schedule" of October 1,

1982.

Our response to each of these three subjects is given below:

l. Meteorolo ical Measurements Pro ram

'The Donald C.'ook Nuclear Plant has wind speed, direction and temperature sensors on one

tower, the microwave tower on-site.

There are two sensors for each of these measurements, therefore providing

'edundancy.

.The meteorological data can be interrogated at the Plant and remotely.

Since we do not have a second meteorological

tower, we consider one set of sensors as providing the primary meteorological mcasuremcnts system and the redundant sensors a

providing thc backup meteorological measurements system.

In conjunction with our review of the Class B dose assessment

model, we will review the need for a backup meteorological tower.

We will provide the NRC with a

status of our review of a second tower by September 1,

1982.

2. Class A Dose Assessment Ca abilit Currently, there are two mo'dels available for calculating off-site radiation doses.

One, designated CPH002, is an in-house computer program developed',

by AEPSC.

This program uses gross radiation monitor readings of known isotopic concentrations.

It. util,izes meteorological data with a

straight line Gaussian dispersion

model, or it can input X/Q values.

Instantaneous whole body and thyroid dose rates are calculated for a

given release time.

Dose assessment using CPH002 will be performed in the Plant's Technical Support Center and will.be able to be performed in

.the final Emergency Operations Facility.

CPH002 does not directly include estimates of plume dimensions and position, magnitude of peak concentrations,'rrival

times, and projected doses.

However,, the MIDAS,"

system provides dispersion information (X/Q) which may be input into the CPM002 program.

The second dose assessment capability exists through the use of the HIDAS Class A program.

This program is available to us through our consultant Pickard, Lowe and Garrick (PL&G).

This model is basically a

straight-line Gaussian model which takes into account local terrain and pertinent site/plant specific factors such as release

height, exit

'velocity, vent or stack diameter and building wake effects.

According to our consultant the Class A model (ACRISO) meets the specifications on pages 2-3 of NUREG-0654, Appendix 2 in that it includes estimates of plume dimensions and position, magnitude of peak concentrations as well as arrival times, projected doses and time to reach Protective Action Guideline dose levels when isotopes and activities are known.

The ACRISO program can be accessed from the PL&G office and the AEPSC-NX office.

The program will be available for use in the Technical Support Center and in the final EOF.

The application of the Class A model to

.the Cook Plant is limited in that under certain conditions it does not account for the effects of Lake Hichigan.

We will review the MIDAS Class A model with PL&G to determine the effects which the lake, may have in meeting the NRC requirements for a Class

-'A model.

We will also review with PL&G setting up the files to allow us to use the Class A

ACRISO program when the in-Plant radiation monitor readings are known.

We will provide the NRC with a, status of our review by September 1,

1982.

3. Class B Dose Assessment Ca abilit We do not have the capability for a Class B model as defined in NUREG-0654.

A Class B model development is currently under review with our consultant.

No firm schedule is available, as the full extent of the software and hardware requirements are unknown at this time.

'UREG-0737 requests that a description of the Class B model be provided to the NRC by September 1,

1982 and that the Class B model have full operational capability by June 1983.

We will provide the NRC with a status of our review of a

Class B model development by September 1,

1982.

Item III.D.3.4 (Control Room Habitabili~t )

We confirm the commitment date of January 1,

1983 for implementation of the control room habitability modifications given in our letter No. AEP:NRC:0398C dated February 9,

1981.

f

'1 1J v~

I f

r I