ML17319B446
| ML17319B446 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/21/1982 |
| From: | Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:0723, AEP:NRC:723, NUDOCS 8207270059 | |
| Download: ML17319B446 (8) | |
Text
REGULATORY DEFORMATION DISTRIBUTION SYj4fM (RIDS)
AOCE'SSION NBR:8207270059 DOC ~ DATE: 82/07/21 NOTARIZED:
NO DOCKET ¹ FACIL:50"315 Donald C ~
Cook Nuclear Power Planti Unit ii 1ndiana L
05000315 AUTH NAME AUTHOR AF F IL I ATION RiR,ST Indiana L Michigan Electric Co ~
>RBC IP ~ NAME RECIPIENT AFFIL'IATION DENTONiH,RE Office of Nuclear Reactor Regulation~
Director
SUBJECT:
Requests emergency temporary relief from requirements of Tech Specs 3,9,-9 action >statement while in operating mode 6
(refueling)+Relief needed in order to make -necessary plant desi.'gn changes.
DISTRIBUTION CODE:
A03QS COPIES RECEIVED:LTR g ENCL /
SIZE:,: s TITLE: Containment Purging NOTES:
REC IP IENT ID CODE/NAME ORB ¹1 BC 01 INT>ERNAL: NRR FIELDS' 15 NRR/DE/EQB 09 NRR/DSI ADRS NRR/DSI/CS8 12 NRR/DSI/RAB 11 RGN3 COPIES LTTR ENCL 7
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INOIANA I MICHIGAN ELECTRIC COMPANY P. O.
BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 July 21, 1982 AEP:NRC:0723 Donald C. Cook Nuclear Plant Unit No.
1 Docket No. 50-315 License No. DPR-58
'Technical Specification Relief Request Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
The purpose of this letter is to request an emergency temporary relief from the requireInents of the Technical Specification (T/S) 3.9.9
'Action Statement'hile in operating Mode 6 (refueling).
This matter has been discussed with members of your staff.
We are currently installing new Containment Purge System isolation valves of superior leak tight characteristics as we indicated in our letter No.
AEP:NRC:0370A dated January 15, 1982.
'Replacement of the Lower Containment and Instrument Room valves is scheduled to commence upon entry into Mode 6 which is currently scheduled for the evening of July 21, 1982.
During the course of this installation work in Mode 6 we will not be able to keep each of the affected purge penetrations capable of being isolated by two barriers as required by T/S 3.9.9.
The single barrier will either be a blind flange or a closed purge isolation valve.
The Upper Containment and Pressure Relief line purge. isolation valves have already been replaced.
In addition, we are installing new radiation monitors during this refueling outage.
When installing these monitors, we have to make portions of the existing radiation monitoring equipment inoperable.
The operability of the existing radiation monitors is required in Mode 6 by T/S 3.3.3.1.
The Action Statement of T/S 3.3.3.1 (Action 20) in Mode 6
for Table 3.3-6, Item 2 also requires that the Action Statement of T/S 3.9.9 be applied. For the reasons discussed above we will be able to fulfillthe T/S 3.9.9 Action Statement with only one barrier in Lower Containment and the Instrument Room.
As discussed below, for one train of the installed isolation valves in the upper containment, we will have completed the wiring necessary to provide the capability for automatic closure of those valves upon a high radiation indication.
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Mr. Harold R. Denton AEP:NRC:0723 We are hereby seeking relief of the T/S 3.9.9 Action Statement requirement for the duration of the current refueling(Mode 6), which will last approximately from July 22, 1982 to early September 1982.
This request will allow for the installation of two major plant design modifications during the current Unit 1 refueling outage.
These two modifications (new purge isolation valves and improved radiation monitoring capability) will result in an overall improvement in plant safety once installed.
The new radiation monitors are part of an overall plant Radiation Monitoring System (RMS) upgrade package and include post-TMI requirements.
It is our desire to complete this phase of the RMS upgrade work during the current Unit j outage so that we can have the equipment operational in time to meet the operability dates stated in our letter of December 23, 1981 (AEP:NRC:0652) for the post-TMI items.
The new monitors which initiate closure of the purge isolation
- valves, are a redundant design with each monitor train oriented to a corresponding Class 1E electrical train.
Thus, in the final design, the new monitors will initiate closure of their respective train of Containment Ventilation Isolation (CVI) valves (7 of 14 isolation valves per Unit).
We have already installed one of the two new radiation monitors. It is only when we remove from service the original radiation monitoring equipment (R-ll and R-12) and enter the Action Statement of T/S 3.3.3.1 that we are unable to assure double purge isolation capability as conservatively required by T/S 3.9.9.
The new radiation monitor already installed will be available during this period of time for monitoring purposes.
The wiring of this monitor will also be completed such that it will be capable of automatically isolating those purge isolation valves in its electrical train that become installed and operational or are already installed (upper containment)
During periods of time when no radiation monitor signal is wired to initiate automatic closure of the inside or outside containment valve a man in the Control Room will have the responsibility to initiate manual closure upon high radiation indication or we willmaintain these valves closed.
It is only now, during this refueling outage, when we are replacing the purge isolation valves and are deleting the single train of original RMS equipment and replacing it with equipment of higher quality that we seek this temporary T/S relief.
We have reviewed the accident analysis as presented in the FSAR.
For Mode 6 the most limiting accident inside containment from the stand-point of direct radiation release to the environment is the Fuel Handling Accident.
Purge and vent line isolation is required for this event to limi.t the consequences to those presented in the FSAR.
The requirement to keep one purge isolation barrier closed during 'this relief period is consistent with the analysis.
As such, the consequences of a fuel handling accident inside containment, if one occurred during this time, would be within the limits as analyzed in the FSAR.
Other serious Mode 6 events that could potentially occur are the boron dilution event and the loss of decay heat removal cooling.
While these events are of concern, the safety considerations as far as immediate direct radiatibn release from the containment to
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~ ~r Mr. Harold R. Dento AE C:0723 environment are bounded by the fuel handling accident discussed above.
Other accident analyses presented in the FSAR, such as LOCA and/or
- MSLB, do not apply since neither the Reactor Coolant System nor the Secondar'y System are pressurized.
Hence, granting this T/S relief will not have any adverse impact on public health and safety.
This request for emergency temporary T/S relief has been reviewed by the Plant Nuclear Safety Review Committee (PNSRC) as required by our T/S and will be reviewed by the Nuclear Safety and Design Review Committee (NSDRC) at their next regularly scheduled meeting.
This request for T/S relief allows us to make the necessary plant design changes to implement requirements covered by other NRC reviews.
As such we interpret 10 CFR 170 as requiring that no fee accompany this submittal.
This document has been prepared following Corporate Procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, R, S,'unter Vice President
/md cc:
John E. Dolan Columbus M. P. Alexich R.
W. Jurgensen W. G. Smi.th, Jr.
Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.
NRC Resident Inspector at Cook Plant Bridgman
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