ML17320A489
| ML17320A489 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/13/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17320A488 | List: |
| References | |
| NUDOCS 8304270206 | |
| Download: ML17320A489 (5) | |
Text
~y,% RE'Qy l
C J'NITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
?1 TO FACILITY OPERATING LICENSE NO.
DPR-58 AND AMENDMENT NO. 53 TO FACILITY OPERATING LICENSE NO.
DPR-74 INDIANA AND MICHIGAN ELECTRIC COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 AND 2 DOCKET NOS. 50-315 AND 50-316 830427020b 8304f3 PDR ADOCK 050003f5 P
PDR By letter dated November ll, 1981, the Indiana and Michigan Electric Company (the 1icensee) proposed changes to the Technical Specifications (TSs) appended to Facility Operating License Nos.
DPR-58 and DPR-74 for the Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2.
The proposed changes revise the surveillance requirements for safety-related hydraulic snubbers.
The proposed changes are consistent with the sample TSs provided to the licensee by letter dated November 20, 1980,- except for modifications made fo the sample TSs to reflect the Cook Plant design (e.g.
the lack of safety-related mechnical snubbers).
By letter dated February 25, 1983, the licensee supplemented their application by revising the wording of section 4.0.5 to the Technical Specifications to include the Standard Technical Specification requirements for inservice inspection and testing.
This change was necessary since the snubber Technical Specifications surveillance referenced the section 4.0.5.
BACKGROUND To reflect accumulated experience obtained from operating plants in the past several years, NRC issued Revision 1 of the Standard Technical Specifications on the surveillance requirements for safety-related snubbers.
On November 20, 1980, this document was transmitted to operating plants excluding those under the Systematic Evaluation Program.(SEP) along with a request for submittal of appropriate. license amendments to incorporate the requirements of this revision.
The same request was extended to SEP plants on March 23, 1981.
DISCUSSION AND EVALUATION The existing TS surveillance requirements for safety-related snubbers were generically incomplete and somewhat deficient in the following areas:
1.
Mechanical snubbers were not included in the surveillance requirements.
2.
The rated capacity of snubbers was not used as a limit to the inservice test requirement.
3.
NRC approval was hecessary for the acceptance of seal materials.
4.
Inservice test requirements were not clearly defined.
5.
In-place inservice testing was not permitted.
P
>(.W Since mechanical snubbers wer'e not subject to any surveillance requirements, some licensees and permit holders believed that mechanical snubbers were pre-ferred by NRC.
Many plants used mechanical snubbers as original equipment and many others requested to replace their hydraulic snubbers with mechanical ones to simplify or avoid an inservice surveillance program.
This is directly contradictory to NRC's intention, where for an unsurveyed mechanical
- snubber, the most likely fai'lure is permanent lock-up.
This failure mode can be harm-ful to the system during normal plant operations.
This concern is not directly applicable to the Donald C.
Cook Nuclear Plant as mechanical snubbers are not employed on safety-related systems.
When the first hydraulic snubber surveillance requirements in the Technical Specifications were drafted, the testing of snubbers was limited to those with rated capacity of not more than 50,000 lbs.
This was because of the available capacity of the test equipment and the requirement to test some parameters at the snubber rated load.
Since then,.greater equipment capacity and better understanding of parametric correlation have been developed.
Therefore, the limit of 50,000 lbs.
has been removed.
Testing of snubbers was usually accomplished by removing snubbers from their installed positions, mounting them on a testing rig, conducting the test, removing them from rig, and reinstalling them to She working position.
Many snubbers were damaged in the removing and reinstallation process.
This defeated the purpose for conducting tests.
Since methods and equipment have been developed to conduct in-place tests on snubbers, taking advantage of these developments could result in minimizing the damage to snubbers caused by removal and reinstal-lation plus time and cost savings to the plants.
From these shortcomings it was concluded that the snubber surveillance require-ments for the Technical Specificatidns should be revised.
The revised surveillance requirements correct these deficiencies in the following manner:
1.
Mechanical snubbers are now included in the surveillance program.
(This item is not applicable to the Cook Plant.)
2.
No arbitrary snubber capacity is used as a limit to the inservice test requirements.
3.
Seal material no longer requires NRC approval.
A monitoring program shall be implemented to assure that snubbers are functioning within their service life.
4.
Clearly defined inservice test requirements for snubbers shall be implemented.
5.
In-place inservice testing shall be permitted.
4
\\
By letter dated February 25, 1983, the licensee supplemented the snubber Technical Specification request to include a section 4.0.5 in the Unit 1
TSs and to modify both Unit 1 and 2 TSs to remove requirements which are no longer applicable.
The section 4.0.5 in Unit 1
on inservice inspection and testing is necessary to complete the requirements of the snubbers surveillance (both units reference requirements of section 4.0.5).
The Unit 1
TSs section 4.0.4 was modified to delete a reference to the first inspection interval for certain fire protection surveillance requirements; this surveillance has begun for all the referenced sections and this exception to 4.0.4 is no longer valid.
The Unit 2 TSs section 4.0.5.a.l is removed since it dealt with inservice inspection and testing before plant operation; this provision is no longer applicable.
These items are removed for, clarification and their removal will have no effect on safe plant operation.
ENYIRONtlENTAL CONSIDERATION Me have determined that the amendments do not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendments involve an action which is insig-nificant from the standpoint of environmental impact and, pursuant to 10 CFR 50.5(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of these amendments.
CONCLUSION Me have concluded, based on the cons'iderations discussed above, that:
(1) because the amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated, do not create the possibility of an accident of a type different from any evaluated previously, and do not involve a significant reduction in a margin of safety, the amendments do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Dated:
April 13, 1983 Principal Reviewers:
H.
Shaw D. Migginton
ci'( i'