ML17321A518
| ML17321A518 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/02/1985 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:0761D, AEP:NRC:761D, NUDOCS 8504090014 | |
| Download: ML17321A518 (9) | |
Text
REGULATOR NFORMATION DISTRIBUTION S l'EM (RIDS)
ACCESSION NBR:8504090014 DOC ~ DATE'e 85/04/02 NOTARIZED+
NO.
FACIL:50-315 Donald C,
Cook Nuclear Power Planti Unit 1< Indiana 8
50-316 Donald C.
Cook Nuclear Power Planti Unit 2i Indiana 8
AUTH BYNAME AUTHOR AFFILIATION ALEXICH < M,P.
Indiana L Michi gan Electric Co, RECIP ~ NAME RECIPIENT AFFILIATION DENTONgH ~ RE Office of Nuclear Reactor Regulationg Director S UBJECT:
Forwards addi info re inadequate core-cooling instrumentation<consisting of milestones schedule for reactor vessel level instrumentation sys,Encl 2 to safety evaluation forwarded w/SA Varga 831219 ltr addressed, DISTRIBUTION CODE:
A002D COPIES RECEIVED:LTR ENCL g
SIZE:
TITLE:
OR Submittal:Inadequate Core Cooling (Item II,F.2)
GL 82-28 NOTES:
OL e 10/25/74 OL: 12/23/72 DOCKET 05000315 05000316 V
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1 INTERNAL: ACRS 17 NRR SHEAi J 01 NRR/DHFS/PSRB16 NRR/DL/ORBS NRR/DSI/CPB 10 NRR/DSI/RSB 13 RGN3 07 10 10 1
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INDIANA8 MICHIGAN ELECTRIC COMPANY P.O. BOX 1663I COLUMBUS, OHIO 43216
'I Donald C. Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74
.INADEQUATE CORE COOLING INSTRUMENTATION April 2, 1985 AEP: NRC: 0761D Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Denton:
In our letter AEP:NRC:0761C dated August 20, 1984, Indiana 5 Miohigan Electric Company (IMECo) committed to provide additional information on the Donald C. Cook Nuclear Plant Inadequate Core Cooling Instrumentation (ICCI) system.
This information consists of a schedule of milestones for implementation of the Reactor Vessel Level Instrumentation System (RVLIS), and addresses Enclosure 2 to the Safety Evaluation forwarded with Mr. S. A. Varga's December 19, 1983, letter.
The requested information is provided in the Attachment to this letter.
This document has been prepar ed following Corporate procedures which incorporate a reasonable set of. controls to ensure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, M. P.
A exich Vice President N MPA/dam cc:
John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Br idgman 85040900i4 850402 PDR ADOCK OSQ003iS PDR
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2 This Attachment provides a schedule of milestones for implementation of the Donald C. Cook Nuclear Plant Reactor Vessel Level Instrumentation System (RVLIS).
The information herein responds to Enclosure 2 of the NRC Safety Evaluat1on attached to Mr. Steven A. Varga's letter dated December 19, 1983.
With regard to the dates associated with the Emergency Operat1ng Prooedures (EOPs), it is noted that the schedule was derived with the assumption that needed work efforts would be in line with the Procedures Generat1on Package (PGP) prev1ously submitted for NRC review. If the NRC requests modification of the PGP, the dates delineated herein will likely be delayed.
e to e Submit the final design description (by licensee)..
Complete the documentation requirements of NUREG-0737, Item II.F.2, includ1ng all plant specific information items identified 1n applioable NRC evaluation reports for generic approved systems.
g~el~ue References (1) and (2) provide 11sts of numerous documents, pertaining to the RVLIS design description, which have previously been transmitted to the NRC by the licensee or Westinghouse Electric Corporation (g). It must be
- noted, however, that Reference (2) indicated g would transmit the Equipment Qualification Data Package No. ESE-50 (RVLIS Umbrella Report) directly to the NRC.
By letter dated February 12, 1985 (Reference (3)), g stated that this document would not be issued because the RVLIS hardware was qualified by other reports.
Additionally, in Reference (4) we stated that we planned to modify RVLIS, sub)ect to final engineering and des1gn review.
This modif1cation was to have consisted of relocat1ng the existing wide range Reactor Coolant System (RCS) pressure transmitters from inside containment to outside containment, where they were to be oonnected to RVLIS through level transmitter access assemblies.
We have now decided to 1nstall additional transmitters outside containment, rather than relooate the existing wide range pressure transmitters to that locat1on.
This installation, together with the required calibration, is scheduled to take place during the upcoming Unit 1
and Unit 2 refueling outages which are expected to beg1n in April and November 1985, respectively.
AEP:NRC:0761D Attachment M
estone 2:
Approval of Emergency Operating Procedure (EOP) technical guidelines (by NRC).
The EOP technical guideline wh1ch incorporates the selected system must be based on the intended uses of that system as described in approved generic EOP technical guidelines.
grege The D. C.
Cook Nuclear Plant EOP Procedures Generation Package.
(PGP),
which included the plant specific technical guidelines used in the development of the
- EOPs, was transmitted to the NRC via Attachment 2 to Reference (5).
The schedule for completion of th1s milestone is contingent upon NRC staff approval of the PGP.
M e t e
~
Inventory tracking systems installation complete (by licensee).
~Sc ed e
RVLIS installation is complete, with the exception of the aforementioned addition of w1de range RCS pressure transmitters outside containment (see schedule for Milestone f1 above).
This installation, together with the required calibration, is scheduled to take place during the upcoming Unit 1
and Unit 2 refueling outages which are expected to begin 1n April and November 1985, respectively.
M e
o e 4 ~
Inventory tracking systems functional test1ng and calibration complete (by licensee).
M~e'g e RVLIS is functional and calibrat1on is complete, with the exception of the aforement1oned addition of wide range RCS pressure transmitters outside containment (see schedule for Milestone d1 above).
This installation, together with the required testing and calibration, is scheduled to take place during the upcom1ng Unit 1 and Unit 2 refueling outages which are expected to begin in Apr11 and November 1985, respectively.
M e
e Prepare rev1s1ons to plant operating and emergency procedures, based on approved EOP guidelines (by licensee).
AEP:ARC:0761D Attachment
~edge As shown in Attachment 3 to Reference (6), the EOP revision process began in November 1983 and ended about October 1984.
The implementation of the final plant specific revision of the EOPs which include incorporation of comments from various reviews, is currently scheduled for December 1985.
M es e
6 Implementation letter report to NRC (by licensee).
Implementation letter report content is suggested by Enclosure 2 to the Safety Evaluation attached to Mr. S.
A. Varga's December 19, 1983, letter.
Co e
eet o
e e
e It is our intent to address the content of the implementation letter report in the following manner, unless we hear differently from the NRC staff:
NRC Item (1):
Notification that the system installation, functional testing, and calibration is complete and the test results are available for inspection.
Anticipated Response:
Most of this information was provided in Reference (4).
The report will confirm the addition of the wide range pressure transmitter installation on RVLIS.
NRC Item (2):
Summary of licensee conclusions based on test results, e.g.:
(a)
The system performs in accordance with design expectations and within design error tolerances; or (b)
Description of deviations from design performance specifications and basis for concluding that the deviations are acceptable.
Anticipated Response:
NRC Item (3):
Most of this information was provided in References (4) and (7).
The report will update the effect of the new wide range pressure transmitter installation on RVLIS performanoe.
Description of any deviations of the as-built system from previous design descriptions with any appropriate explanation.
Anticipated Response:
Most of the as-built detail has been described in References (1), (2), and (4).
The report will update any further as-built deviations after addition of the wide range pressure transmitters.
AEP:NRC:0761D Atachment NRC Item (4):
NRC Item (5):
Request for modification of Technical Specifications to include all ICC instrumentation for accident monitoring.
Request for NRC approval of the plant specific installation.
NRC Item (6):
Conf1rm that the EOPs used for operator train1ng will conform to the techn1cal content of NRC approved EOP guidelines (generic or plant specific).
Anticipated
Response
The NRC has previously approved the generic EOPs for implementation.
Once we receive NRC approval of our PGP, this item will be considered complete.
~Schedu e
S1nce the content of this report will necessary.y depend upon the addition of the wide range RCS pressure transmitters outside containment (see schedule for Milestone
$ 1 above), it is anticipated that the implementation letter report will be transmitted approximately four (4) months following the end of the Unit 2 1985 refueling outage.
M e
e Perform procedure walk-through to complete task analysis portion of RVLIS design (by licensee).
Sc~ei~ue As noted in Attachment 2 to Reference (5),
a two-phase Verification/
Validation (V/V) program is ourrently being carried out.
This program is intended to determine if the actions specified in the EOPs can be performed by the operators to effeotively respond to emergency conditions. It 1s currently anticipated that the V/V program will be completed December 1985.
M e
e 8 ~
Turn on system for operator training and familiarization (by licensee).
~Sc d~e It is currently anticipated that the RVLIS will be available for operator training and familiarization following installation, testing, and calibrat1on of the wide range RCS pressure transmitters 1n each Unit.
Mi e e
Approval of plant specific installation (by NRC).
AEP: NRt',: 0761D Attachment Schedule The schedule for completion of this milestone is contingent upon the NRC staff.
Mi e e
10'mplement modified operating and emergency procedures (by licensee).
~Sc edge The schedule for Milestone 810 must necessarily depend upon the NRC staff's approval of the plant specific installation (Milestone 09).
Furthermore, since the procedures are an integrated set and some in the set assume an operable RVLIS, implementation of the D. C.
Cook Unit 2 procedures requiring RVLIS may have to be delayed until the Unit 2 RVLIS is operable.
Therefore, although operators will be trained in the use of RVLIS, we will not be able to actually achieve this milestone for both Units until after the above activities are completed.
It is anticipated, however, that the modified procedures may be implemented within 90 days of NRC acceptance, following submittal of the implementation report for each Unit.
e e
e e
(2)
(3)
(4)
(5)
(6)
(7)
Letter No. AEP:NRC:0761, R. F. Hering (IMECo) to H. R. Denton (NRC),
dated March 11, 1983.
"Inadequate Core Cooling Instrumentation System (Generic Letter No. 82-28)
Request For Extension."
Letter No. AEP:NRC:0761A, R. F. Hering (IMECo) to D. G. Eisenhut (NRC),
dated June 22, 1983.
"Inadequate Core Cooling Instrumentation (Generic Letter No. 82-28)."
Letter No. AEP-85-516, C.
C. Swist (g) to S. L. Mar (AEPSC), dated February 12, 1985.
"RVLIS Documentation."
Letter No. AEP:NRC:0761C, M. P. Alexich (IMECo) to H.
R. Denton (NRC),
dated August 20, 1984.
"Inadequate Core Cooling Instrumentation System Status Report."
Letter No. AEP:NRC:0773I, M. P. Alexich (IMECo) to H.
R. Denton (NRC),
dated September 28, 1984.
"June 12, 1984, Confirmatory Order Status Report on Detailed Control Room Design Review (DCRDR) and Upgraded Emergency Operating Procedures (EOPs)."
Letter No. AEP:NRC:0773H, M. P. Alexich (IMECo) to H.
R. Denton (NRC),
dated August 6, 1984.
"May 8,
- 1984, Request For Additional Information on Detailed Control Room Design Review (DCRDR)."
Letter No. AEP:NRC:0761B, M. P. Alexich (IMECo) to H. R. Denton (NRC),
dated February 3,
1984.
"Inadequate Core Cooling Instrumentation; Preliminary Response to Request For Additional Information."