ML17324A864
| ML17324A864 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/23/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17324A860 | List: |
| References | |
| NUDOCS 8605020237 | |
| Download: ML17324A864 (6) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE. OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
9~
TO FACILITY OPERATING LICENSE NO.
DPR-58 AND AMENDMENT NO.
81 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 INTRODUCTION By letters dated October 19, 1984, and May 31, 1985, the licensee requested revisions to the Technical Specifications for the D.
C.
Cook Nuclear Plant, Units 1 and 2.
Additional justification for the changes was provided by letters dated October 18, 1985 and February 7,
1986.
A description of each proposed change is provided below, along with our assessment of the change.
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! Ch 3/4.6 Containment Systems The licensee has proposed to add a footnote to Surveillance Requirement 4.6.
- 1. l.a. 1 to specify that valves, blind flanges, and deactivated automatic valves which are located inside the containment and are locked, sealed, or otherwise secured in the closed position, shall be verified closed during each cold shutdown, rather than once per 31 days as currently required.
The licensee claims that access to these valves inside containment is undesirable on a monthly basis when the unit is operating due to ALARA considerations.
The footnote the licensee proposes to add was not included in early drafts of the Standard Technical Specifications (STSs) on which Unit 1 Technical Speci-fications (TSs) were based, but has been incorporated in more recent revisions of the STSs.
This change would make this Unit 1 TS consistent with the Unit 2 TS as well as the STS (NUREG-0452, Revision 4.)
The staff has considered the proposed change and finds it to be acceptable.
We note that while the change can result in some increase in the probability or consequences of a previously analyzed accident due to the decreased sur-veillance frequency for the affected valves, the reduction in safety margin is within acceptable limits.
This is evidenced by consistency with the STS.
On this basis, we find the change to be acceptable.
3/4.6.3 Containment Isolation Valves The licensee has proposed to delete the present requirements to (1) demon-strate the operability of each power operated or automatic valve testable 8605020237 860423 PDR
- DOCK 050003i5 P
'DR during plant operation at least once per 92 days (Surveillance Requirement 4.6.3.1.1.a) and (2) demonstrate the operability of each power operated or automatic valve, and certain manual valves during cold shutdown or refueling at least once per 18 months (Surveillance Requirements 4.6.3. 1.2.d and e, respectively).
The licensee would, instead, test the affected valves pursuant to TS 4.0.5, i.e., in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
The testing requirements for each valve under Specification 4.0.5 have been incorporated in a new section 4.6.3. 1.3.
The proposed change would make the Unit 1 TS consistent with the Unit 2 TS, as well as the STS.
The staff has asseSsed the impact of this change on the method and frequency of valve testing.
We find that the full stroke valve test performed under ASME Section XI (the IST program) is equivalent to that required by the current TS with the following exceptions:
(1) valves ICM-250 and 251 (Boron injection inlet) are tested once every 92 days under the current TS but are tested only during cold shutdown under the IST program, and (2) valves ICM-111 (RHR to RC cold legs) and NPX-151-VI (dead weight tester) are tested once every 92 days under the current TS but-are not tested at all under the IST program.
The licensee has justified the less frequent test interval for the boron injection inlet valves on the basis that these valves cannot be cycled during normal plant operation without introducing boron into a non-heat traced line.
(The boron could crystalize and plug the line.)
This justification has been accepted by the staff in its review of the IST program for D.
C.
Cook Unit 1.
Omission of valve ICM-ill from the IST program was also considered acceptable by the staff on the basis that the valve is closed during plant operation and is only used for normal shutdown cooling (use of a parallel flow path is assumed in plant accident analyses).
We consider this to be adequate justifi-cation for deleting the current TS requirement to test these valves once every 92 days.
With regard to valve NPX-151-VI, this valve, is an instrument valve which performs a containment isolation function.
The valve is normally closed and is required to remain closed to perform its safety function.
The licensee has stated that NPX-151-VI is tested per Appendix J, and that the valve has been included in the second 10 year interval IST program.
We consider this to constitute acceptable testing requirements for the valve.
In summary, the staff considers the reduction in safety margin due to the de-creased testing requirements for the aforementioned valves to be within acceptable limits.
On this basis, we find the proposed change to be acceptable.
The licensee has also proposed to delete the column entitled "Testable during Plant Operation" from the table of containment isolation valves (Table 3.6-1)
'n the basis that this information is now given in the IST program for D.
C.
- Cook, and is no longer needed in the TS.
The proposed change would make the format of the Unit 1 TS consistent with the Unit 2 TS as well as the STS.
The purpose of indicating which valves are testable during operation is to identify which valves are to be tested under Surveillance Requirement 4.6.3. 1. 1.a.
As discussed
- above, the licensee has
- proposed, and staff considers acceptable, the deletion of this surveillance requirement.
We therefore find the deletion of the subject column to be acceptable.
Unit 2 Chan es 3/4.6.3 Containment Isolation Valves The licensee has proposed to modify Table 3.6-1 by adding asterisks for the containment isolation valves in the upper containment grab sample line (valves SM-8 and SM-10), to denote that these valves may be opened on an intermittent basis under administrative controls.
As the TS is currently written, the open-ing of these valves requires entry into an action statement and associated administrative tasks.
The licensee has stated that rather than enter the action statement, plant practice has been to send personnel into upper containment when it is necessary to obtain. grab samples, even if the unit is at power.
The proposed change would allow upper containment samples to be taken without having personnel access upper containment, thereby enhancing the ALARA program.
The proposed change would also make the Unit I and Unit 2 TS consistent.
The staff has considered the proposed change and finds it to be acceptable on
'he basis that the increase in risk posed by intermittent use of the valves is small compared to the reduction in occupational exposure which 'could be achieved by reducing personnel entries to obtain air samples.
The licensee has also proposed to delete from Table 3.6-1 14 valves inadver-tently left in the TS in Amendment No. 42, and to sequentially renumber certain other valves.
The valves to be deleted are NSW-415-1, 2, 3, 4; NSW-419-1, 2, 3, 4; NSW-224-1', 2, 3, 4 and NSW-417-3, 4.
These valves are already identified elsewhere in Table 3.6-1 by revised valve numbers.
The staff has reviewed the proposed change and concurs in the licensee's assessment that the change is administrative in nature.
On this basis, we find it to be acceptable.
Finally, the licensee has proposed to delete from certain pages of Table 3.6-1 a footnote stating "This Technical Specification will not be effective until after the 1982 refueling outage."
This footnote reflected a planned installation of replacement valves during th'e 1982 refueling outage.
The valve replacement was completed at that time, eliminating the need for the footnote.
On this
- basis, we consider deletion of the footnote to be acceptable.
ENVIRONMENTAL CONSIDERATION These amendments involve a change in the installation or use of the facilities'omponents located within the restricted areas as defined in 10 CFR 20 and a
change in surveillance requirements.
The staff has determined that these amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration, and there has been no public comment on such finding.
Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR Sec 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.
0
CONCLUSION The Comnission made a proposed determination that the amendments involve no significant hazards consideration which was published in the Federal Re ister (49 FR 50805) on December 31, 1984, and consulted with the st~ate o
sc agan.
No public comments were received, and the state of Michigan did not have any comments.
We have concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, and (2) such activities will be conducted in compliance with the Comaission s regulations, and the issuance of these amendments 'will.not be inimical to the common defense and security or to the health and safety of the public.
Princi al Contributors:
- p. Wigginton, PWR84 R. Palla Pated APril 23, 1986
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