ML17325A523
| ML17325A523 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/09/1987 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| AEP:NRC:0969L, AEP:NRC:969L, NUDOCS 8712160086 | |
| Download: ML17325A523 (7) | |
Text
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ACCESSION NBR:
FACIL: 50-315 50-316 AUTH. NAME ALEXICHIM. P.
RECIP. NAME MURLEYa T. E.
REGULAT INFORMATION DISTRIBUTION STEM (RIDS) 871216008b DOC. DATE: 87/12/09 NOTARIZED:
NO DOCKET 0 Dona' C.
Coo k Nuc lear Power Plant'nit 1 i Indiana 8c 0500031 5 Donald C.
Cook Nuclear Pacer Planti Unit 2i Indiana 8c 0500031b AUTHOR AFFILIATION Indiana Michigan Poeer Co.
(formerly Indiana 5 Michigan Ele RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to 871207 request for addi intro re request for code relic% extension re inservice testing. Revised analysis uJhich alloujs operation uj/RHR or safety inJection crosstie valves closed currently being pursued.
DISTRIBUTION CODE:
A047D COPIES RECEIVED:LTR l
ENCL Q SIZE:
TITLE:
OR Submittal:
Inservice Inspection/Testing NOTES:
RECIPIENT ID CODE/NAME PD3-3 LA MIGGINQTON4 D lNTERNAL: AEOD/DOA ARM/DAF/LFMB NRR/DEST/MTB OQC/HDS1 RES/DE/EIB EXTERNAL:
LPDR NSIC COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD3-3 PD AEOD/DSP /TP*B NRR/DEST/MEB NR ILRB EQ 01 NRC PDR COPIES LTTR ENCL 5
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 19 ENCL
P II sK
Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 8
AEP:NRC:0969L Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 INSERVICE TEST (IST)
- ADDITIONAL INFORMATION FOR CODE RELIEF EXTENSION U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Attn:
T.
E. Murley December 9,
1987
Dear Dr. Murley:
This letter responds to,your,,staff,',s,December;,7;,."1987request
.for additional information on oui request for code relief extension contained in our letter AEP:NRC:0969I, dated November 20, 1987.
In AEP:NRC:0969I, we requested an extension of relief for four valves in the Residual Heat Removal (RHR) System that our Inservice Testing (IST) Program requires us to stroke quarterly.
Temporary relief had previously been granted by the NRC for the four valves in a letter from B. J. Youngblood to John E. Dolan, dated December 19, 1986.
In AEP:NRC:0969I, we proposed to continue testing the valves during refueling outages or during intervening outages of sufficient duration when the plant is in a condition which would accommodate the testing.
(Testing frequency would not exceed once per 92 days in the event of frequent
- outages, however.)
In a telephone conversation on December 7,
1987, your staff requested additional information on why valves IMO-340 and 350 could not be tested during power operation.
Information Re uested
~,
C N
Valve 'IMO-340 is located *in the discharge, from the East.RHR pump (downstream of the heat exchanger) to the suction of the centrifugal charging pumps.
IMO-350 is located in the discharge 87i 2i6008E', 87i209.'..:
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Dr. T.
E. Murley AEP:NRC:0969L from the West RHR pump (downstream of the heat exchanger) to the suction of the safety injection (SI) pumps.
Both of these valves are normally closed during power operation, and would be opened during the recirculation phase of a LOCA to allow the RHR pumps to provide water from the containment recirculation sump to the charging pump (IMO-340) and SI pump (IMO-350) suctions.
'The valves are each interlocked with valves IMO-262 and 263.
IMO-262 and 263 are located in series in the safety injection pump mini-flow (recirculation) line to the refueling water storage tank.
These normally open valves protect the SI pumps from dead-heading in the event the pumps start while the reactor coolant system pressure is above the pump shutoff pressure, and are required by Technical Specification (T/S) 4.5.2.a to be open, with control power locked out, while the unit is in Modes 1, 2, or 3.
In order to open IMO-340 or 350, it is necessary to first close either IMO-262 or 263.
Since IMO-262 and 263 are in series,
'losing these valves renders both SI pumps inoperable, and thus places the unit in T/S 3.0.3, which allows one hour to restore the SI pumps to operable status or begin a unit shutdown.
The valve and equipment lineup necessary to perform testing of IMO-340 and 350 is complex because of the various interlocks associated with the valves.
In addition to both SI pumps being inoperable, one train of RHR would also be rendered inoperable by the required valve lineup.
The complicated lineup makes it unlikely that the testing can be completed within the one hour time limit of T/S 3.0.3.
For this reason, we do not believe valves IMO-340 and 350 can be tested without having to institute a unit shutdown.
As discussed in our letter AEP:NRC:0969I, we are currently pursuing revised analyses which will allow us to operate with the RHR or SI cross-tie valves closed.
The revised analyses may make it feasible to perform testing of IMO-340 and IMO-350 at power.
We will continue to investigate this possibility, and will advise you of our conclusions at the time the cross-tie analyses are submitted.
If our review determines that it still is not prudent to test IMO-340 and 350 at power, we will request a permanent change in our IST program to require testing of these valves during cold shutdowns, instead of quarterly.
We note that it may be possible to perform the testing of IMO-340 and 350 by jumpering the interlocks associated with IMO-262 and
- 263, thus avoiding having to close these valves.
- However, jumpering the valve interlocks would be considered maintenance per Article IWV-3200 of Section XI of the ASME Boiler and Pressure Vessel Code.
This article would then require testing of the interlock function (including closing IMO-262 and 263) once the
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I I
Dr. T. E. Murley AEP:NRC:0969L jumpers were removed before the equipment could be considered operable.
This pose-maintenance testing would require entry into T/S 3.0.3, and thus places the unit in the same position as does testing without jumpering out the interlocks.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M.
. Ale 'ch Vice Presa.dent cm cc:
John E
~ Dolan W.
G. Smith, Jr.
- Bridgman R.
C. Callen G.
Bruchmann G. Charnoff NRC Resident Inspector
- Bridgman A.
BE Davis
- Region III