ML17325A544
| ML17325A544 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/10/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17325A543 | List: |
| References | |
| NUDOCS 8712210185 | |
| Download: ML17325A544 (5) | |
Text
~ ~g REay
+
O~
Cy UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELA AND AMENDMENT NO.
95 FACILITY OPE ING LICENSE N
PR-
-58 INDIANA AND MICHIGAN POWER COMPANY DONALD I AND 2
1.0 BACKGROUND
NUREG-0737, "Clarification of THI Action Plan Requirements,"
sets forth all required post TNI'-related modifications to operating plants including schedules, applicability, method of implementation review, and licensee submittal dates.
Section II;F.1.5 of NUREG-0737 (with additional guidance from Regulatory Guide 1.97) requires that a continuous indication of containment water level be provided in the control room for all plants, both PWR's and BWR's.
For PWR's, a narrow range instrument must be provided to measure from the bottom to the top of the containment sump.
Wide range instruments must be available to measure from the bottom of the containment to the elevation equivalent to 600,000 gallons capacity.
NUREG-0737 also requires that technical specifications (TS) be developed which provide assurance that facility operation is maintained within limits determined acceptable following the implementation of specific TNI action items, including containment water level monitoring.
Generic Letter 83-37, dated November 1, 1983, set forth guidance on the scope and content of TS covering NUREG-0737 items.
Among the guidance provided was a proposed specification which set forth minimum channel requirements, limiting conditions for operation (LCO) and surveillance requirements for containment water level instrumentation.
The generic letter called for one channel of narrow range monitoring of contain-ment sump level, and two channels for wide range monitoring of containment water level.
The generic letter also set forth an LCO action statement, for narrow range monitors, which requires that an inoperable channel be restored to operable status within 30 days or the plant be brought to hot shutdown as required for other accident monitoring instrumentation.
The suggestion for wide range monitoring instrumentation placed no specific outage time constraint on inoperable channels.
The guidance suggested that the LCO action statement for wide range should be similar to that for other accident monitoring instru-mentation included in a plant's existing technical specifications.
gy128101<>
~>OOP$ 15
- --- 712'10 pDR ggQGK 0 PgR I
P
"f f
iK r,i<-~ ~.
On July 19, 1984, the licensee submitted proposed technical specifications covering changes made pursuant to NUREG-0737,Section II.F.1.5.
These changes deviated from the guidance contained in the generic letter by proposing that only one channel be required for wide range monitoring.
The proposed changes further neglected to impose requirements for periodic channel checks of either wide or narrow range instrument channels as part of surveillance requirements.
Subsequent to a January 13, 1986, meeting between the staff and the licensee, the licensee's proposals were modified and resubmitted by letter dated May 19, 1986.
Unlike the original proposal, the revised proposal requested TS changes to require (1) routine monthly channel checks for both containment sump (narrow range) and containment (wide range) water level instrumentation, and (2) the addition of two instrumentation channels to monitor containment water (wide range) level rather than the single channel as originally proposed by the licensee.
The revised proposal also requested that the existing 30-day action statement in the Units 1 and 2 TS for other accident monitoring instrumentation be applied to containment water level instrumentation (wide range).
These revisions brought the TS into accord with the guidance of the generic letter as far as recommended instrumentation and required surveillances are concerned.
However, with respect to limiting conditions for operation and associated action statements for containment sump level, the licensee's revised proposal continued to deviate from the guidance contained in the generic letter.
The generic letter calls for the LCO for sump level instrumentation to include the requirement that the inoperable channel be restored to operable status within 30 days or the plant be brought to hot shutdown condition as required for other accident monitoring instrumentation.
The plants'urrent TS require reactor shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following a 30-day period of inoperability of other accident monitoring instrumentation.
But for inoperability of the sump level instrumentation
- channel, the licensee proposed to deviate from this shutdown requirement by substituting a requirement to submit a special report to the Regional Administrator.
This report would outline available backup equipment, the cause of the inoperability, and the plans and schedule for restoring the system to operable status.
This report would be submitted pursuant to Technical Specification 6.9.2, Special
- Reports, which the licensee proposed to amend to reflect its applicability to sump level instrumentation.
The licensee felt justified in exempting containment sump level instrumentation from adhering to the 12-hour shutdown provision applied to other instrumentation channels because of the number of backup instrumentation systems available (humidity monitors, sump pump run time, containment atmosphere particulate radioactivity monitoring channels, containment atmosphere gaseous radioactivity monitoring channels, the containment water level instrumentation, and refueling water storage tank water level).
The licensee's May 19, 1986, letter also contained a proposed change to the Bases for Post-Accident Instrumentation which stated that (1) an acceptable instrument drift for containment water level channels is 25 percent of full
- scale, and (2) for sump level channels, a difference between readings on the two parallel channels of up to 25 percent of full scale is acceptable.
In a letter dated May 6, 1987, the staff provided a preliminary safety evalua-tion (SE) which addressed the proposed technical specification changes and requested the licensee to review the staff positions on the deviation for the sump level instrumentation LCO and on the unacceptability of a 25 percent drift in containment water level instrumentation.
In response to the staff's
- request, in a July 16, 1987, letter the licensee has now proposed revised changes to the plants'echnical specifications which are intended to supersede the previously proposed changes for containment sump level and containment water level in their entirety.
In the May 19, 1986 letter, the licensee also proposed an editorial change to remove a duplication on the operational leakage Technical Specifications.
'he exact same words are currently shown on two separate pages.
2.0 EVALUATION The licensee proposed to add containment sump level and containment water level instrumentation to the current post-accident monitoring instrumentation tables in the plants'echnical specifications with one channel and two channels required, respectively (with an LCO of 30 days followed by hot shutdown).
The licensee proposed a monthly channel check and a refueling outage channel calibration be added for the above instruments in the existing tables of post-accident monitoring instrumentation surveillance requirements in the plants'echnical specifications.
The staff finds these proposed changes acceptable on the basis that they follow the guidance contained in Generic Letter 83-37.
The licensee proposed to add a footnote:
"The requirements for these instruments will become effective after the level transmitters are modified or replaced and become operational.
The schedule for modification or replacement of the trans-mitters is described in the Bases." to the new entries (discussed above) for containment sump level and containment water level instrumentation.
The licensee proposed to add:
"The containment water level and containment sump level trans-mitters will be modified or replaced and OPERABLE by the end of the refueling outage scheduled to begin in February 1989." to Bases Section 3/4.3.3.8 in the Unit I technical specifications and to add:
"The containment water level and containment sump level transmitters will be modified or replaced and OPERABLE by the end of the outage currently scheduled to begin in May 1988." to Bases Section 3/4.3.3.6 in the Unit 2 technical specifications.
The staff finds these proposed changes acceptable on the basis that they reflect the schedular require-ments associated with Generic Letter 83-37 and Regulatory Guide 1.97.
The licensee's proposed changes to correct the duplicative requirements on the operational leakage Technical Specifications for Unit I are also acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes an inspection or surveillance requirement.
The staff has determined that the amendments involve no significant increase in the amounts, and no
4 significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupa-tional radiation exposure.
The Commission has previously published 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 eligibilitycriteria for categorical exclusion set forth in 10 CFR 551.22(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.
- 4. 0 CONCLUSION The staff has 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 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.
Principal Contributor: F. Burrows Dated:
December 10, 1987