ML17326A303

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Forwards Response to 790801 Request to Institute License Condition Requiring Implementation of Secondary Side Water Chemistry Monitoring & Control Program.Program Already in Effect & No Fee Required for Formalization
ML17326A303
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/25/1979
From: Dolan J
INDIANA MICHIGAN POWER CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
00262, 262, NUDOCS 7911020283
Download: ML17326A303 (5)


Text

RKGULAT INFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR!7911020283 DOC ~ DATE! 79/10/25 NOTARIZED!

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Cook Nuclear Power Pl anti Uni t ii Indiana 8

50 316 onald C ~

Cook Nuclear Power Plantr Unit 2< Indiana I AU..A 4UTHOR AFFILIATION DOLANpJ ~ E, Indiana L Michigan Power Co, RKC IP ~ NAME RECIPIENT AFF ILIATION DENTONgH ~ R, Office of Nuc'l ear Reactor Regulation SUB JKCT!

For war ds nesponse to 790801 r equest to insti tute l i cense condition requiring implementation of secondary side water chemistr y monitor ing 0, contr o'l pr ogram,Such progt am already in ef fect 4

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INDIANA IL MICHIGAN POV/ER COMPANY P. O. BOX 18 BO WL IN G G R E EN STAT ION NEW YORK, N. Y. 10004 October 25, 1979 AEP:NRC:00262 Donald C.

Cook Nuclear Plant Unit Nos.

1 and 2

Docket Nos.

50-315 and 50-316 License Nos.

DPR-58 and DPR-74 Mr.:.Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D; C.

20555

Dear Mr. Denton:

This letter serves to respond to Mr. A. Schwencer's letter dated August 1, 1979 wherein we were requested to institute a license condition requiring implementation of a secondary side water chemistry monitori ng and control program.

Upon implementation of such a license condition, present technical specifications on Secondary Side Chemistry, and the surveillance requirements associated with those technical specifications,

'would be'deleted.

A program for the monitoring of secondary side water chemistry has been in effect for some time at the Cook Plant.

Plant procedures and/or administrative controls are in effect for all areas of concern addressed in the enclosure, "Model License Condition," to Mr. Schwencer's letter.

We would like to point out that the concerns addressed in Mr. Schwencer's letter are similar to those expressed in our response to Mr. D. L.

Ziemann's letter of September 10, 1976, regarding the implementation of secondary side water chemIstry Technical Specifications.

Our response to Mr. Ziemann's letter, dated November 29, 1976, stated that implementation of Technical Specifications on secondary side chemistry would limit the flexibilityto stabilize, interpret, and correct any unusual secondary side chemistry condition.

The existing secondary side water chemistry monitoring and control program and the associated procedures and adminis-trative controls that are maintained at the Cook Plant, provide.

sufficient assurance that proper attention is being given to the control of secondary side chemistry in order to assure the long term integrity of the steam generator tubes.

These are available to your staff for inspection.

V911G20 +83

Mr. H. R. Denton, Director AEP:NRC:00262 Me understand that the proposed license condition would not be violated in the event that chemical analyses were to reveal non-compliance with the prescribed limits of a given parameter provided that the appropriate actions, as described in the applicable procedure(s),

were taken.

Upon implementation of the proposed license condition, the Technical Specifications listed below should be deleted.

Unit No.

1

. Technical Specifications 3.7.1.6, 4.7.1.6 and Table 3.7-3 on pages 3/4 7-11 through 3/4 7-13.

Unit No.

2 Technical Specifications 3.7.1.6, 4.7.1.6, and Table 3.7-3 on pages 3/4 7-10a through 3/4 7-10c.

The proposed license condition contained in the attachment to this

letter, and the technical specification revisions shown above have been reviewed by the Plant Nuclear Safety Review Committee (PNSRC) and the AEPSC Nuclear Safety and Design Review Committee (NSDRC).

As a result of their respective reviews, both the PNSRC and the NSDRC have concluded that institution of the license modifications described herein will have no adverse effect on the health and safety of the general public.

Modifications, when needed, to the plant procedures and/or adminis-trative controls for the secondary side water chemistry monitoring and control program will be made subsequent to review by the appropriate members of IMPCo. and/or AEPSC.

Additional guidance concerning the assessment of fees for proposed license amendments was transmitted to us in the attachments to Mr. M. 0.

Miller's letter of July 12, 1979.

Footnote (1) to 10 CFR 170.22 states.

that "license amendments or approvals resulting from Commission Orders issued pursuant to 10 CFR 2.204... are not subject to these (170.22)

fees, except as provided in footnote (1) to 170.21."

Part 170.21 is not applicable to this submittal.

Footnote (2) further states that "Class I, II or III amendments which result from a written Commission request for the application may be exempt from fees when the amendment is to simplify license or technical specifications, the amendment has only minor safety significance, and is issued for the convenience of the Coranission."

Mr. H.

R. Denton, Director AEP:NRC:00262 As stated previously.in this letter, a program for the monitoring and control of secondary side water chemistry has been in effect for some time at the Cook Plant.

Thus, the implementation of a License Condition will only serve to formalize with the NRC our existing internal requirements for secondary side water chemistry monitoring and control.

Such formalization does not involve any environmental, safety, or other issue for the Cook Plant.

For reasons cited above, IMPCo interprets 10 CFR 170 as requiring that no fee accompany this submittal.

Very truly yours, JED.ab John E. Dolan Vice President cc:

R.

G.

R.

R.

D.

C. Callen Charnoff S. Hunter W. Jurgensen V. Shaller - Bridgman

(ATTACHMENT TO AEP:NRC:00262)

DONALD C.

COOK NUCLEAR PLANT UNIT NOS.

1 AND 2 DOCKET NOS. 50-315 and 50-316 LICENSE NOS.

DPR-58 and DPR-74 PROPOSED LICENSE CONDITION ON SECONDARY SIDE WATER CHEMISTRY MONITORING Indiana 8 Michigan Power Company and Indiana 5 Michigan Electric Company (the licensees) shall implement a secondary side water chemistry program to inhibit steam generator tube degradation.

This program shall define the process sampling points and sampling schedules for the monitoring of critical secondary side parameters.

The procedures and/or administrative controls used to quantify parameters, control the recording and management of data, define corrective actions for off control point chemistry conditions, and identify the authority responsible for the interpretation of the data shall be made part of the program.