ML17328A051
| ML17328A051 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/19/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17328A050 | List: |
| References | |
| NUDOCS 8906010152 | |
| Download: ML17328A051 (10) | |
Text
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+~*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATIOI'I BY THE OFFICE OF NUCLEAR REACTOR REGULPTICN RELATED TO AMENDMENT NO. 124TO FACILITY OPEPATING LICENSE NO.
DPR-58 AY'D AMENDMENT NO 1 1 1 TO FACILITY OPERATING LICENSF.
NO, PPR-74 INDIANA MICHIGAN POMER COMPANY DONALD C.
COOK NLCLEAR PLANT, UNITS NOS.
1 AND 2 DOCKETS NOS. 50-315 AND 50-316
1.0 INTRODUCTION
By letter dated May 28, 1987, the Indiana Michigan Power Company (the licensee) requested amendments to the Technical Specifications (TSs) appended to Facility Operating Licenses
Cook Nuclear Plant, Units Nos.
1 and 2.
The proposed amendments would modify the Engineering Safeguards Features (ESF) and Storage Pool Ventilation System TS (3/4.7.-6.1 and 3/4.9.12, respectively The proposed changes will update the licensee's testing standards and clarify several aspects of system operation.
- 2. 0 EVALUATION 2.1 Adoption of the 1980 Version of ANSI N510 The proposed change consists of replacing references to the 1975 version of the ANSI N510 standard "Testing of Nuclear Air-Cleaning Systems," with references to the 1980 version.
The licensee stated that literal compliance with all requirements of ANSI N510 testing standards cannot physically be achieved because the Engineered Safety Features (ESF) and Storage Pool Ventilation Systems are not of ANSI N509 design.
The 1980 version of ANSI N510 differs from the 1975 version in that (among other things) the 1980 version states specifically that "It is the intent of this standard that it be rigorously applied only to systems designed and built to ANSI N509; however, sections of.this standard may be used for technical guidance for testing of non-N509 systems."
Also NUREG-0800, "Standard Review Plan," Section 6.5.1, "ESF Atmosphere Cleanup System,"
acceptance criteria include Acceptability, with respect to in-place testing should include meeting the requirements of ANSI N510-1980.
For laboratory testing of activated carbon adsorbent, conformance with ANSI N509-1980 wi'll be used as an acceptability criterion."
This change would allow the use of a less stringent acceptability criterion for the air-aerosol mixing uniformity test described in Section 9 of ANSI N520-1980
(+ 20K, compared to +10% for ANSI N510-1975).
This test is 0goiOi52 8905i9 PDR ADOCK 050003i5 PDC
prescribed only upon completion of initial system installation, modification, or major repair, and is not required each time an in-place leak test of filters (Section
- 10) or adsorbers (Section
- 12) is made.
The purpose of the uniformity test is to verify that the tracer injection and sampling locations provide proper mixing of the tracer in the air approaching the stage to be in-place leak tested.
Both ANSI N510-1975 and ANSI N510-1980 provide that, where the mixing uniformity test acceptance criterion is not met, the injection port should be relocated, means for additional mixing should be provided, or multiple sampling should be specified in the procedures for the in-place leak tests.
Otherwise, single point sampling upstream and downstream is prescribed.
A recommended multiple sampling technique is provided in Section 11 of both ANSI N510-1975 and ANSI N510-1980.
The licensee has conducted the air-aerosol mixing uniformity tests required by Section 9 of ANSI N510-1980 with the result that, for ESF and Storage Pool Ventilation Systems filter units, certain individual readings differ from the mean concentrations by more than the prescribed value of + 20'.
The licensee has determined that the addition of baffling or other attempts to enhance the uniformity of mixing would be fruitless; and no provisions were included in the design of these systems to allow for multiple sampling.
Therefore, the licensee has developed, based on the mixing uniformity test results, correction factors which are proposed for use in the in-place leak tests to account for the non-uniformity of mixing displayed by these systems.
The licensee's comparison of the 1975 and 1980 versions of ANSI N510 has deter-mined that the above differences are the only ones of significance, except for requirements related to the laboratory testing of activated carbon adsorbent.
Also, minor changes related to penetrometer sensitivity, adsorber residence time calculations and background dust testing occur in the 1980 version but were determined by the licensee to be either more restrictive or to have a minimal impact on safety.
Regarding laboratory testing of adsorbent, ANSI N510-1980 specifies ASTM D 3803 as the testing standard and that testing conditions shall be in accordance with plant Technical Specifications.
ASTM D 3803 provides methods for methyl iodide penetration tests at 30'C and 95K relative humidity, 80 C and 95K relative humi-dity, and 130~C and 95K relative humidity.
Currently, the licensee test is in accordance with the RDT M 16-1T-1973 standard referenced in ANSI N510-1975, which specifies the test conditions of 130'C and 95K relative humidity included in the present plant Technical Specifications.
The licensee has been evaluating, the appropriateness of the candidate test temperatures by conducting parallel tests at 30'C and 130'C whenever practicable.
These comparative tests were to continue through July 8, 1988 at which time the need for adapting different test conditi,ons would be evaluated and, following this, revision to the Technical Specifications would be proposed if appropriate.
The licensee stated that the proposed changes discussed above do not increase the consequences of a previously analyzed accident.
While the 1980 version of ANSI-N510 involves certain relaxation's of requirements contained in the 1975
- version, the 1980 version is considered current by the industry and corresponds more closely to the D.
C.
Cook system design.
The correction factors determined to apply to the specific ANSI N510 test, which cannot literally be met, will assure that no significant decrease in safety margin should result.
The staff concurs with the above stated evaluation and finds that the proposed changes described meet the intent of Regulatory Guide (RG) 1.52, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature'tmosphere Cleanup Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants,"
and Standard Review Plan (SRP) Section 6.5. 1, "ESF Atmosphere Cleanup Systems,"
and are, therefore, acceptable.
- 2. 2 Motor - 0 crated Roll-u Doors The proposed change consists of adding a footnote applicable to the Action Statement of the Technical Specification governing the Storage Pool Ventilation System and adding a further explanation to the Bases for this Technical Specifi-cation.
The footnote would state that the crane bay roll-up door and the drumming room roll-up door may be opened under administrative control during movement of fuel within the storage pool or during crane operation with loads over the storage pool.
The Bases would explain that administrative control might be, for example, to station a person at the door in question to control its opening and closing; and that, if the doors became blocked or stuck open while under administrative control, movement of fuel within the storage pool or crane operation with loads over the pool would be expeditiously suspended.
In addition, the person stationed at the crane bay door would be in communication with personnel in the spent fuel pool area so that he would be readily informed of an emergency and, if needed, actuate the door closure mechanism (closes within 30 seconds after activation).
In order to maintain the minimum negative pressure required by Technical Speci-fications during movement of fuel within the storage pool or during crane operation with loads over the pool, the crane bay roll-up door and the drumming room roll-up door must be closed.
The licensee has stated that, per Technical Specifications, movement of fuel within the storage pool or crane operation with loads over the pool must be suspended whenever either of the doors is open; and this can cause significant operational burdens, particularly during outages, when the roll-up doors are needed quite often for ingress and egress of personnel and material.
The staff has performed an independent analysis of the consequences of a fuel-handling accident in the auxiliary building.
In this, no credit was given for removal of radioiodine by the charcoal adsorbers.
Based on this, the staff estimates that the 0-2 hours site boundary thyroid dose, without credit for containment and charcoal filtration, meets the intent of the SRP Section 15.7.4, "Radiological Consequences of Fuel Handling Accidents,"
acceptance criteria of "well within" the 10 CFR Part 100 exposure guideline values, i.e.,
75 rem for the thyroid and 6 rem for the whole body doses.
In reality, the quantity of unfiltered radioiodines released would be significantly below that assumed to be released without filtration or containment, since the roll-up doors would be expected to be closed quickly enough to significantly reduce the quantities of unfiltered radioiodines released to the environment.
Based on the above, the staff finds that the above described proposed changes meet the intent of SRP Sections
- 9. 4. 2, "Spent Fuel Pool Area Ventilation System,"
and 15.7.4 and, therefore, are acceptable.
2.3 S ent Fuel Pool Ventilation Confi uration The licensee stated that the proposed changes are corsidered adm-'nistrative in nature and are intended to clarify the TS requirements.
TS Section 4.9. 12.d does not adequately reflect the D. C.
Cook system design.
The current wording requires that, on a hioh radiation signal, the system automatically starts (unless already cperating) and directs
'.zs exhaust low through she HEPA filters and charcoal adsorber banks.
The revised wording would reauire that, on a high radiation signal, the system automatically directs its exhaust flow through the charcoal adsorber banks and automatically shuts down the storage pool ventilation system supply fans.
The staff concurs that the proposed change is administrative in nature
- and, therefore, finds it to be acceptable.
2.4 Filter Unit Air Flow Distribution Test The licensee proposes to delete the air flow distribution testing requirement from TS Sections 4.7.6.1 and 4.9.12 because air distribution is a function of the as-built configuration of the system and not a parameter that needs to be regularly reverified.
This is based on Section 8.3.2 of ANSI N510-1980, which states that the air distribution test should be performed only as an acceptance test following original installation and after major modification or repair of the air cleaning system.
- Further, the Standard -Technical Specifications (STS) provided in NUREG-0452, Revision 4 do not require this testing.
The staff concurs with the above evaluation and finds that this change is consistent with the guidance of ANSI N510-1980, R.G. 1.52, SRP Section 6.5.1, and the STS and, therefor e, is acceptable.
2.5 Filter B ass Testin Re uirements and ESF Ventilation Unit 0 erations The licensee proposes to delete the specific testing requirement that total filter bypass of the ESF Ventilation System to the facility vent, including leakage through diverting valves, is not greater than 15 when tested by admittimg DOP at the system intake.
The licensee stated that, because of the design of the D. C. Cook system, this testing requirement is redundant to the other requirements for testing the bypass flow around the HEPA filters and the bypass flow around the charcoal adsorbers and, therefore, is not needed.
Other changes are proposed for clarification which the licensee considers to be administrative in nature.
The staff concurs in the licensee's evaluation of the above changes and finds the proposed changes consistent with R.G. 1.52 and SRP Section 6.5. 1 and, therefore, acceptable.
2.6 Leak Testin of Charcoal and HEPA Filters The licensee proposes to add a leak testing requirement to TS Sections 4.7.6. l.b.4 and 4.9. 12.b.4 to achieve consistency with the leak testing required by TS Sections 4.7.6. l.c.2 and 4.9. 12.c.2.
The licensee proposes tn delete the requirements of TS Sections 4.7.6.1.c.2 and 4.9.12.c.2 for leak testing of the HEPA filters following reinstallation of the charcoal tray used to obtain a charcoal sample.
Such tests are not recommended by ANSI N510-1980 or by R.
G.
1.52.
Reinstallation of a charcoal tra., would rot he expected to '.rpact-the leakage characteristics of the HEPA units which are located in different sections of the filter housing.
Consequently, the requirement for leak testing the HEPA filters following reinstallation of a charcoal tray is not necessary.
The staff concurs in the licensee's evaluation and finds the proposed change consistent with ANSI N510-1980, R.
G. 1.52 and SRP Section 6.5. 1 and, therefore, acceptable.
2.7 Addition of Footnotes Related to Crane 0 eration The licensee stated that the proposed change would add a footnote to TS Section 3.9. 12, Action a, which would exempt the auxiliary building crane main load block from the restrictions on crane operation over the spent fuel storage pool with an inoperable storage pool exhaust ventilation, provided the main load block is de-energized.
A similar footnote was previously added to TS Section 3.9.7, "Crane Travel-Spent Fuel Storage Pool Building," which prohibited operation of the auxiliary building crane with the main load block over the storage pool.
(The main load block weighs more than the TS Section 3.9.7.2, 500 pound limit.)
As noted in the NRC's safety evaluation report for the previous amendment, "by de-energizing the main hook it becomes a passive, integral component of the auxiliary building crane and need not be considered a heavy load."
The proposed footnote is to ensure consistency between the above TS sections and to avoid problems associated with literal interpretation of TS Section 3.9.12, Action a.
This change is, therefore, considered administrative in nature and the staff finds the proposed change acceptable.
2.8 Editorial Chan es The proposed amendment also makes several editorial changes to the TS.
Table I is a list of each change.
The changes are to correct typographical errors in the TS or were necessary in renumbering or retyping a
TS page The changes are administrative in nature and, therefore, do not reduce the margin of safety.
Consequently, the staff finds these proposed changes acceptable.
4 VgI 3.0 ENVIRONMENTAL CONS IDERATION 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 and a change to the surveillance requirements.
The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluer ts that may be released offsite ano 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 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.
4.0 CONCLUSION
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 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.
Date:
Nay I9
],981 Princi pal Contributor:
C. Nichols
C-C~
TABLE 1 EDITORIAL CHANGES Unit TS Descri tion 4.7.6.1.b "or" added after "18" months" 4.7.6.l.b. 1 word "deleted" replaces paragraph 4.7.6.1.c.l 4.7.6.1.c.2 4.7.6.1.d.1 4.7.6.1.d.2 4.7.6.l.d.3 4.7.6.1.e "of" added after "efficiency" "a" deleted; "analysis" changed to "analyses" extra "c" removed from "across" word "deleted" replaces paragraph additional "-" added after "Containment Pressure" "a" added after "replacement of"; "band" changed to "bank" 3/4.7.6 3.9.12 The entire TS was retyped; thus, the location of sections on the various pages has changed phrase added to indicate that system is shared with D. C.
Cook Unit 2 4.9.12.b.1 word "deleted" replaces paragraph 4.9.12.b.4.b "the" added before "thickness" 4.9.12.b.5 "cfm" added after "30,000" 4.9.12.c.2 4.9.12.d 4.9.12.d.1 4.9.12.d.2 3/4.9.12 "a" deleted; "analysis" changed to "analyses" Semicolon changed to colon after "18 months by" "the" added before "pressure drop"; "Guage" changed to "Gauge" Word "deleted" replaces paragraph The entire TS was retyped; thus, the location of sections on the various pages has changed Bases 3/4.7.5 "t"'dded to "consisten";
"General Design Criteria 10" changed to General Design Criterion 19" Bases 3/4.7.6 "s" added to "room"; "was" changed to "were" Bases 3/4.7.7 "is" changed to "are" Bases'3/4.9.13 Text moved to new page B 3/4 9-4 and 3/4.9.14
TABLE 1 (CONTINUED)
Unit TS Descri tion Bases 3/4.9.13 "ensures" changed to "ensure" Bases 3/4.9. 14 "provides" changed to "provide" 4.7.6. 1.b
'omma added after "system" 4.7.6. 1.b. 1 word "deleted" replaces paragraph 4.7.6. l.c. 1 "of" added after "efficiency" 4.7.6. l.c.2 "a" deleted; "analysis" changed to "analyses" 4.7.6.1.d.2 word "deleted" replaces paragraph 4.7.6.1.e "a" added after "replacement of" 3/4.7.6.1 3.9.12 The entire TS was retyped; thus, the location of sections on the various pages has changed; page 3/4 7-19a intentionally left blank because of reduced space required for retyped TSs.
"*" changed to "*"" in heading and footnote 4.9.12 "air cleanup systems" changed to "ventilation system" 4.9.12.b "gamma" added after "with the system" 2
4.9.12.b.l word "deleted" replaces paragraph 4.9.12.b.4.b "the" added before "thickness" 4.9.12.b.5 "cfm" added after "30,000" 4.9.12.c.2 "a" deleted:
"analysis" changed to "analyses" 4.9. 12.d Semicolon changed to colon after "18 months by"
$.9.12.d.1 4.9. 12.d. 2 3/4.9.12 "the" added before "pressure drop"; "Guage" changed to "Gauge" word "deleted" replaces paragraph The'ntire TS was retyped; thus, the location of sections on the various pages has changed Bases 3/4.7.6 "s" added to "room"; "was" changed to "were" Bases 3/4.7.7 Comma added in paragraph 1 of the Bases 3/4.7.7;
"-" added to "18 month" in paragraph 5.
(;,,+ 'ip
~'ABLE1 (CONTINUED)
Unit TS Descri tion Bases 3/4.7.7 Text from page 8 3/4 7-5 moved to page B 3/4 7-6 Bases 3/4.7.8 "is" changed to "are"; "This limitation will" changed to "These limitations" Bases 3/a.7.9 "occuring" changed to "occurring" in paragraph 1
Bases 3/4.9.10 "assemble" changed to "assembly";
paragraphs merged; and 3/4.9.11 "intervals" changed to "internals" Bases 3/4.9.13 text moved to new page B 3/4 9-4 arid 3/4.9.14 Bases 3/4.9.13 "ensures" changed to "ensure" Bases 3/4.9.14 "provides" changed to "provide"
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