ML17328A239
| ML17328A239 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/21/1989 |
| From: | Giitter J Office of Nuclear Reactor Regulation |
| To: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| References | |
| GL-88-17, TAC-69736, TAC-69737, NUDOCS 9001030129 | |
| Download: ML17328A239 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 December 21, 1989 Docket Nos.
50-315 and 50-316 Hr. Hilton P. Alexich Indiana hIichigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
Dear llr. Alexich:
SUB JECT:
CONh1ENTS ON TklE INDIANA MICHIGAN POWER COMPANY RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO PROGRAHI'lED ENHANCEIIEIITS FOR LOSS OF DECAY HEAT REI'IOVAL FOR D.
C..COOK UNITS 1
AND 2 PLANTS (TAC NOS.
69736 AND 69737)
Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat removal (DHR) during nonpower operation.
In the GL, we requested (1) a description of your efforts to implement the eight recommended expeditious actions of the GL and (2) a description of the enhancements, specific plans ard a schedule for implementation of the six recommended program enhancements.
The NRC staff has reviewed your response to Generic Letter 88-17 on programmed enhanceIIIents in the letter of February 6, 1989 in which you committed to implement the programmed enhancements within the time frame stipulated in the GL.
We find that the response appears to meet the intent of the GL but lacks some of the details.
Your response to some items is brief and therefore does rot allow us to fully understand your actions taken in response to GL 88-17.
You may wish to consider several observations in order to assure yourselves that the actions are adequately addressed:
1.
You indicate that you will provide two independent electronic RCS level indications which will provide continuous wide and narrow range control room indications and alarm functions.
You have stated in the expeditious actions that the level instrumentation shares a
common tap with your "visual level instrument," which is a temporary level instrument.
If this "visual level instrument" is continued in use, extra care wi 11 be needed to detect blockage, such as a means of periodic draining or flushing.
This is suggested in Section 3.1.2.1 of GL 88-17, Enclosure 2, "Guidance for Heeting GL 88-17."
You have not indicated what the expected accuracy of the level systems is.
The inaccuracy of the level measurement should be small since an error of a few inches, when in the critical region of mid-loop operation, could cause the RHR pumps to be disabled from air ingested by vortexing.
2.
You have discussed some areas of concern that you revised procedures wi 11 address.
Also, you indicate that a plant procedure is being developed 900i030i29 89i22i PDR ADOCK 050003i5 P
PDC which delineates the administrative requirements associated with reduced inventory operation.
From your presentation it cannot be determined if all the several items listed in Section 3.2.2.1 of Enclosure 2 to GL 88-17 will be covered in your revised procedures.
3.
You have discussed your participation in the Westinghouse Owners Group (HOG) and your analyses which provides plant specific information concerning the thermal-hydraulic behavior for various plant conditions which is factored into your procedures.
You did not state if these analyses extended into the understanding of behavior of the level instrumentation as discussed in Section 3.4.1 of Enclosure 2 of GL 88-17.
4.
You have discussed a number of refinements in perturbation avoidance.
We cannot determine if your refinements include consideration of a number of refinements discussed in Section 3.6.2 of Section 2.0 of GL 88-17.
Among these are (I) informing control room personnel immediately before initiating an operation which could perturb the RCS system or a system which is necessary to maintain the RCS in a stable and controlled condition while a reduced RCS inventory condition exists, (2) awareness of difficulties with implementation of new instruments, and (3) sensitivity of maintenance personnel to the use of tubing or of openings to the RCS.
There is no need to respond to the above observations.
As you are aware, the expeditious action you previously described were an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation, and these are to be supplemented and in some cases replaced by programmed enhancements.
We intend to audit your response to the programned enhancement program.
The areas where we do not fully understand your responses as indicated above may be covered in the audit of programmed enhancements.
Sincerely, Joseph G. Giitter, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation
Mr. Milton Alexich Inaiana Michigan Power Company Donald C.
Cook Nuclear Plant CC:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen El lyn, Il1inois 60137 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Township Supervisor Lake Township Hall Post Office Box 818 Bridgman, Michigan 49106 Al Blind, Plant Manager Donald C.
Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S. Nuclear Regulatory Commission Resiaent Inspectors Office 7700 Red Arrow Highway Stevensville, Michigan 49127 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366 Bridgman, Michigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3500 N. Logan Street Post Office Box 30035 Lansing, Michigan 48909 Mr. S. Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43216
which delineates the administrative requirements associatedwith reduced inventory operation.
From your presentation it cannot be determined if all the several items listed in Section 3.2.2.1 of Enclosure 2 to GL 88-17 will be covered in your revised procedures.
3.
You have discussed your participation in the Westinghouse Owners Group (WOG) and your analyses which provides plant specific information concerning the thermal-hydraulic behavior for various plant conditions which is factored into your procedures.
You did not state if these analyses extended into the understanding of behavior of the level instrumentation as discussed in Section 3.4.1 of Enclosure 2 of GL 88-17.
4.
You have discussed a number of refinements in perturbation avoidance.
We cannot determine if your refinements include consideration of a number of refinements discussed in Section 3.6.2 of Section 2.0 of GL 88-17.
Among these are (1) informing control room personnel immediately before initiating an operation which could perturb the RCS system or a system which is necessary to maintain the RCS in a stable and controlled condition while a reduced RCS inventory condition exists, (2) awareness of difficulties with implementation of new instruments, and (3) sensitivity of maintenance personnel to the use of tubing or of openings to the RCS.
There is no need to respond to the above observations.
As you are aware, the expeditious action you previously described were an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation, and these are to be supplemented and in some cases replaced by programmed enhancements.
We intend to audit your response to the programmed enhancement program.
The areas where we do not fully understand your responses as indicated above may be covered in the audit of programmed enhancements.
Sincere ly, DISTRIBUTION NRC 5 LOCAL PDRs PD31 GRAY FILE JZWOLINSKI ACRS(10)
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D SP JGI 12 JGI ITTER PSHUTTLEWORTH OGC EJORDAN PM/P 1:DRSP 12/~ 89 C~ifin@slgnedby Joseph G. Giitter, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V 5 Special Projects Office of Nuclear Reactor Regulation COOK GL88-17 COMMENTS
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