ML17329A001

From kanterella
Jump to navigation Jump to search
Application for Amends to Licenses DPR-58 & DPR-74,changing Tech Specs 4.6.1.1 & 4.6.1.2 to Clarify Potential Deficiency in Requirements for Containment Airlocks & Making Unit 1 Airlock Surveillance Consistent W/Unit 2
ML17329A001
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 04/16/1991
From: Fitzpatrick E
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To: Murley T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17329A002 List:
References
AEP:NRC:1145, NUDOCS 9104220192
Download: ML17329A001 (9)
v • d • e


Text

ACCELERATED DIS UTION DEMONS TION SYSTEM

'I ~

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9104220192 DOC. DATE: 91/04/16 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana & 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana & 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to Licenses DPR-58 & DPR-74,changing Tech Specs 4.6.1.1 & 4.6.1.2 to clarify potential deficiency in requirements for containment airlocks & making D Unit 1 airlock surveillance consistent w/Unit 2.

DISTRIBDTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution $ ENCL g SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES'TTR D ID CODE/NAME LTTR ENCL ID CODE/NAME ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 COLBURN,T. 2 2 D

INTERNAL: NRR/DET/ECMB 9H 1 1 NRR/DET/ESGB 1 1 NRR/DOEA/OTSBll 1 1 NRR/DST 8E2 1 1 NRR/DST/SELB 8D 1 1 NRR/DST/SICB 7E 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 OC/LFMB 1 0 OGC/HDS2 1 0 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR NSIC 1 1 R

D A

D D

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 16

Indiana Michigan Power Company One Summit Square P.O. Box 60 Fort Wayne, IN 46801 219 425 2111 EN!NANSl MCNlGQN PSST AEP'NRC:1145 Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 TECHNICAL SPECIFICATIONS CHANGE REQUEST; REQUIREMENTS FOR CONTAINMENT AIR LOCKS U.S. Nuclear Regulatory Commission Attn: Document Control Desk Vashington, D.C. 20555 Attn: T ~ E. Murley April 16, 1991

'ear Dr. Murley:

This letter and its attachments constitute an application for changes to the Technical Specifications (T/Ss) for Donald C. Cook Nuclear Plant Units 1 and 2 in accordance with 10 CFR 50.90. The proposed changes will clarify a potential discrepancy in the requirements for the containment air locks contained in T/Ss 1.8, 4.6.1.1 and 4.6.1.2. Ve are also proposing a change to make the Unit 1 air lock seal surveillance consistent with that of Unit 2 and the Standard Vestinghouse T/Ss.

Attachment 1 provides a detailed description of the proposed changes, the justification for the changes, and our proposed determination of no significant hazards consideration performed pursuant to 10 CFR 50.92. Attachment 2 contains the existing T/Ss pages marked to reflect the proposed changes. Attachment 3 contains the proposed T/Ss pages, As a point of information, in an October 5, 1989 submittal, the Tennessee Valley Authority requested on behalf of its Sequoyah Nuclear Plant the identical changes that we are requesting in this submittal. That request was subsequently approved by the NRC on February 16, 1990.

Ve believe that the proposed changes will not result in (1) a significant change in the types of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

9104220192 910016 PDR'DOCK 05000315 P

" PDR

Dr. T. E. Murley AEP:NRC:1145 The proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee.

In compliance with the requirements of 10 CFR 50.91 (b)(1), copies of this letter and its attachments have been transmitted to Mr. J. R. Padgett of the Michigan Public Service Commission and to the Michigan Department of Public Health.

This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature of the undersigned, Sincerely, E. E. Fi zpatrick" Vice President Attachments cc: D. H. Williams, Jr, A. A. Blind - Bridgman J. R, Padgett G. Charnoff A. B. Davis - Region III NRC Resident Inspector - Bridgman NFEM Section Chief

Attachment 1 to AEP:NRC:1145 10 CFR 50.92 Analysis for Changes to the Donald C. Cook Nuclear Plant Uni.ts 1 and 2 Technical Specifications

Attachment 1 to AEP:NRC:1145 Page 1 k

1.0 SECTIONS TO BE CHANGED Technical Specifications (T/Ss) Sections 1.8, 4.6.1.1.b, and 4.6,1.2.e for both Units 1 and 2. Technical Specifications Section 4.6.1.3.a for Unit 1.

2.0 EXTENT OF CHANGE We propose to modify the definition of containment integrity given in T/S 1.8 and the surveillance requirements specified in T/Ss 4.6.1.1.b and 4.6.1.2.e for both Cook Nuclear Plant units'he proposed changes modify the requirements for containment air locks to be consistent with Revision 5 of NUREG-0452, "Standard Technical Specifications for Westinghouse Pressurized Water Reactors," (W STS).

In addition, we propose to delete Unit 1 T/S 4.6.1.3,a, which will make the Unit 1 T/Ss consistent with those of Unit 2 and with Revisions 4 and 5 of the W STS.

3.0 CHANGES RE UESTED We are proposing to make the following changes to both the Unit 1 and Unit 2 T/Ss.

Revise the Definition of Containment Inte rit Currently, T/S 1.8, which is the definition of containment integrity, includes the following statement:

Each air lock is OPERABLE pursuant to Specification 3.6.1.3, and We are proposing to adopt the wording of Revision 5 of the W STS to define containment integrity (W STS 1.7), as follows:

Each air lock is in compliance with the requirements of Specification 3.6.1.3, and Revise T S 4.6.1.1.b to Re uire Com liance Rather Than 0 erabilit The current T/S reads as follows; By verifying that each containment air lock is OPERABLE per Specification 3.6.1.3.

We are proposing to modify it in accordance with Revision 5 of the W STS, as follows:

By verifying that each containment air lock is in compliance with the requirements of Specification 3.6.1.3.

Attachment 1 to AEP:NRC:1145 Page 2 Revise T S 4.6.1.2.e to Re uire Com liance Rather Than 0 erabilit Currently T/S 4.6.1.2.e states:

Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.

We are proposing to modify this as follows:

Each containment air lock shall be verified to be in compliance with the requirements of Specification 3.6.1.3.

Remove Unit 1 T S 4.6.1.3.a Re irement for Visual Ins ection of Airlock Seals Currently T/S 4.6.1.3 states:

Each containment air lock shall be demonstrated OPERABLE:

a. By visual inspection after each opening to verify that the seal has not been damaged.

We propose to delete this requirement and renumber the subsequent surveillance requirements.

4.0 DISCUSSION S stem Descri tion The containment system is designed to ensure that acceptable, limits for leakage to the environment of radioactive materials are not exceeded even in the improbable event of a gross rupture of a reactor coolant system pipe.

Together with the engineered safety features, the containment system is designed to limit radiation doses under conditions resulting from the design basis accident (DBA) to less than 10CFR100 criteria at the site boundary and beyond. The DBA is defined in Chapter 5 of the UFSAR as a double-ended rupture of the largest pipe in the reactor coolant system.

The containment air locks, which are part of the containment pressure boundary, provide a means for personnel access during all modes of operation. The air lock doors have been designed and certified capable of withstanding a pressure in excess of the maximum peak pressure resulting from a DBA. Each door is provided with double gasket seals to provide pressure integrity. Consequently, closing one door establishes containment integrity.

To ensure that containment integrity is maintained, an air lock door mechanism prevents both doors from being opened simultaneously. In addition, control room indication is provided to alert the operator whenever an air lock door interlock mechanism is defeated.

Attachment 1 to AEP:NRC:1145 Page 3 Justification for Chan e i ecification 3.6.1.1 states that Tec h n ca 1 S pec primary containment integrity shall be maintained in Modes 1, 2, 3 and 4. The action s a e T/S states that, without containment integrity, containment i t rity must be restoredprimary within one hour or the un it must be in at least hot standby within the next. six hours and in cold shutdown within the h following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Surveillance Requirement 4.6.1.1.b requires that each containment air lock e er T/S 3.6.1.3. The action statement of T/S 3,6.1.3 states that, with an airlock inoperable, the airlock must be restorered too op o erable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the unit must be in at least hot standby within the next six hours and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The / '.l.l.b

~ording o f T/S 4 may lead to an interpretation that precludes .

the use of the action provisions given in T/S 3.6.1,3 when an air oc s inoperable but still within the allowed leakage limits of T/S 3,6.1.2. The wording in Revision 5 of the W STS allows the use of the action provisions given in T/S 3.6.1.3.

The 24-hour allowable out-of-service time given in T/S 3..6.1.3 is both reasonable and prudent for those cases in which air lock leakage renders the air lock inoperable but does not present a containment integrity problem.

The 24-hour period provides time to repair the air lock before imposing a P lant transient and plant shutdown. The 1-hour allowable out-of-service time given in the T/S 3.6.1.1 action statement is appropriate for those cases in which air lock leakage represents a containment integrity problem.

in T/S 4.6,1.2.e also contain the requirement that /the containment The current definition of containment integrity given in T/S 1,8 and the wor ding air locks be operable. This wording, as well as that of T/S 4. . . . , s consistent with Revision 4 of the W STS. Westinghouse STSs (Revision 5) 1.7 (Cook Nuclear Plant T/S 1.8) and 4.6.1 1.b require compliance with T/S

~

3.6.1.3 for the containment air locks. Consequently, the approval of this T/Ss change request would make Cook Nuclear Plant T/Ss l..8 and 4.6.l.l.b consistent with Revision 5 of the W STS.

The existing T/S 4.6.1.2.e is identical to that in Revision 5 of the W STS.

However, we are proposing to change the word "operable" to "compliance" to allow the use of the action provisions contained in T/S 3.6,1. 1.3. This wording was approved by the NRC for Sequoyah Nuclear Plant Units 1 and 2 on February 16, 1990.

The proposed changes to the containment integrity definition given in T/S 1.8, as well as the proposed changes to T/Ss 4.6.l.l.b and 4.6.1.2,e, car y clarif thee requirements for air lock inoperability for those cases in which overall air lock leakage does not present a containment integri y p The proposed changes do not affect the overall containment leakage requirements imposed through T/Ss 3.6,1.1 and 3.6.1.2,

Attachment 1 to AEP:NRC:1145 Page 4 The existing Unit 1 T/S 4.6.1.3.a requires that a visual inspection be performed after each air lock door opening to verify that the seal has not been damaged. Neither the Unit 2 T/Ss nor Revisions 4 or 5 of the W STSs require a visual inspection. The visual inspection is a good practice and we plan to continue it even if our request to delete the requirement from the Unit 1 T/S is granted. In fact, although it is not required by the T/Ss, we c'urrently perform visual inspections on Unit 2. However, having the requirement in the T/Ss puts us in jeopardy of a reportable event if we cannot provide documentation that the inspection was done. There are literally hundreds of entries into containment during Modes 1-4 and the burden of ensuring that visual inspections are completed and documented seems unnecessary and causes distractions to control room personnel.

5.0 NO SIGNIFICANT HAZARDS DETERMINATION We have evaluated the proposed T/Ss change and have determined that it does not represent a significant hazards consideration based on the criteria established in 10CFR50.92(c). Op'eration of the Cook Nuclear Plant in accordance with the proposed amendment will nots (1) Involve a si nificant increase in the robabilit or conse uences of an accident reviousl evaluated.

As described in Section 5.0 of the UFSAR, the containment structure is designed to ensure that an acceptable upper limit of leakage of radioactive material is not exceeded under design basis accident conditions. The containment air locks, which provide personnel access to both upper and lower containment, were designed and constructed and are tested to ensure that the allowable leakage limits for containment are maintained. The proposed changes to the definition of containment integrity and to T/Ss 4.6.1.1.b and 4.6.1.2.e are made to clarify the use of the action provisions of T/S 3.6.1.3. The actual acceptance criteria for primary containment and air lock leakage rates remain unchanged. The proposed change to T/S 4.6.1.3.a will make the T/Ss consistent between the units and with the W STSs. As such, the proposed changes are administrative in nature and serve to eliminate the potential for misinterpretation of the T/Ss requirements. The proposed changes do not increase the probability of a previously evaluated accident because the primary containment and air lock leakage rates are not associated with the initiation of any design basis accident. Because the acceptable limits on the primary containment and air lock leakage rates remain unchanged, the consequences of a previously evaluated accident are not increased.

Attachment 1 to AEP:NRC:1145 Page 5 (2) Create the ossibilit of a new or different kind of accident from an re'viousl anal zed.

As described above, the proposed changes to the definition of containment integrity and to T/Ss 4.6.1.1.b and 4.6. 1.2.e are made to clearly allow the use of the action provisions of T/S 3.6.1.3.

The proposed change to Unit 1 T/S 4.6.1.3.a will reduce the administrative requirements for Unit 1 and will make the requirements of Units 1 and 2 identical. The acceptance criteria for primary containment and air lock leakage rates remain unchanged. Thus, no radiological consequence analysis assumptions are changed. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any previously analyzed.

(3) Involve a si nificant reduction in a mar in of safet The proposed changes to the definition of containment integrity and to T/Ss 4.6.1.1.b and 4.6.1.2.e are made to clarify the use of the action provisions of T/S 3.6.1.3. The proposed change to Unit 1 T/S 4.6.1.3.a will remove an overly conservative documentation requirement that distracts control room personnel's attention from more important safety-related activities. The proposed changes are administrative in nature and serve to eliminate the potential for misinterpretation of the T/Ss requirements. The actual acceptance criteria for primary containment and air lock leakage rates are not changed.

Therefore, the proposed changes do not reduce the margin of safety.

6.0 PENDING T Ss PROPOSALS IMPACTING THIS SUBMITTAL At the time that this submittal is made, no T/Ss change requests that would impact the T/Ss being proposed herein are pending NRC review.

Retrieved from "https://kanterella.com/w/index.php?title=ML17329A001&oldid=1984116"