ML17329A368
| ML17329A368 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/24/1992 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| Shared Package | |
| ML17329A369 | List: |
| References | |
| NUDOCS 9201310011 | |
| Download: ML17329A368 (6) | |
Text
Docket No. 50-316 Indiana Michigan Power Company ATTN:
Hr. E.
E. Fitzpatrick Vice President
~
Nuclear Operations Division 1 Riverside Plaza
- Columbus, OH 43216
Dear Nr. Fitzpatrick:
We have reviewed your letter dated January 23,
- 1992, (AEP:NRC:1172) documenting your oral request for a one-time basis Waiver of Compliance from Donald C.
Cook Plant,Unit 2 Technical Specifications, Sections 3/4 1.2.8 and 3/4 5.5, These Technical Specifications require, among other things, that the Refueling Water Storage Tank (RWST) boron concentration must be between 2,400 ppm and 2,600 ppm.
You requested relief from the upper limit.
A copy of your letter is enclosed.
The circumstances leading to this request were that, following transfers ef water among various storage tanks onsite, including a consequential increase in RWST contained volume, you discovered the RWST boron concentration was above 2,600 ppm.
The highest sample had a concentration of 2,644 ppm.
In compliance with applicable Technical Specifications referenced
- above, you declared the RWST inoperable at 6:30 a.m.
(EST) on January 22, 1992.
You initiated an orderly plant shutdown at 8:22 a.m. to ensure compliance to a
time limit of 1:30 p.m. for achieving hot standby.
Concurrently, you performed an evaluation of the safety significance of the out-of-specification condition.
The limit in question was established to control post-accident pH within analyzed bounds.
In the current plant conditions, wi-th reduced boric acid concentration in the primary coolant
- system, post-accident pH would remain within analyz'ed bounds with a RWST boron concentration up to 2,872 ppm.
Therefore,
-the proposed waiver retains conformance to analyzed conditions and the margin of safety is not reduced.
You contacted this office, and the Office of Nuclear Reactor Regulation (NRR),
with a verbal request for a Waiver of Compliance.
A joint conference call among your staff at both the plant and the corporate office, staff of NRC Region III, and NRR personnel, was conducted.
We gave a verbal authorization at 11:15 a.m.
(EST) temporarily waiving the subject boron limit, because there was no consequent safety risk.
9'201310011
'720124 PDR ADOCK 0'5000316 P
'ndiana Michigan Power Company The verbal waiver was also premised on the following conditions:
1.
RWST upper boron concentration was not to exceed 2,700 ppm.
2.
With one containment spray (CS) puttp in use for RWST recirculation, no work was to be permitted on the other CS train.
'3; Procedures or instructions were to be put in place to restore the CS pump from recirculation to emergency mode if needed.
I 4.
Any plant anomalies associated with RWST boron is to be immediately reported to the NRC Res.dent Inspector.
5.
Duration was limited to six days or such earlier time as concentration is returned to specification.
We understand that you have determined that your request for a temporary Waiver of'ompliance, meets the eligibility criteria in 10 CFR 51.22(c)(9) and-that pursuant to 10 CFR 51.22(b),
no environmental impact statement need be prepared.
We oranted the requested relief on January 22, 1992, based on the minimal increase
.in risk associated with delaying a plant shutdown to allow time to restore full compliance.
Requiring an immediate plant shutdown could result in an unnecessary thermal cycle on the plant.
This letter constitutes written Waiver of Compliance under the same terms-and conditions specified above in the discussion of the verbal waiver.
Specifically, Items 1. through 6. remain in effect.
If these conditions cannot be met during the waiver pqriod, or if other Technical Specification actions not covered by the waiver may so re'quire, we understand that you will promptly initiate an orderly shutdown.
Enclosure:
As Stated See Attached Distribution A. Bert Davis Regional Administrator
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Indiana Michigan Power Company Distribution cc w/enclosure:
A. A. Blind, Plant Manager DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office M'.chigan Department of Public Health D. C. Cook,
- LPM, NRR T.
E. Murley, Director, NRR J.
Lieberman, Director, OE M. Boyle, Technical Assistant, DRP I/II, NRR E. Leeds, Technical Assistant, DRP III/IV/V,NRR B. A. Boger., Director, DRP III/IV/V, NRR L. B. Marsh, Directorate III, NRR PDR
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~s UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 399 ROOSEVELT ROAD CLEN ELLYN, ILLINOIS 60137 Docket No. 50-316 Indiana Michigan Power Company ATTN:
fir. E.
E. Fitzpatrick Vice President Nuclear Operations Division 1 Riverside Plaza
- Columbus, OH 43216
Dear Nr. Fitzpatrick:
1 We have reviewed your letter dated January 23, 1992, (AEP:NRC:1172) documenting your oral recuest for a one-time basis Waiver of Compliance from Donald C.
Cook Plant Unit 2 Technical Specifications, Sections 3/4 1.2.8 and 3/4 5.5.
These Technical Specifications require, among other things, that the Refueling Water Storage Tank (RWST) boron concentration must be between 2,400 ppm and 2,600 ppm.
You requested relief from the upper limit.
A copy of your letter is enclosed.
The circumstances leading to this request were that, following transfers of water among various storage tanks onsite, including a consequential increase in RWST contained volume, you discovered the Rl.'ST boron concentration was above 2,600 ppm.
The highest sample had a concentration of 2,644 ppm.
In compliance with applicable Technical Specifications referenced
- above, you declared the PWST inoperable at 6:30 a.m.
(EST) on January 22, 1992.
You initiated an orderly plant shutdown at 8:22 a.m. to ensure compliance to a.
time limit of 1:3C p.m. for achieving hot stardby.
Concurrently, you performed an evaluation of the safety significance of the
'out-of-spEc',fication condition.
The limit irI question was established to
'ontrol post-accident pH within analyzed bounds.
In the current plant conditions, with reduced boric acid concentration in the primary coolant
- system, post-accident pH would remain within analyzed bounds with a RWST
- boron corcerItration up to 2,872 ppm.
Therefore, the proposed waiver retains conformance to ar alyzed conditions aIId the marg ir of safety is not reduced.
You contacted this office, and the Office of Nuclear Reactor Regulation (NRR),
with a verba'equest for a Waiver of Compliance.
A joint conference call among your staff at both'he plant and the corporate office, staff of NRC Region III, and NRR personnel, was conducted.
We gave a verbal authorization at 11:15 a.m.
(EST) temporarily waiving.the subject bcrnn limit, because there s~-s I o consequent safety risl.
Indiana H~chigan.Power Company The verbal waiver was also pres;ised cn the fo",cwing conditions:
1.
-PWST upper boron concentration was not to exceed 2,700 ppm.
2.
With ore containment spray (CS) pump in use for RllST recirculation, no work was to be permitted on the other CS train.
3.
Procedures or instructions were to be put in place to i estore the CS pump from recircu~ation to emergency mode if needed.
4.
Any, plant anomalies associated with RWST boron is to be immediately reported to the NRC Resident Inspector.
Duration was limited to six days or such earlier time as concentration is returned to specification.
We understand that you have de'errrined that your request for a temporary Waiver of Compliance meets the eligibility criteria in 10 CFR 51.22(c)(9) and that pursuant to 10 CFR 51.22(b),
no environmental impact statement need be prepared.
We granted the requested relief on January 22,
- 1992, based on the minimal increase in risk associated with delaying a plant shutdown to allow time to restore full compliance.
Reauiring an immediate plant shutdown could result in an unnecessary thermal cycle on the plant.
This letter constitutes written Waiver of Compliance under the same terms and conditions specified above in the discussion of the verbal waiver.
Specifically, Items 1. through 6. remain in effect.
If these cord',tions cannot be met during the waiver period, or if other Technical Specification actions not covered by the waiver may so
- require, we understand that you will promptly ir tiate an orderly shutdown.
Enclosure:
As Stated Pegional Administrator II See Attached Distribution
Indiana Michigan Power Company Distribution cc w/enclosure:
A..A. Blind, Plant Manager DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office Michigan Department of Public Health D. C. Cook,
Lieberman, Director, OE M. Boyle, Technical Assistant, DRP I/II, NRR
. E. Leeds, Technical Assistant, DRP III/IV/V,NRR B. A. Boger, Director, DRP III/IV/Y, NRR.