ML17331A102
| ML17331A102 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/16/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17331A101 | List: |
| References | |
| NUDOCS 9303230282 | |
| Download: ML17331A102 (3) | |
Text
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Op0 UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
TO FACILITY OPERATING LICENSE NO.
DPR-58 ND AMENDMENT NO.
153 TO FACILITY OPERATING LICENSE NO.
DPR-7 INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 AND 2 DOCKET NOS.
50-315 AND 50-316
- 1. 0 INTRODUCTION By letter dated February 21, 1991, the Indiana Michigan Power Company (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License Nos.
DPR-58 and DPR-74 for the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2.
The proposed amendments would add a
statement to TS 3.6.3. 1 that would make TS 3.0.4 not applicable, thus allowing mode changes with a containment isolation valve inoperable.
The requested change is in accordance with Generic Letter (GL) 91-08, "Removal of Component Lists from the Technical Specifications,"
by adding the following statement to the Limiting Condition for Operation (LCO) 3.6.3. 1:
"The provisions of specification 3.0.4 are not applicable."
This exception would apply to all containment isolation valves listed in Table 3.6-1 associated with TS 3.6.3. 1.
Enclosure 1 to GL 87-09, "Alternatives to the STS Requirements to Resolve Three Specific Problems with Limiting Conditions for Operation and Surveillance Requirements,"
states that although TS 3.0.4 may unduly restrict facility operation, nothing in the staff position should be interpreted as endorsing or encouraging a plant start-up with inoperable equipment.
- However, even with the staff guidance and recommendations in GL 87-09, the staff believes there is still room for misinterpretation of the intent of an exception to TS 3.0.4.
Therefore, included in this Safety Evaluation is a
discussion of the staff's intent and expectations in granting a TS 3.0.4 exception.
- 2. 0 EVALUATION The list of containment isolation valves generally found within TS typically include footnotes that modify the TS requirements for these valves.
Generic Letter 91-08 provides guidance on removing the list of valves from the TS, if the licensee opts to do so.
Part of this guidance is that these footnotes must be incorporated into the LCO so that they will remain in effect when the table listing the valves is removed from the TS..
By incorporating this 9303230282 9303i6 PDR ADOCK 050003l5 PDR
guidance into the LCO, the licensee could delete the list of valves from TS 3.6.3. 1 while still keeping the appropriate guidance in effect.
Generic Letter 87-09 noted that there has been an inconsistent application of TS 3.0.4 in that it would "...preclude entering a mode or specified condition if an LCO is not met, even if the Action Requirements would permit continued operation of the facility for an unlimited period of time.
Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply.
However, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well documented....Although the staff encourages the maintenance of all plant systems and components in an operable condition as a good practice, the T/Ss generally have not precluded entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operation."
The action requirements for containment isolation valves (CIVs) permit continued operation with an inoperable valve when the associated penetration is isolated.
The licensee has administrative controls in place to limit the use of TS 3.0.4 exceptions.
This includes PHI-4030, "Technical Specifications Review and Surveillance,"
which requires review and approval of a mode change under the TS 3.0.4 exception by the operations department superintendent and the plant manager.
Additionally, the licensee s prioritization scheme for corrective maintenance classifies job orders concerning inoperable Technical Specification-related equipment as generally having the highest priority to be worked.
The staff has reviewed the licensee's submittal and has found the proposed change to be acceptable.
The exception from requirements of TS 3.0.4 is applicable to all CIVs.
This change is acceptable because it is consistent with the guidance provided in GL 91-08, as long as the intent and expectations regarding the exception from TS 3.0.4 (discussed below) are met.
The guidance provided in GL 87-09 and GL 91-08 should not be interpreted to allow CIVs to remain in a degraded condition indefinitely.
Containment isolation valves serve a significant safety function in that they establish containment integrity.
Therefore, it is urgent that these valves be returned to an operable status at the earliest possible opportunity.
In general, the staff believes that nuclear plants should start-up from an outage with all CIVs operable.
But because of extenuating circumstances, such as unavailability of equipment needed for repair or replacement, or the discovery of inoperable CIVs just prior to start-up, there will be isolated instances where allowances will be made to support a start-up with inoperable CIVs.
However, these isolated instances should coexist with the understanding that the inoperable CIV(s) be repaired or replaced at the earliest possible opportunity in accordance with 10 CFR Part 50, Appendix B.
The licensee is also expected to keep the NRC staff abreast of such instances.
Moreover, in approving the above licensee-proposed change to TS 3.6.3. 1, the staff holds the following position, which is contained in TS 4.0.4:
Entry into an operational mode or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation has been performed within the stated surveillance interval, or as otherwise specified.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change the requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (56 FR 22470).
Accordingly, the 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 the amendments.
5.0 CONCLUSION
The staff has 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, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
T. Dunning A. Young W. Dean Date:
March 16, 1993