ML17331A141

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Requests Relief from Performance of Load Rejection Test of FSAR Amend 82.Test Deemed Unnecessary Because Stringent Surveillance Testing Has Assured That Overspeed Protection Equipment Will Perform When Required.Risks Not Justified
ML17331A141
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 02/16/1979
From: Disbrow R
INDIANA MICHIGAN POWER CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
AEP:NRC:00130, AEP:NRC:130, NUDOCS 7902270231
Download: ML17331A141 (9)


Text

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RKGULATO 'NFORMATION DISTRIBUTION "

STEM (RIDS)

ACCESSION NBR:7902270231'OC

~ DATE:'9/02/16 NOTARIZED:

YES DOCKET FACIL!50~316 DONALD 'C ~

COOK NUCLEAR POWER PLANTr UNIT 2i INDIANA 5 05000316 AUTHGNAME AUTHOR =AFFILIATION DISBROWt R ~ Ea INDIANA 5 MICHIGAN POWER CO ~

RECIP ~ NAME RECIPIENT AFFILIATION DENTON H,R ~

OFFICE OF NUCLEAR REACTOR REGUL'ATION

SUBJECT:

REQUESTS RELIEF-FROM PERFORMANCE OF LOAD REJECTION 'TEST OF FSAR AMEND 82 ~ TEST OEEMEO UNNECESSARY BECAUSE STRINGENT SURVEILLANCE'ESTING HAS ASSURED THAT OVERSPEED PROTECTiON EQUIPMENT WILL'ERFORM WHEN REQUIRED ~ RISKS NOT JUSTIFIED ~

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INDIANA 5 MICHIGAN POWER COMPANY P. O. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 February 16, 1979 AEP:NRC:00130 Donald C.

Cook Nuclear Plant Unit No.

2 Docket No. 50-316 License No.

DPR-74 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U,S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Denton:

On November 27, 1978 (AEP:NRC:00086) we requested from the Commission permission from having to perform, as part of the startup testing of Unit 2 of the Donald C.

Cook Nuclear Plant, an independent turbine trip test.

More specifically, our request, transmitted to you as part of an FSAR amendment (No. 82), would allow us to perform only the load rejection test.

We have further evaluated the usefulness in performing a load rejection test.

Based on today's turbo-generator technology and the AEP experience in operating both the Cook Units and our coal-fired units, we have concluded that this load rejection test is unnecessary.

We therefore request relief from having to perform the load rejection test.

Let me now expand on the reasons on which we base our request.

The Unit 2 turbine control system, since commercial operation on July 1, 1978, has responded successfully, automatically or manually, from power levels above 75K on the following occasions:

DATE POWER TRIP REASON FOR TRIP 7/6/78 97%

Generator Loss of stator water cooling 7/14/78 985 Turb-Reactor Loss of feed pump

~90 22' 2g(

Nr. Harold R. Denton, Director AEP: NRC: 001 30 CONTINUED DATE 8/21/78 8/27/78 11/26/78 1/13/79 POWER 99K 85Ã 75K 100Ã TRIP Turb-Reactor Tur b-Reactor Turb-Reactor Generator REASON FOR TRIP Low Vacuum Low Vacuum Loss of Feed Pump Electrical Fault-ice on 765 kV Insulator The overspeed protection system is functionally checked on an annual basis.

The steam valves, main stop, control and reheat stops and inter-ceptor valves are tested weekly.

The emergency governor device simulating an overspeed trip is actuated weekly.

The oil trip system which actuates the controls for complete valve closure is tested during each start-up.

Please note that the unit trip from 98% power level on 7/14/78 shown

above, opened the generator breakers and simultaneously tripped the turbine valves hydraulically.

This is the same trip sequence performed during the Load Rejection Test, except that the unit would be at a slightly higher power/load.

The 100/ power condition was present in the January 13, 1979 trip also shown above, which is for all practical purposes identical to the load rejection test trip.

We have in the American Electric Power System, in addition to our two nuclear units, 39 single reheat units with over 650 operating years (177 unit years) of experience, and 11 double reheat units operating with over 90 operating years of experience.

Extensive and frequent checking of all equipment relevant to the turbine-generator's overspeed protection is carried out on these units.

Through proper surveillance testing, we are assured that the overspeed protection equipment will perform when required.

The load rejection test only proves that the equipment functions properly at that particular instance.

It is our opinion that the data to be gained from the performance of this test simply does not justify the risks involved

Hr. Harold R. Oenton, Director AEP:NRC:00130 when you unnecessarily expose this urgently needed production equipment to such violent transients.

r RED:em Sworn and subscribed to before me this g,'r" day of February, 1979 in New York County, New York Very truly yours, I

R.

E.

Di sbrow Vice President Notary cc:

R.

C. Callen G. Charnoff P.

W. Steketee R. J. Vollen R. Walsh D. V. Shaller-Bridgman R.

W. Jurgensen 1

c G=.GQF( t1. GI >M c;-'a of;:c;y York 0

31 ~~g<3431 Qualified fn ffo:y Yo:k County Commission Expires March 30, 1g.~

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41>/'7~x'.

Amended Fo"m Date:

william 0. Miller, Chief License Fee Management Branch,~M FACILITY AMENDMENT CLASSIFICATION - DOCKET NO(S)

Licensee:

P

'Plant Name and Unit(s):

License No(s):

6 P ho-0 5J' Request Dated:

4 FM 4.

9 7 ~

Assigned TAC No:

Licensee's Fee Classi.fication:

5"c-Y F Mail Control No:

Fee Remitted:

Yes M

No Class I

, IIA, III IV Y

, VI None 2.

This request is incorrectly classified and should be properly catecorizad as Class ~.

Justification for classificatio or reclassification:

0 Amendment No.

Date of Issuance

\\

I; This request has been reviewed by DDR/DPH in accordance vIith Section 170. 22 of Part 170 and is properly cate gori zed.

3.

Additional information is required to properly ca".egorize the request:

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4.

This request. is'a Class type of action and is exempt from iees because it:

(a) was filed by a nonprofit educational institutior (b) was filed by a Government agency and is not for a

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power reactor, (c) is for a Class (can only be a I, II, or III) arend.:,ent which results rom a written Commission request dated

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for the application and the amendment is to sirplify or clari=y license or technical specifications, has only minor safety significance, and is being issued for the convenience of the Commission, or (d) other (state reason therefor):

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Divis "on'f Operating Rea '~ors/Proj-"ct i'.=n"ge.".':-n-'~

The above request has been reviewed and is exempt from =ees$y~g

,'FMB 6/7B (illiam 0. Hiller, Chief License Fee Hanaqemcnt Branch Date

Milliam D. Hiller, Chief I License Fee Management Branch, ADM FACILITY AMENDMENT CLASSIFICAT ON - DOCKET NO(S).

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Licensee:

. Amen ddc~ A~

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0 Hail Control No:

~ 40 d P~

Fee Remitted:

Yes No I

IV,.V,VI Plant Name and Unit(s):

'icense,No(s):

'equest Dated:

'Assigned TAC No:

f 2-Licensee's Fee Classification:

ClassI, II sr, II None Amendment No.

Date of Issuance 1.

This request has been revievIed by DDR/DPN in accordance with Section 170.22 of Part 170 and is properly categorized.

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This request is incorrectly classified and should be properly categorized as C'lass Justification for classification or reclassification:

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3.

Additional information is required to properly categorize the request:

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4.

This request is a Class type of action and is exempt fron fees because it:(a)'as filed by a nonprofit educational institution, (b) was filed by a. Government agency'nd is not for a power reactor, (c) is for a Class (can only be a I, II, or III) amendment which results from a written Commission request dated for the application and the amendment is to simplify or clarify license or technical specifications, has only minor safety significance, and is being issued for the convenience of the Commission, or (d) other (state reason therefor):

cA. /

iv sio of pe tin eactors Projec iIanagement The above request has been r vieved a

d is exempt from fees.

iB 6/78 illiam 0. Miller, Chief License Fee Hanaqemcnt Branch Date

',RilTiam 0. Hiller, Chief

-;te:

License Fee Management

Branch,

,OM Amended te:

FACILITY AMENDMENT CLASSIFICATION -

DOCKET NO(S).

Licensee:

P Plant Name and Unit(s):

License No(s):

8 Pg b~

5 J <

Mail Control No:

Request Dated:

vt FM d

0 7 p Fee Remitted:

Yes M

Ro Assigned TAC No:

4 Licensee's Fee Classi.fication:

Class I

, IIA, III

, IY Y

, YI None m

Amendment No.

Date of Issuance I;

This request has been reviewed by DOR/DPH in accordance with Section 170.22 of Part 170 and is properly categorized.

Qg R.

This request is incorrectly classified and should be properly categorized as Class ~.

Justification for classificatio or reclassif'ication:

e Additional information is required to properly categorize the request:

4.

This request is aCl'ass type of action and is exempt from fees because it:

(a) was filed by a nonprofit educational institution, (b) was filed by a Government agency and is not for a

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power reactor, (c) is for a Class (can only be a I, II, or III) ar,endment which results from a written Commission request dated

./

for the application and the amendr.ent is to simplify or clari=y license, or technical specifications, has only minor safety significance, and is being issued for the convenience of the

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Commission, or (d) other (state reason therefor):

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C.C'ivis on'f Operating Rea ors/Project ihianage".;.ent The above request has been reviewed and is exempt from fees.

li FMB e/78 lilliam 0. Miller, Chief License Fee Management Branch Date

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