ML17331A684

Forwards Response to 801124 Ltr Re Applicable Provisions of App R to 10CFR50 for Fire Protection Emergency Lighting & Reactor Coolant Pump Oil Collection Sys.No Further Actions Needed Re Section III G, Fire Protection of Safe....

ML17331A684
Person / Time
Site:	Cook
Issue date:	03/27/1981
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:00428A, AEP:NRC:428A, NUDOCS 8104060589
Download: ML17331A684 (23)

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INDIANA L MICHIGAN ELECTRIC COMPANY P'. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 March.27, 1981 AEP:NRC:00428A Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 FIRE PROTECTION RULE (45 FR 76602)

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Denton:

The attachment to this letter provides our response to Mr. Eisenhut's letter of November 24, 1980 regarding the provisions of Appendix R to 10 CFR 50 which are applicable to the D. C. Cook Nuclear Plant, Those provisions are set. forth in Section III.G, "Fire Protection'of Safe Shutdown Capability"',

III.J, "Emergency Lighting"; and III.O, "Oil Collection'ystems for Reactor Coolant Pump" of the said Appendix R.

On July 31, 1979, the Commission issued Amendments No. 31 and No. 12 to the Cook Plant Operating L'icense, along with the corresponding Fire Protection Safety Evaluation Report (SER). Table 1 of the SER listed the plant modifications'nd their respective completion dates. All of the items in Table 1 have been implemented, as required, and as'uch the fire protection program for the'Cook Plant is in'ull compliance with the guidelines contained in Appendix A to Branch. Technical Position APCSB 9.5-1 and General Design Criterion 3. These facts 'are supported by the NRC's conclusion .drawn in the July 31, 1979 SER which states:

conclusion is that a fire occurring in any area of the

'Our D. C.'ook Nuclear. Plant will not prevent either unit from being brought to a controlled safe shutdown, and further .

that such a fire would not cause the release of significant amounts of radiation";

Sro <0005/.,

Mr. Harold R. Denton AEP:NRC:00428A On January 30, 1981, the Commission issued Amendments No. 44 and No. 26 to the Cook Plant Operating Licenses which provided us with the final revision to our fire protection Technical Specifications in accordance with Table 1 of the Fire Protection SER.

Enclosure 2 to Mr. Eisenhut's November. 24, 1980 letter states that no open items from previous NRC staff fire protection reviews exist. for the Cook Plant. The attachment to thi's letter demonstrates that the Cook Plant

'is already in compliance with the applicable provisions of Appendix R, noted above, which Mr..Eisenhut s letter requires to be backfit. These. provisions of Appendix R, although not explicitly required by NRC Branch Technical-.

Position APCSB 9.5-1, were included in the previous fire protection. upgr'ade as a result of the Plant' Fire Hazards Analysis and the ensuing. NRC 'ffort questions/positions on the fire protection features of the Cook Plant.

Very truly yours,

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'R". S. Hunter

.,Vice President cc: John E: Dolan - Columbus R. W; Jurgensen D. V. Shaller - Bridgman R. C. Cal 1 en G. Charnoff Region III Resident Inspector at Cook Plant - Bridgman

ATTACHMENT TO AEP:HRC;00428A

Tni s a t tacnment prov ides our response to Sections I I I . G, I I I . J and I I I. 0 of Appendix R to 10. CFR. 50 as required by 10CFR50.48(c) (5) . The information and references provided below demonstrate compliance with those sections of Appendix R and, as such, no further'lant. modifications are neces-sary.

0~1 The initial design of the Cook Nuclear Plant employs a Hot Shutdow.. panel for each Unit separated from its associated Unit's control room. This control panel contains sufficient instruments'nd controls to shut the reactor down and maintain it in a hot shutdown condition.

Upon receipt of I E Bul 1 etins 75-04 and 75-04A, i ssued subsequent to the Brown's Ferry Fire, a thorough study of the Cook Plant design was made to determine what'hanges and additions'ould have to be made to the existing plant design to permit shutting the reactor down and bringing the Unit to a cold shutdown condition from outside the control room. This study was completed and is described in our responses to the bul 1 etin's and monthly progress reports on the status of the work submitted to the NRC. The re-quired engineering changes consisted of the installation jn each Unit of local remote shutdown indicator panels with .cabling independent of the cable spreading rooms. An al ternate emergency shutdown and cool down procedur'e in the event of a loss of normal and preferred alternate methods has been for use in corijunction with 'the local shutdown system. The procedure de-'eloped has been written so that it cari be used in part or in its entirety by pro-viding instructions for taking local control of any operation that can not be performed using normal or preferred alternate methods. The specific procedures for modifying components for local control are mounted at the component so that, they wil 1 .be readily available 'when the need arises.

Through the use of these local shutdown panels, modifications of standby essential equipment for local manual control and the associated emergency shutdown and cooldown procedure, we have the installed and demonstrated cap-ability to safely shutdown arid cooldown the plant with or without offsite power upon loss of 'control of essential systems and 'equipment rom the con-trol room and/or ihe ho shutdown panel.

Me provided further detail ed descr iptive information on the local shutdown system and procedures in our response to Appendix A to Branch Technical Position APCSB 9.5-1. in our Fire Hazards Analysis, during the NRC fire protection site v i si t (April 1 9-22, 1 977), at the t1ay 11, 1 977 meeting with the NRC staff, i n'ur letter of June 1, 1977 (fol 1owup to the I'1ay 1, 1 1977 meeting); in parts of Appendix Q to the FSAR (Question-040.5) and in

. our responses to. the "Fire'rotection Questions" 1, 40, 46, 47, 52 asked in Hr.. K. Kniel 's letter of July 11, 1977. In addition, we have provided in both Units 1 and 2 local manual control capability of the emergency diesel generators as oart of the alternate local shutdown system in accordance with Unit 2 license condition 2. C. 3. (0). (c). This provides the local shutdown system wi th t'e capabi1 i ty of performing i ts function- given a:1 oss of offsi te power. 'he NRC f ire protection SER, i ssued July 31, 1979, accepted tne Cook local shutdown system and,amended the Cook operating licenses accordingly, (removing Unit 2 license condition 2.C.3. (0) "eotirely). All changes and improvements li sted in Table 1 of .the SER, including those pertaining to the

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local shutdown system have been implemented. Furthermore, as rep'orted in the SER, the procedures and control operations for the local shutdown method

.were testec during Unit 2 initial power ascension. As such, the Cook Plant capability to achieve and maintain a safe cold shutdown condition including the necessary communications has been fully demonstrated.

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Our fire hazards analysis considered the effects of fire in every fire zone'n. the Cook Plant with respect to structures, systems, and com-ponents important to safe shutdown. In all cases the ability to achieve and maintain a safe shutdown condition is preserved. Redundancy of design and separation of systems and equipment is provided in the Cook Plant design.

As stated in our response to Question 040.6 in Appendix Q to the FSAR, the design of the Cook Plant complies with the separation requirements of -Safety Guide '1.75 as applied to Class IE equipment and circuitry.

For'the treatment of associated circuits the Cook Plant design provides the following:

a) Won Class IE cables ar routed with Class IE cail"s in cable trays. The cable numbers of these associated cir-cuits are modified to include a letter designation identifying

'he train association. These cables are allowed to leave the Class IE cable t'rays and be. routed with non-safety cables but are not allowed to be again routed with Class IE cables of either safety train.

b) tlon-safety loads are allowed to be connected to sa=ety buses

.in the following manner. All non-safety loads, whether shed automatically upon transfer to emergency power or retained, are powered through Class IE circuit interrUpting devices.'ll load shedding devices are Class IE as are the fault detecting and isolating equipment, applied to disconnecting non-safety.

related loads. The non-safety loads are described in our re-sponse to Question 040.11 and 040.14 in Aopendix Q to the FSAR.

These non-safety loads do not degrade the performance of any sa ety bus.'lass IE circuit breakers a) e. provided for non-safety AC loads ed from AC safety buses ivhich are .not shed

. following a loss of offsite power.

c) For the DC power system, fuses are used as the protective de-vices for non-safety 'loads connected to the -DC safety buses.

idion-safety cables originating from the CD ba'ttery. (for example) are permitted to be routed wi.th safety cables of the CD battery only. Non-safety cah'les from the CD hattery are allowed to leave the=.CD battery safety trays 'and be routed with the balance of plant cables in non-safety trays but are not allowed to be again routed with CE battery safety cables. Once the non-safety cable leaves the safety train routing it must remain in the non-cable routing and cannot be again routed with the safety 'afety train cables of either train.

r d) Protection grade instrument ation safety equipment's protected from faults in the non-safety analog circuits connected to it by Isolators.

When accounting for the redundancy and senaration of circuits for equipment necessary to achieve and maintain safe shutdown(Class IE circuits) and our treatment of associated circuits, the Cook Plant design provides adequate protection of safe shutdown capability. For any areas of the plant which were determined to be susceptible to a fire exposure from transient fire loads automatic fire detection and automatic sprinkler systems are provided. These fire protection systems were installed in the Cook Plant in accordance with Table 1 of the SER and these systems are included in our fire protection Technical Specifications. As such the Cook Plant design provides adequate protection of safe shutdown capability and supports the conclusion that a fire occurring in any area of the Cook Plant should-not prevent either Unit from being brought to a controlled safe shutdown. Further!.ore, special attention was given to the design of the local shutdown system'so that either Unit could be brought to and maintained in a cold shutdown condition for the case of a fire in the cable spreading room rendering circuits in the main con-trol room and hot shutdown panel inoperable. No further actions need to be taken with regard to Section III.G of Appendix R for the'Cook Plant.

Emergency lighting units with an eight (8) hour battery pack are prov,ided in all areas of the plant needed for operation of safe shutdown equipment and in 'access and egress routes thereto. This requirement has already been implemented in accordance with'our September 30, 1977 response to fire protection questions Nos. 1 and 40 on the schedule pursuant to item No. 22 contained in Table 1 of the HRC fire protection SER. No urther actions are necessarv with regard to Section III.J of Appendix R for the Cook Plant.

Section I! I.O "Oil Collection S stem for Reactor Coolant Pum The Reactor Coolant Pump (RCP) oil spillage. control and prote tion system has already been installed on each RCP in both Units of the. Cook Plant in accordance. with our August 19, .1977 response'o fire protection question No. 51 as supplemented by our flovember 22, 1977 letter which, in part, provided additional information with regard to queStion No. 51 subsequent to our November 3-4; 1977 meeting with the NRC Staff.

'his system was installed in accordance with item No. 19A of Table 1 of the NRC Fire Protection SER. This system fully. meets the requirements of Section III.O of Appendix R and no further action is required for Cook Plant.

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Docket Nos.: 50-315 50-316 MEMORANDUM FOR: Thomas Novak, Assistant Director for Operating Reactors Division of Licensing FROM: William V. Johnston, Assistant Director for Materials qualifications Engineering Imi Division of Engineering'UBJECT:

FIRE PROTECTION STATUS - D.C. COOK UNITS 1 Imi 2 (TACPr47036/47037)

Facility: Donald C. Cook Nuclear Plant Unit Nos. 1 E 2 Licensee: Indiana 5 Michigan Electric Company Docket Nos: 50-315/316 Responsible Branch: ORB g1.

Project Manager: Sydney Miner Reviewing Branch: Chemical Engineering Branch

. Reviewer: R. Anand Status: Complete On February 17, 1981, the fire protection .ru,le for operating nuclear power plants, 10 CFR 50.48 and Appendix R to'10 CFR Part 50 became effective. By letter dated March 27, 1981, the licensee stated that D.C. Cook Plant Units 1 and 2 meet the requirements of sections III.G, III.J and III.O of .Appendix R. to 10 GFR Part 50. Therefore', no technical exemptions were requested nor were any modifications proposed to meet the requirement of III.G-3 which

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spec'ifies alternative or dedicated shutdown capability if other requirements of III.G are not met. Therefore, DSI/ASB. does not have this plant under review.,

The CMEB review of the fire protection program is complete.

(~William V..Johnston, ~assis ant Director for Materials & qualifications Engineering Division of Engineering cc: R. Vollmer R. Ferguson D, Eisenhut S. Varga R. Tedesco V. Panciera V. Benaroya S. Minor T. Wambach T. Sullivan

0. Parr R. Anand

1 JAN 0 6 fgeP S p~ 9

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Docket No. 50-316

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LICENSEE: Indiana 8 Michigan Electr fc Company FACILITY: D. C. Cook Nuclear Plant, Unit No. 2

SUMMARY

OF MEETING HELD ON DECEMBER 8, 1981 WITH INDIANA AND MICHIGAN El ECTRIC COMPANY AND AMERICAN ELECTRIC POWER SERVICE CORPORATION TO DISCUSS THE USE OF EXXON NUCLEAR FUEL FOR THE FUEL CYCLE NO. 4 RELOAD OF D. C.

COOk NUCLEAR PLANT UNIT NO. 2 AND A PROPOSED INCREASE IN UNIT NO. 2 POWER ABOl3T lg A meeting was held December 8, 1981 between membqis of Lndfana 8 tlfchfgan Electric Company (licensee), American Electric Power Service Corpora'tdon, Exxon Nuclear and the NRC. The purpose of the meeting was to give the .

licensee the opportunity of (1) discussing with thr NRC staff the information required to justffy a proposed Unft No. 2 power fncrease, and the supporting information to be supplied with regard to the reload of Unit No. 2 with Exxon fuel. The attendees list (Enclosure 1) and copies of the meeting vfewgraphs are attached.

A. Rlloposed Power Increase I'he licensee stated that they will propose to increase the Thermal Power of Unit 2 from 3391 t@t 1982 refuelfng. Subsequently, to 3425 tit following the September conversation the during a telephone licensee stated the the Thermal Power increase will be limited to 4411 I%it (the current maximum for <~, 4 loop Westfnghouse Plants).

The licensee stated the the increase can be accomplished without any hardware changes. We had the following comments:

(1) They probably will have to amend the environmental report.

(2) They should review the new decay heat load to determine whether there will be an impact.

(3) They should review and provide for the record any analysis which references power level.

(4) The current burnup level for fuel handling fs 25,000 IND/Mt. If they expect burnup beyond this ft will have to be addressed.

OFFICE I ~0~0~~~ ~~~~ ~~~~~~ ~~0~~~ I~ ~ ~ ~ ~ ~ i ~~ ~ ~~ ~ ~0 SURNAME/ f

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W (5) If the.f5ssion product inventory, enrichment or burnups are different from those currently used in the analysis of normal radioactive releases or rel,eases due. to accidents or ti;ansients, the impact of this on the Safety Analysis in the FSAR should be provided.

N B. Unit No. 2 Core Reload for Cycle 4 The fuel for the reload will be 17xl7 fuel supplied by Exxon Nuclear.

The current core is loaddd with 17xl7 Westinghouse Fuel. The codes (methodology) and the status of the codes to be used in the analysis to supports the reload are shown,zh Enclosure 2. The outline of the info@nation to be provided is shown,in Enclosure 3. The licensee indicated that in their application they will supply only the large break LOCA analysis, The small break analysis will be provided as part of the THI items.

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~suamar The licensee provided a 6hhedule (Enclosure 4) for submihsion of their license amendment request, the data necessary to support, the request and the NRC approval dates necessary to support the November 19(8 startup schedule following the next Unit 2 reload. He noted that some of the ENC topical reports on Evaluation Models had notiabeen bubmitted for NRC review.

The schedule for their submittals allows only two,to four months for their approval by the NRC. lie indicated that with the current scheduled NRC workload this is a very tight schedule for approval of topicals required to support a Safety Evaluation to be .completed in time for Unit No. -2 startup.

Sydner Miner, Progect Manager Operating Reactors Branch ¹1 Division of Licensing

Enclosures:

As stated cc w/enclosures:

See next page OFFICE/ ORB ¹1: QP ORB 1:Di SURNAME/ SMin~@FP DATE 5 ..ou.<I.W...... ..IS.Z....

NRC FORM 318 OO-80) NRCM 0240 OFFICIAL R ECOR D COPY USQPO: 1981~960

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MEETING

SUMMARY

OPERATING REACTORS BRANCH NO.'1 DIVISION OF LICENSING DI STRI BUT I ON Doc ket Fi 1 e NRC PDR Local PDR ORB No. 1 Rdg File J. Olshinski J. Heltemes, AEOD B." Grimes (Emergency Preparedness)

S. Varga Project Manager OELD OIaE (3)

C. Parrish ACRS (10)

NRC Participant NSIC TERA cc: Licensee with short cc list

Mr. John Dolan Indiana and Michigan Electric Company cc: Nr. Robert W. Jurgensen Chief Nuclear Engineer American Electric Power Service Corporation 2 Broadway Hew York, New York < 10004 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.

Washington, D. C. 20036 Maude Preston Palenske Memorial Library 500 Market Street St. Joseph, Michigan 49085 Mr. D. Shaller, Plant Manager Donald C. Cook Nuclear Plant P. 0. Box 458 Bridgman, Michigan 49106 U. S. Nuclear Regulatory Commission Resident Inspectors Office 770 Red Arrow Highway Stevensville, Michigan 49127 William J . Scanlon, Esquire 2034 Pauline Boulevard Ann Arbor, Michigan 48103 The Honorable Tom Corcoran United States House of Representatives Washington, D. C. 20515

ENCLOSURE 1 AEP REETlNG .

D. C. COOK UNI'T 1 & 2 DECEMBER 8, 1981 Sydney Miner NRR/DL Tim Mo NRR/RAB Nick Fioravante NRR/DSI/ASB H. J. Richings NRR/DS I/CPB J. A. Mitchell NRR/ DSI/AEB Michele M. DeWitt Westinghouse R. H. McFetridge lfestingfiouse W. Pasedag NRC/AEB Howard L. Sobel AEP - Nuclear Engineering Juan I. Castresana AEP - Nuclear Engineering Jude G. DelPercio AEPSC - Nuclear Engineering John J. Weiss AEPSC - Nuclear Engineering Gerald Owsley Exxon Nuclear J. N. Morgan Exxon Nuclear H. E. Williamson Exxon Nuclear Lambros Lois NRC/CPB Norm Lanbey NRC/RSB

ENCLOSURE 2 D. C. COOK UNIT 2 CYCLE 0 RELOAD AND STRETCH POWER LICENSING METHODOLOGY L ICENSING STATUS

. NEUTRON I CS ANALYSIS METHODS APPROVED POWER DISTRIBUTION CONTROL BASIC APPROVED'PTION UNDER REVIEW

. THERMAL HYDRAULICS THERMAL HYDRAULI C COND IT IONS APPROVED DNBR CORRELATION BEING REVISED PRESSURE DROP TESTING RESULTS INCORPORATED ROD BOW EFFECT UNDER REVIEW

. MECHANICAL DESIGN DESIGN CRITERIA R BASIC DESIGN APPROVED FOR SPECIFIC PREVIOUS APPLICATIONS DESIGN ANALYSIS RODEX2 UNDER REVIEW

LOSURE 2 (cont'd) 2 NETHODOLOGY (CONT.) LICENSING STATUS

. PLANT TRANSIENTS PTS/PMR2 APPROVED FOR SPECIFIC PREVIOUS APPLICATIONS

. ROD EJECTION ACCIDENT XTRAN APPROVED GENERIC ANALYSIS APPROVED FOR SPECIFIC PREVIOUS APPLICATIONS

. ECCS RELAP4-EN APPROVED REFLEX. TOODEE2 BEING REVISED RODEX2 UNDER REVI EN

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1 pC f ENCLOSURE 3 P

RELOAD APPLICATION FOR D. C. COOK UNIT 2 AT 3025 MNT ITEM MECHANICAL DESIGN ENC TOPICAL REPORT REFERENCED (TOPICAL REPORT TO BE SUBMITTED)

THERMAL-HYDRAULIC DESIGN NEUTRONIC/CYCLE DESIGN PLANT TRANSIENT ANALYSIS 'SEPARATE REPORT LIMITING TRANSIENTS WILL BE IDENTIFIED. ABOUT 7 WILL NEED TO BE ANALYZED.

ECCS ANALYSIS LARGE BREAK SEPARATE REPORT SMALL BREAK REFERENCE FSAR ROD EJECTION REFERENCE ENC TOPICAL REPORT TECHNICAL SPECIFICATION CHANGES P

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C LICENSING SCHEDULE ACTION ITEM DATE ORGANIZATION TOPICAL REPORT - FUEL ROD THERMA -MECHANICAL RESPONSE FVALUATiON,NODEL 8/81 ENC TOPICAL REPORT JUST IF I CAT I.ON FOR INCREASED FUEL EXPOSURE (RESPONSE To NRC LETTER To ENC DATED, 8/17/81) 1/82 ENC TOPICAL REPORT MODIFIED ECCS EVALUATION MODEL (ENC INITIATED ACTION To MODIFY ITS ECCS EVALUATION MODEL IN MID-1981: ENC LETTER TO NRC DATED 9/21/81) 1/82 ENC PRIATEE TOPICAL REPORT MODIFIED DNBR CORREI ATION FOR PMR'S WHICH INCORPORATES 17X17 FUEL AND APPRO-METHODOLOGY FOR APPLYING THE MODEL 2/82 ENC I

TOPICAL REPORT MECHANICAL DESCRIPTION OF 17X17 FUEL DESIGN 3/82 ENC APPLICATION FOR D C COOK UNIT NO. 2 OPERATION WITH ENC FUEL AT A REACTOR THERMAL POWER LEVEL OF 3425 MMT Q/82 IMECo APPROVAL OF MODIFIED ECCS EVALUATION MODEL 4/82 NRC APPROVAL OF RODEX2 FUEI PERFORMANCE CODE 6/82 APPROVAL OF DNBR CORRELATION 6/82 NRC FUEL POOL LIMIT 3/82

'APPROVAL OF D. C. COOK UNIT 2 APPLICATION 10/82 NRC D C, COOK UNIT 2 STARTUP CYCLE 11/82 IMECo

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