ML17331A955
| ML17331A955 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/25/1993 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:1100B, NUDOCS 9309010109 | |
| Download: ML17331A955 (6) | |
Text
accKcaa~mmoocUMKm OrSrm nOr svsrzM REGULAT~ INFORMATION DISTRIBUTIO STEM (RIDS)
ACCESSION NBR:9309010109 DOC.DATE: 93/08/25 NOTARIZED:
NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315
,DO-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
RECIP.NAME RECIPIENT AFFILIATION MURLEYPT.E.
Office of Nuclear Reactor Regulation, Director (Post 870411
SUBJECT:
Submits schedule commitments for modifying discrepant piping as result of plant large bore piping reconstitution program analyses.
DISTRIBUTION CODE:
AOOZD COPIES RECEIVED-LTRj ENCL 0 SIZE:
TITLE: OR Submittal:
General Distribution D
NOTES:
RECIPIENT ID CODE/NAME PD3-1 LA DEANPW COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD3-1 PD COPIES LTTR ENCL INTERNAL: NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT OGC/HDS2 EXTERNAL: NRC PDR NRR/DORS/OTSB NRR/DRPW NRR/DSSA/SRXB Cy'EFDCB EG FILB 01 NSIC NOTE TO ALL"RIDS" RECIPIENTS:
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TOTAL NUMBER OF COPIES REQUIRED:
LTTR 16 ENCL
II
)
).
Indiana Micblgan Power Company P.O. Box 16631 Columbus, OM 43216 R
AEP:NRC:1100B Donald C. Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 LARGE BORE PIPING RECONSTITUTION PROGRAM (LBPRP)
SCHEDULE U. S. Nuclear Regulatory Commi.ssi.on Document Control Desk Washington, D.C.
20555 ATTN:
T. E. Murley August 25, 1993
Dear Dr. Murley:
The purpose of this letter is to amend schedule commitments for modifying discrepant piping and/or pipe supports as a result of the Donald C.
Cook Nuclear Plant (DCCNP)
Large Bore Piping Reconstitution Program (LBPRP) analyses.
In submittal AEP:NRC:1100A, and subsequent conversations with NRC staff, we committed to complete the program by
- 1996, over four refueling outages for each unit, and to fix the discrepant supports identified in the analyses.
We were to make reasonable efforts at scheduling
- repairs, and we were to notify Region III when modifications could not be completed prior to unit startup.
A six-month planning window prior to unit refueling outage is now being introduced to permit proper planning and resource allocation, and we now propose not to noti.fy the region of modifications deferred until the next outage.
LBPRP BACKGROUND A 1989-1990 study of a representative sample of safety-related piping systems at DCCNP confirmed that the piping systems meet operability criteria.
The conclusi.ons of this study stated that the piping systems at DCCNP are safe to operate in their current condition.
This conclusion matched the findings from the evaluation of numerous piping and pipe support related discrepancies identi.fied through the condition report mechanism.
This informati.on was presented at a conference which took place at the NRC Region III office on June 7, 1990.
The reanalysis of safety-related piping and pipe supports in the DCCNP Units 1 and 2 is being performed under the LBPRP.
The LBPRP was committed to in 1990 as a proactive step by AEP/IMPCo to identify and correct piping and pipe support design basis discrepancies, and to establish design basis documentation.
The LBPRP analytical work wi.ll run through 1996 and the resulting modifications are to be implemented in a planned and timely manner, in accordance with the commitments of AEP!NRC:1100A.
These commitments included inspection, comparison to interim acceptance
- criteria, and operability and reportabili.ty determination for situati.ons where as-found piping supports were found not to meet the original FSAR design requirements.
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Dr. T. E. Murley AEP!NRC:1100B As of June 30,
- 1993, we have completed 65 LBPRP piping analyses involving 1317 of the 6002 safety-related large bore pipe supports at DCCNP.
The LBPRP modifications to date have involved pipe supports almost exclusively, with the exception of the occasional reinforcement of small bore branch line connections.
No piping segment which required breach of the pressure boundary had to be modified.
The expectation is that this will continue through the remainder of LBPRP.
LBPRP PIPE SUPPORT MODIFICATIONS AND REFUELING OUTAGES The LBPRP analytical effort currently overlaps several scheduled unit refueling outages.
The analysis of the safety-related piping systems will be continuous, and the results of the analysis may identify piping and/or pipe supports which willrequire modification to meet design basis limits.
The implementation of the modifications will require four refueling outages for each unit.
The outages for Unit 1 are
- UlR92, U1R94, U1R95 and U1R97.
The outages for Unit 2 are U2R92, U2R94, U2R96 and U2R97.
The implementation (before unit restart) of piping and/or pipe support modifications identified through the LBPRP analytical effort immediately before or during the
- U1R94, U2R94, U1R95 and U2R96 refueling outages creates difficulties with the planning and execution of the outages and increases the risks associated with the implementation of the modifications.
In
- addition, the implementation of other short lead time pipe support modifications resulting from in service inspection work and other inspection and verification activities competes for resources and compounds the difficultyof outage planning and scheduling.
LBPRP PIPE SUPPORT MODIFICATION PLANNING WINDOW To overcome these difficulties it has become necessary to formally establish a planning window (prior to the
- U1R94, U2R94, U1R95 and U2R96 refueling outages) for identification of LBPRP piping and/or pipe support modifications.
This planning window will provide the necessary processing time for developing the design drawings of the modifications and for proper planning, scheduling and execution of the modifications.
Modifications identified prior to the cut off date will be implemented before unit start-up following the next applicable refueling outage.
Modifications identified after the cut off date will be implemented before start-up following the subsecyxent refueling outage.
The balance of the modifications will be implemented during the U1R97 and U2R97 refueling outages.
The planning window required for the identification of LBPRP piping and/or pipe support modifications prior to the U1R94,
- U2R94, U1R95 and U2R96 refueling outages is set at six months prior to the planned start of each refueling outage.
The cut off dates for the two 1994 refueling outages will be August 1993 and February 1994 for Unit 1 and 2, respectively.
The six-month lead time will support the proper development of the outage schedules, the accurate identification and deployment of resources, the timely procurement of materials and the comprehensive ALARA review and planning.
Dr. T. E. Murley AEP!NRC:1100B In the unlikely event that the LBPRP analyses identify discrepancies that affect operability, the necessary modifications will be implemented immediately and appropriate reporting recpxirements will be executed.
We believe that the introduction of a six-month planning window for implementing piping and/or pipe support modifications resulting from the LBPRP analysis effort will provide for successful refueling
- outages, and safe and economical implementation of the modifications.
This approach was discussed with J.
- Gavula, Region IZI and B. A. Wetzel of NRR on August 2,
- 1993, and they indicated their agreement.
We intend to implement this approach unless we receive further correspondence on this issue from the NRC.
Sincerely, ZF E. E. Fitz trick Vice President dr cc:
A. A. Blind G. Charnoff J.
B. Martin Region ZZZ NFEM Section Chief NRC Resident Inspector Bridgman J.
R. Padgett