ML17331B292
| ML17331B292 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/09/1994 |
| From: | Fitzpatrick E Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co) |
| To: | Murley T NRC/IRM |
| Shared Package | |
| ML17331B294 | List: |
| References | |
| AEP:NRC:1204, NUDOCS 9403160174 | |
| Download: ML17331B292 (26) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9403160174 DOC.DATE: 94/03/09 NOTARIZED-YES DOCKET FACIL:50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E..
Document Control Branch (Document Control Desk)
SUBJECT:
Application for amend to license DPR-74,revising TS surveillance interval for Type B
& C leak rate testing two-yr interval exemption from 10CFR50,App J.
DISTRIBUTION CODE: A017D COPIES RECEIVED:LTR ENCL SIZE TITLE: OR Submittal:
Append J Containment Leak Rate Testing NOTES:
D RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: OC~PBS~
EG 01
/DSIR/SAIB EXTERNAL: NRC PDR COPIES LTTR ENCL 1
1 1
0 1
1 1
1 1
1 RECIPIENT ID CODE/NAME HICKMAN,J OGC/HDS2 RES/DE/SEB NSIC COPIES LTTR ENCL 2
2 1
1 1
1 1
1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
A D
D PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 10 ENCL 9
i l
~
~
A
indiana Michigan Power Company P.O. Box 16631 Cotumbus, OH 43216 8
AEP: NRC: 1204 Donald C.
Cook Nuclear Plant Unit 2 Docket No. 50-316 License No.
DPR-74 UNIT 2
CYCLE 9
TECHNICAL SPECIFICATION SURVEILLANCE INTERVAL EXTENSION FOR TYPE B AND C LEAK RATE TESTING, AND TWO-YEAR INTERVAL EXEMPTION FROM 10 CFR 50, APPENDIX J U.
S. Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
T.
E. Murley March 9, 1 994
Dear Dr. Murley:
This letter cons titutes an application for amendment to the Technical Specifications (T/Ss) for Donald C.
Cook Nuclear Plant Unit 2.
Pursuant to 10 CFR 50. 12, this letter also requests a one-time exemption from 10 CFR 50, Appendix J, Sections III. D. 2 (a) and III. D. 3.
Specifically, the requests are to extend the surveillance interval for Type B and C leak rate testing which are required to be performed prior to May 29, 1994.
We are requesting relief from these requirements until the Unit 2 refueling outage, which is currently scheduled to begin August 6, 1994.
A description of the proposed T/S change, our analysis concerning significant hazards considerations, and our justification for the 10 CFR 50, Appendix J exemption are contained in Attachment 1.
The existing T/S
- page, marked to reflect the proposed
- change, is contained in Attachment 2.
The proposed, revised T/S page is contained in Attachment 3.
Unit 2 Cycle 9 is being lengthened approximately five months by operating at reduced power for much of the cycle.
The purpose of extending this cycle is to provide separation between the Unit 1 refueling outage (scheduled to complete late April, 1994) and the Unit 2 refueling outage (scheduled to commence mid-August, 1994).
In accordance with 10 CFR 50. 92 (c), our evaluation of the change indicates no significant hazards because the change does not
( 1 )
involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in the margin of safety.
QN 0403140174 940309 PDR
,. ', PDR, jADOCK 03000314 oi'P
Dr. T. E. Murley 2
AEP: NRC: 1204 In accordance with 10 CFR 50.12, the exemption is justifiable since (1) it will not present an undue risk to the public health and
- safety, (2) the underlying purpose of the rule will be served, (3) compliance would result in undue hardships and cost in terms of radiological exposure and lost revenues, and (4) it is temporary and the surveillance willbe performed during the refueling outage.
The Nuclear Regulatory Commission has granted similar requests to Connecticut Yankee Atomic Power Company and Tennessee Valley Authority.
These proposed changes have been reviewed and approved by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee.
In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.
This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached.
Sincerely, E.
E. Fitzpatrick Vice President dr Attachments CC:
A. A. Blind G. Charnoff J.
B. Martin - Region III NFEM Section Chief NRC Resident Inspector J.
R. Padgett
STATE OF OHIO)
COUNTY OF FRANKLIN)
E.
E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power
- Company, that he has read the forgoing UNIT 2
CYCLE 9
TECHNICAL SPECIFICATION SURVEILLANCE INTERVAL EXTENSION FOR TYPE B
AND C
LEAK RATE TESTING AND TWO-YEAR INTERVAL EXEMPTION FROM 10 CFR 50, APPENDIX J proposed in Letter AEP:NRC:1204 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to before me this ~~
day of 19~.
z0 NOTARY P BLIC
-" RITA D. HILL TIOTAIIYPUBLIC. STATE OF OHIO
ATTACHMENT 1 TO AEP:NRC:1204 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C.
COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATIONS AND 10 CFR 50.12 JUSTIFICATION FOR EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50, APPENDIX J, SECTIONS III.D.2(a) AND III.D.3
Attachment 1 to AEP:NRC:1204 Page 1 of 14 I.
DESCRIPTION OF THE CHANGES We propose a one-time modification to T/S 4.6.1.2.d (Type B and C leak rate test frequency) for Cook Nuclear Plant Unit 2 to avoid an unnecessary shut down for the sole purpose of performing this surveillance.
The surveillance will be completed during the refueling outage, which is scheduled to begin approximately two months after T/S 4.6.1.2.d is next due.
T/S 4.6.1.2.d currently states the following:
Type B and C tests shall be conducted at P~, 12.0 psig, at intervals no greater than 24 months except for tests involving air locks.
We are proposing to modify this surveillance requirement with a footnote that reads as follows:
One-time exemption to 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3 allows the provisions of Technical Specification 4.0.8 to be applicable.
T/S 4.0.8 was added in Amendment 158 to allow for extending the due dates of
~ certain surveillance requirements until the scheduled refueling outage.
Since the 24-month interval of T/S 4.6.1.2.d is based on the requirements of 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3, a schedular exemption from these requirements is also being sought.
This exemption request is to provide temporary relief (one-time) of the two-year test interval associated with the Type B and C leak rate tests.
The proposed T/S change and 10 CFR 50, Appendix J exemption request apply to all Type B and C components.
II.
REASONS FOR THE PROPOSED T
S CHANGE AND APPENDIX J EXEMPTION RE VEST T/S 4.6.1.2.d is due May 29, 1994, which is approximately two months prior to the refueling outage scheduled to begin August 6, 1994.
We are requesting the one-time extension to allow us to avoid a shut down solely to perform Type B and C
leak rate tests.
The extension would allow continued operation of Unit 2 through the end of the cycle.
The surveillance would then be completed during the refueling outage.
The 24-month surveillance due date is going to be reached during the operation of Cycle 9 because of two factors.
After completing the Cycle 8 outage, major obstacles were encountered with the Unit 2 turbine-generator.
Unit 2
was essentially out of service for six months while repairs were being made to the turbine-generator.
Also, since Unit 1 completed a refueling outage during this six-month period, simultaneous'efueling outages for both units were inevitable.
It was determined to operate Unit 2 at reduced capacity (~70K) for approximately a year to allow for adequate separation of the outages.
Attachment 1 to AEP:NRC:1204 Page 2 of 14 III.
JUSTIFICATION AND EVALUATION The intent of the, two-year interval specified in Appendix J is to impose a
testing frequency which is often enough to prevent significant deterioration of containment integrity and long enough to allow Type B and C leak rate tests to be performed during plant outages.
The leak rate tests are performed during refueling outages to reduce the radiation exposure to plant personnel.
Performance of the tests during a mid-cycle shut down, with the sole purpose of satisfying the two-year surveillance requirement, would result in at least doubling the radiation exposure to plant personnel.
This is because the tests would have to be performed again during the refueling outage.
We believe the cost of the increased radiological exposure to plant personnel is greater 'han the benefit of performing a
mid-cycle surveillance to gain marginally increased assurance that the components will perform as designed for the remainder of the cycle.
The function and/or location of most Type B and C components prohibits them from being tested while at power.
- Thus, to perform the tests, we would perform a reactor shut down and cool to Mode 5.
The cooldown is necessary, and required by procedure, to avoid challenging T/S 3.6.1.1 (Containment Integrity) and its one-hour limiting condition for operation.
The time required to perform the tests during a mid-cycle outage is estimated to be five to six weeks.
Since the testing would be performed with fuel in the vessel, additional challenges other than increased radiation exposure would be encountered as follows:
o draining of several emergency core cooling system pathways which impacts management of shut down risks, o
significant expenditure of personnel resources to review and
- rewrite, where necessary, steps of the test procedure to allow testing in an abnormal configuration (fuel in the vessel),
and o
adding an additional plant cooldown and heatup, which increases the probability of undesirable events that are more likely to occur during such transients.
A review of past Type B and C surveillance results and an evaluation of the data showed that there is no reason to believe Cook Nuclear Plant Unit 2 should experience serious degradation of the components during the cycle.
Table 1 lists the final results of the past three Type B and C surveillances.
Examination of the "As Found" results reveals that we have significantly improved in reducing the leak rates.
The 1992 "As Found" leak rate increased only 0.01 L, from the 1990 "As Left" leak rate, which is excellent and shows a significant improvement in our results as compared to previous cycles.
Our improving trend of reduced "As Found" leak rates over the past three surveillances provides us confidence in anticipating that the 1994 "As Found" leak rate will be well below the Appendix J leak rate (Type B and C) acceptance criteria of 0.6 L~.
Attachment 1 to AEP:NRC:1204 page 3 of 14 III.
JUSTIFICAT ON AND EVALUATION (continued)
Table 2 lists the 1990 "As Left," the 1992 "As Found,"
and the 1992 "As Left" surveillance data for each Type B and C volume.
Table 3 shows the corrective actions taken for the Type C valves that were found with excessive leakage in 1992 (all Type B components were found with acceptable limits).
As can be seen in Table 3, strainers were installed in the drains for the upper and lower containment ventilation units'rain header (DCR-620 and DCR-621) to reduce the amount of foreign material entering into the valves.
This corrective action was taken because our Type B and C trending program identified this drain header as having excessive leakage in the previous surveillance.
This is the only component to have a repetitive failure over the past three surveillances.
- Thus, we believe that our corrective actions towards components with excessive leakage have been appropriate.
Cook Nuclear Plant Unit 2
has proven to have a very tight containment as demonstrated by the excellent results of our integrated leak rate tests (ILRTs).
The results of previous ILRTs are shown below and compare very favorably to the acceptance criteria of 0.1875 weight percent per day.
Year 1992 1989 1984 1981 1977 Leakage wt da 0.0378 0.0743 0.0387 0.0575 0.0043 To conclude, our significant improvement in Type B and C leak rate test results, anticipated low leak rate for the next surveillance, aggressive corrective actions taken, and excellent ILRT results indicate there is no reason to believe that delaying the Type B and C leak rate tests approximately two months will cause serious deterioration to these components.
Attachment 1 to AEP:NRC:1204 Page 4 of 14 IV.
10 CFR 50.92 CRITERIA As stated in 10 CFR 50.92(c),
a proposed change does not involve a significant hazards consideration if the change does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) the change does not create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) the change does not involve a
significant reduction in a margin of safety.
Criterion 1
The limiting conditions for operation involving containment integrity are not altered by this proposed change.
The surveillance requirement concerning the Type B and C leak rate test is slightly relaxed by the proposed change.
The function of the components affected by this surveillance are to ensure containment integrity.
Delaying the surveillance approximately two months would not change the probability of an accident.
Our significant improvement in Type B
and C
leak rate test
- results, low anticipated leak rate for the next surveillance, aggressive corrective actions
- taken, and excellent ILRT results indicate there is no reason to believe that delaying the Type B and C leak rate tests approximately two months will cause serious deterioration to these components.
Furthermore, similar requests by utilities to extend the surveillance beyond two years have already been found acceptable by the NRC.
Therefore, it is concluded that the proposed amendment does not involve a
significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2
No changes to the limiting conditions for operation for containment integrity are proposed as part of this amendment request.
The proposed change does not involve any physical changes to the plant or any changes to plant operations.
Thus, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3
The intent of the Type B
and C leak rate surveillance is to ensure that containment integrity does not significantly deteriorate.
This is established by measuring a total leak rate of less than 0.60 L,.
Our significant improvement in Type B and C leak rate test results, aggressive corrective actions taken, and excellent ILRT results indicate there is no reason to believe that delaying the Type B
and C leak rate tests approximately two months will cause serious deterioration to these components.
The "As Found" trend of the leak rates over the past three surveillances indicate that the leak rate for the next surveillance will be below the Appendix J
leak rate acceptance criteria.
Therefore, it is concluded that the proposed amendment does not involve a
reduction in a margin of safety.
Attachment 1 to AEP:NRC:1204 Page 5 of 14 V.
10 CFR 50 12 CRITERIA Exemption from the requirements of 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3 is justified in accordance with 10 CFR 50.12, "Specific exemptions,"
Sections (a)(1), (a)(2)(ii), (a)(2)(iii), and (a)(2)(v) as follows.
(a)(l) The exemption ".
. will not present an undue risk to the public health and safety The significant hazards consideration, per 10 CFR 50.92(c),
performed above provides justification that there will not be undue risk to the public health and safety.
As stated
- above, our significant improvement in Type B and C test results, expected low leak rate for '994, aggressive corrective actions
- taken, and excellent ILRT results provide assurance that serious deterioration of containment integrity willnot occur during the extension period.
(a)(2)(ii) "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
The underlying purpose of Appendix J is to ensure that serious deterioration of containment integrity will not occur.
Our examination of past Type B and C leak rate tests indicates that the anticipated 1994 total leak rate of the Type B and C components will be less than the Appendix J
acceptance criteria.
Since the extension of the interval is only slightly greater than two months and we anticipate an acceptable leak
- rate, we believe that completing the surveillance within the two-year surveillance interval is not necessary to achieve the underlying purpose of the rule.
(a)(2)(iii) "Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated."
When the regulation was adopted in 1973, it was not the intent of the two-year surveillance interval to force a shut down solely to perform Type B and C leak rate testing. If required to perform mid-cycle Type B and C leak rate testing, there would be undue hardships in the terms of increased radiological
- exposure, costs for replacement
- energy, and the additional cost of performing the test twice during 1994.
Attachment 1 to AEP:NRC:1204 Page 6 of 14 V.
10 CFR 50.12 CRITERIA (continued)
(a)(2)(v) "The exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation.'l The exemption is only being requested to delay, for approximately two months, this cycle's Type B and C leak rate tests until the scheduled refueling outage.
The exemption request is necessary because of the combined effects of the following:
(1) a six-month delay of normal power operation due to turbine-generator problems at the beginning of the cycle, and (2) extending the cycle five months by operating at reduced power to provide separation between the Unit 1 and Unit 2 refueling outages.
There have not been any forced outages of significant duration this cycle which would have allowed for completion of Type B and C leak rate tests.
Attachment 1 to AEP:NRC:1204 Page 7 of 14 Table 1
- 1989, 1990 and 1992 Type B and C Total Leak Rate Results As Found 1989 As Left 1990 As As Found Left 1992 As As Found Left Leak Rate Margin 3.00
-400X 0.076 0.74 0.17 87X
-24X 72X 0.18 70X 0.17 72X Note: In the above table, the leak rate is expressed in terms of L~,
and the margin is the percent difference between the limit (0.6 L~) and the measured total leak rate.
Attachment 1 to AEP:NRC:1204 Page 8 of 14 Table 2 1990 and 1992 Type B Leak Rate Data (sccm~)
Test Pen.
Step No.'escription 1990 As Left 1992 1992 As Found As Loft 1
X-1A 2
X-1B 3
X-2 612 Airlock 650 Airlock Zone 3 Penotrations 4,617.3 4,808.7 0.0 5,511.0 550.0 20.0 1,759.9 1,951.8 20.0 4
X-4 Zone 4 Ponotrations 89.7 20.0 20.0 5
X-6 7
X-7A Fuel Transfer Blind Flange Ice Loading Blind Range (CPN-80) 0.0 0.0 0.0 0.0 0.0 0.0 8
X-7B Ice Loading Blind Range (CPN-57) 0.0 0.0 0.0 9
X-7C Flux Thimble Handling 0.0 20.1 0.0 10 X-7D Spare Ponotration (CPN-67) 11 X-9A 650'quipment Hatch Ring Body Flange Seal 12 X-9B 650'irlock Eqpmnt Hatch Cover Flange Seal 13 X-35A Soniico Penetration (CPN-71) 19.9 0.0 0.0 N/AO 0.0 0.0 825.0 20.0 0.0 0.0 0.0 0.0 Total 9,445.9 6,966.0 3,751.7 t
Pen. No.
m Containment Penetration Number (CPN) t sccm ~ Standard (pressure and temperature)
Cubic Centimeters O
Penetration new to test in 1992.
Attachment 1 to AEP:NRC:1204 Page 9 of 14 Table 2 (continued) 1990 and 1992 Type C Leak Rate Data (sccm~)
Test Pen.
Step No.'escription 1990 1992 As Left As Found 1992 As Left 1
CPN-17 CPN-21 CLV ¹1 (WCR-SOO, WCR-902) 64.7 20.1 0.0 2
CPN-17 CPN-21 3
CPN-20 CPN-24 CLV ¹1 (WCR-901, WCR-903)
CLV ¹4 (WCR-912, WCR-914) 0.0 0.0 0.0 0.0 0.0 0.0 4
CPN-20 CLV ¹4 (WCR-913, WCR-915) 5 CPN-26 CUV ¹1 (WCR-920, WCR-922) 6 CPN-26 CUV ¹1 (WCR.921, WCR-923) 7 CPN-84 CUV ¹4 {WCR-932, WCR-934) 8 CPN-84 CUV ¹4 (WCR.933, WCR-935) 9 CPN-26 RCP ¹1 Motor Cooler (WCR-941, WCR-945) 10 CPN-26 RCP ¹1 Motor Cooler {WCR-95'I, WCR-955) 11 CPN-84 RCP ¹4 Motor Cooler (WCR-944, WCR-948) 12 CPN-84 RCP ¹4 Motor Cooler {WCR-954, WCR-958) 0.0 0.0 24.7 0.0 19.9 20.0 0.0 20.1 0.0 20.2 60.5 0.0 1 20.8 0.0 0.0 0.0 0.0 0.0 20.2 60.5 0.0 0.0 70.6 0.0 0.0 0.0 0.0 13 CPN-18 CPN-22 14 'PN-18 CPN-22 15 CPN-19 CPN-23 16 CPN-19 CPN-23 CUV ¹2 (WCR-904, WCR-9061 CUV ¹2 (WCR.905, WCR-907)
CUV ¹3 (WCR-908, WCR-910)
CUV ¹3 (WCR-909, WCR-911) 0.0 256.4 20.0 0.0 421.9 0.0 0.0 0.0 353.3 0.0 0.0 0.0 17 CPN-27 CUV ¹2 (WCR-924, WCR-926) 18 CPN-27 CUV ¹2 {WCR-925, WCR-927) 19 CPN-S5 CUY ¹3 {WCR 928, WCR-930) 20 CPN-85 CUY ¹3 (WCR-929, WCR-931) 21 CPN-27 RCP ¹2 Motor Cooler (WCR-942, WCR-946) 22 CPN-27 RCP ¹2 Motor Cooler (WCR-952, WCR-956) 23 CPN-85 RCP ¹3 Motor Cooler (WCR-943, WCR-947) 24 CPN-85 RCP ¹3 Motor Cooler (WCR-953, WCR-957) 25 CPN-73 Instrument Room East (WCR-960, WCR.962) 26 CPN-73 Instrument Room East(WCR-961, WCR.963) 27 CPN-73 Instrument Room East (WCR-964, WCR-966) 0.0 0.0 0.0 1 29.4 20.0 0.0 0.0 194.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 20.2 0.0 20.2 0.0 20.2 0.0 0.0 0.0 0.0 0.0 0.0 20.2 0.0 20.2 0.0 20.2 0.0 0.0
Attachment 1 to AEP:NRC:1204 Page 10 of 14 Table 2 (continued) 1990 and 1992 Type C Leak Rate Data (sccm~)
Test Pen.
Step No.'escription 1990 1992 As Left As Found 1992 As Loft 28 CPN-73 Instrument Room East (WCR-965, WCR-967) 29 CPN-61 Instr. Rm Supply 612'VCR-101, VCR-201) 30 CPN-62,.
Instr. Rm Exhaust 612'(VCR-102, VCR-202) 31 CPN-64 Lower Supply 633'VCR-103, VCR-203) 32 CPN-63 Lowor Exhaust 633'VCR-104, VCR-204) 33 CPN-59 Cnt Vent Spply 650'VCR-105, VCR-205) 34 CPN-60 Cnt Vent Spply 650'(VCR-106, VCR-206) 35 CPN.65 Press Equalization 650'(VCR-107, VCR-207) 36 CPN-95 H2 Return Une (ECR-10, ECR-20) 37 CPN-95 ESR-1 (ECR-11, ECR-21) 38 CPN-95 ESR-2 (ECR-12, ECR-22) 39 CPN.95 ESR-3 (ECR-13, ECR-23) 40 CPN-93 ESR-4 (ECR-14, ECR.24) 41 CPN-95 ESR-5 (ECR-15, ECR.25) 42 CPN.93 ESR-6 (ECR-16, ECR-26) 43 CPN-93 ESR-7 (ECR-17, ECR-27) 44 CPN-93 ESR-8 (ECR-18, ECR.28) 45 CPN-93 ESR-9 (ECR-19, ECR-29) 46 CPN-11 RCP <<1 Seal HO (CS.442-1) 47 CPN-14 RCP P4 Seal HO (CS-442-4) 48 CPN-12 RCP 42 Seal HO (CS-442-2) 49 CPN-13 RCP 0'3 Seal HO (CS-442-3) 50 CPN-15 Relief Valve Hoador to PRT(SI-189) 51 CPN-70 AirParticulate/Radioactive Gas Monitor (SM-1) 52 CPN-32 N2 to Accumulators (N-102) 53 CPN-74 N2 to PRT (N-275) 54 CPN-33 PW to PRT (PW-275) 55 CPN-35 Charging to Regen HX (CS-321) 56 CPN-30 Dead Weight Calibrator (NPX-151-Vl) 57 CPN-86 Glycol Return (VCR-10, VCR-11) 58 CPN-56 Glycol Return (VCR-20, VCR-21) 0.0 210.0 2,200.0 0.0 493.5 0.0 2,744.8 297.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 222.1 445.8 0.0 59.2 417.3 20.1 300.0 0.0 0.0 0.0 0.0 89.8 0.0 219.8 797.0 70.7 5,290.0 145.5 20.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 202.3 20.2 70.3 100.7 65.0 115.2 0.0 903.4 0.0 27.2 26.1 0.0 65.9 0.0 219.8 5,032.9 65.8 5,290.0 145.5 20.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 202.3 20.2 70.3 100.7 65.0 115.2 0.0 903.4 0.0 27.2 26.1
Attachment 1 to AEP:NRC:1204 Page 11 of 14 Table 2 (continued) 1990 and 1992 Type C Leak Rate Data (sccm~)
Test Pen.
Step No.'escription 1990 1992 As Left As Found 1992 As Left 59 CPN-31 N2 & Vent Head for RCDT (DCR-203, DCR-207) 60 CPN-31 N2 & Vent Head for RCDT (N-160, DCR-201) 61 CPN-31 Ice Condenser AHU Drain HDR (DCR-610, DCR.B'l1) 62 CPN-31 CLV & CUV Drain Header (DCR-620, DCR-621) 63 CPN-40 RCDT Drain Header (DCR-205, DCR-206) 0.0 0.0 0.0 39.7 0.0 209.6 0.0 209.6 0.0 0.0 0.0 0.0 139.2 1,949.9 501.4 64 CPN-41 CNT Sump to HU Tanks (DCR-600, DCR-601) 65 CPN-34 Letdown (QCR-300) 66 CPN-34 Letdown (QCR-301) 67 CPN-37 RCP Seal HO Return (QCM-250, QCM-350) 68 CPN-45 RHR Recirc East (ICM-305) 69 CPN-46 RHR Recirc West(ICM-306) 70 CPN-36 Demin H20 for Rx Cavity Scrub (QCR-919, QCR-920) 71 CPN-36 Refueling H20 to Rx Cavity (SF-152, SF-154) 72 CPN-42 Refueling Cavity Drain (SF-159, SF-160) 73 CPN-66 NSX-101, 103 Hot Leg Samples (NCR-105, NCR-106) 74 CPN-66 NSX-102 P2R Uquid Samples (NCR-107, NCR-108) 75 CPN-66 NSX-103 PZR Steam Samples (NCR-'l09, NCR-110) 76 CPN-81 NSI-52 PRT Sample (RCR-100, RCR-101) 77 CPN-81 DSI-201 RCDT Sample (DCR-202, DCR-201) 78 CPN-81 ISX-1,2,3,4 Accum Samples (ICR-5, ICR-6) 79 CPN-31 AirParticulate/Rad.
Gas Monitor (ECR-33, ECR-35) 80 CPN-43 North Sl Discharge (ICM-260) 81 CPN-68 South Sl Discharge (ICM-265) 82 CPN-32 AirParticulate/Rad.
Gas Monitor (ECR-31, ECR-32) 83 CPN-74 Control Airto Containment (XCR-100) 84 CPN-29 Control Airto Containment (XCR-102) 85 CPN-74 N2 to PRT (GCR-301) 86 CPN-32 N2 to Accumulators (GCR-314) 87 CPN-32 Sl Test Une (Sl-171, SI-172, Sl-194) 88 CPN-33 PW to PRT (NCR-252) 0.0 0.0 19.9 19.9 0.0 0.0 0.0 19.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 59.2 0.0 0.0 79.1 64.4 0.0 20.0 0.0 0.0 0.0 150.7 0.0 0.0 0.0 49.9 19.9 0.0 0.0
'.0 0.0 0.0 0.0 60.1 0.0 0.0 90.3 0.0 0.0 90.3 95.2 70.6 0.0 0.0 0.0 0.0 150.7 0.0 20.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 60.1 0.0 0.0 90.3 0.0 0.0 90.3 95.2 70.6 0.0 0.0 0.0 0.0
Attachment 1 to AEP:NRC:1204
,Page 12 of 14 Table 2 (continuedj 1990 and 1992 Type C Leak Rate Data (sccm~)
Test Pen.
Stop No.'escription 1990 1992 As Left As Found 1992 As Left
'89 CPN-39 CCW to and from RCP Oil Coolers/Thermal Barrier CPN-38 (CCM.452, CCM-454, CCM-458)
CPN-59
'90 CPN-39 CCW to and from RCP Oil Coolers/Thermal Barrier CPN-38 (CCM-451, CCM-453, CCM-459)
CPN.S9
'91 CPN-75 CCW to and from Excess Letdown Heat Exchanger (CCR-460, CCR-462) 92 CPN-82 CCW to and from Rx Supports (CCR-457, CCW-135)
'93 CPN-82 CCW to and from Rx Supports (CCR-455, CCR-456) 94 CPN-89 Grab Sample (SM-4, SM.6) 229.6 449.1 19.9 19.9 0.0 0.0 55.4 45.3 70.8 0.0 0.0 0.0 0.0 0.0 70.8 0.0 0.0 0.0 95 CPN.94 CNT Press. Phase A/B Isolation (PPP-300) 96 CPN-92 CNT Press. Phase A/B Isolation (PPP-301) 97 CPN-91 CNT Pross. Phase A/B Isolation {PPP-302) 98 CPN-96 CNT Press. Phase A/B Isolation(PPP-303) 99 CPN-97 CNT Press. Alarm(PPA-310, PPA-311) 100 CPN.98 CNT Press. Alarm {PPA-312, PPA-313) 101 CPN-44 Boron Injection (ICM-251) 102 CPN-44 Boron Injection (ICM-250) 103 CPN-83 Weld Channel Pressurization {CA-181S) 104 CPN-83 Weld Channel Pressudzation (CA-181N) 105 CPN-89 Grab Sample (SM-8, SM-10)
'106 CPN-25 CCW to CPN Coils 2 &. 5 East (CCW-243-25)
'107 CPN-25 CCW to CPN Coils 2 & 5 East (CCW-244-25)
'108 CPN-72 CCW to CPN Coils 3 & 4 West (CCW-243-72)
'109 CPN-25 CCW to CPN Coils 3 & 4 West (CCW-244-72)
'110 CPN-25 CCW to CEQ-1 (CCM-430)
'111 CPN-25 CCW from CEQ-1 (CCM-431)
"112 CPN-25 CCW from CPN Coils 2 & 5 (CCR-440)
'113 CPN-72 CCW to CEQ.2 {CCM-432)
'114 CPN-72 CCW to CEQ-2 (CCM-433)
'115 CPN-72 CCW from CPN Coils 3 &4 (CCR-441) 116 CPN-86 Glycol Supply Expansion Valve (R-156) 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 163.5 119.3 79.7 0.0 80.8 60.2 19.9 0.0 0.0 79.4
'.0 0.0 84A 45.0 30.4 20.0 807.5 423.2 278.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 20.1 0.0 0.0 0.0 50.2 41.0 70.3 0.0 0.0 0.0 0.0 0.0 50.2 41.0 70.3 0.0 0.0 0.0 59.8 20189.4 443.7
Attachment 1 t:o AEP:NRC:1204 Page 13 of 14 Table 2 (continued) 1990 and 1992 Type C Leak Rate Data (sccm~j Test Pen.
Step No.', Description 1990 1992 As Left As Found 1992 As Loft 117 CPN-56 Glycol Supply Expansion Valve (R-157) 118 CPN-67 Post Accident Sampling Return Chock Valve (NS-357) 89.4 1 60.9 1 60.9 0.0 0.0 0.0 119 CPN-67 Post Accident Sampling Return isolation Valves (ECR-496, ECR-497) 47.6 10.0 10.0 120 CPN-67 Post Accident Sampling Supply Isolation Valve (ECR-416) 121 CPN-67 Post Accident Sampling Supply (ECR-417) 122 CPN-32 Containment Sampling (ECR-535) 123 CPN-32 Containment Sampling (ECR-536) 124 CPN-70 AirParticulate/Rad.
Gas Monitor Return (ECR-36) 125 CPN-29 Plant Airto Containment (PCR-40) 126 CPN-29 Plant Airto Containment Check Valve (PA-342) 127 CPN-95 Hydrogen Sample Return Chock Valve (NS-283) 128 CPN-74 Control Airto Containment (XCR-101) 129 CPN-29 Control Airto Containment (XCR-103) 0.0 0.0 64.9 99.9 59.4 149.6 0.0 0.0 64.4 0.0 0.0 501.9 0.0 60.5 0.0 0.0 80.2 210.4 0.0 0.0 0.0 0.0 0.0 60.5 0.0 0.0 80.2 2'I0.4 0.0 0.0 Total 9,682.5 12,883.1 14,876.7 t
Pen. No. ~ Containment Penetration Number (CPN)
I t sccm m Standard (pressure and temperature)
Cubic Centimeters
'hese valves pertain to the CCMI system and are not required to be included in the total leak rate calculation.
Attachment 1 to AEP:NRCr1204 Page 14 of 14 Table 3
')992 Corrective Action for Type C Valves with Excessive Leakage Description CCW to CPN Coils 2 &. 5 East (CCW-243-25)
As Found As Left Corrective Action 807.5 423.2 Internals cleaned.
CCW to CPN Coils 2 & 5 East (CCW-244-25) 20,189 443.7 Internals cleaned.
Post Accident Sampling 'Supply (ECR-417) 501.9 0.0 Internals cleaned and blue checked.
CLV & CUV Drain Header (DCR-620, DCR-621) 1,951.8 501.9 Internals cleaned.
System lines hydro-lazed and flushed clean.
Strainers installed in CLV &. CUV drains.
ATTACHMENT 2 TO AEP:NRC:1204 EXISTING TECHNICAL SPECIFICATION PAGE MARKED TO REFLECT PROPOSED CHANGES
>T
'$1
~rf~
CONTAINMENT SYSTEMS SURVEILLANC-RE UIREMENTS Continued b.
If any periodic Type A test fails to meet..75 L
< the test schedule for subsequent, Type A tests shall be reviewed and approved by the Commission.
If two consecutive Type A tests fail to meet
.75 L,
a Type A test shall be'performed at least every 18 months until two consecutive Type A tests meet
.75 L, at which time the above test schedule may be resumed.
a'o The accuracy of each Type A test. shall be verified by a supple-mental test which:
1.
Confirms the accuracy of the Type A test by verifying that the difference between supplemental and Type A test data is within 0.25 L,
a'.
'as a duration sufficient to establish accurately the change in leakage between the Type A test and the supplemental test.
3.
Requires the quantity of gas injected into the contain-ment or bled from the containment during the supplemental test to be equivalent to at least 25 percent of the total measured leakage rate at P
, 12.0 psig.
- d. Type B and C tests shall be conducted at P, 12.0 psig> at a'ntervals no greater than 24 months except for tests involving air locks.t e.
Each containment air lock shall be verified to be in compliance with the requirements of Specification 3.6.1.3.
- f. All test leakage rates shall be calculated using observed data converted to absolute values.
Error analyses shall be performed to select a balanced integrated leakage measurement system.
1 go The provisions of Specification 4.0.2 are not applicable.
(() gF'p g~
p[pencl<y + ~~~5 XK v ZCo) Elle(
l6+5 t~ pf QQ~S)(5VL5
@ F 7~~+
5 Q.o ( ~ AC 'L~C; E'+IN~ Lt,O g 4 4z. o-fplicck(e.
COOK NUCLEAR PLANT - UNIT 2 3/4 6-3 AMENDMENT NO
1 C
ATTACHMENT 3 TO AEP:NRC:1204 PROPOSED REVISED TECHNICAL SPECIFICATION PAGE
CONTAINMENT SYSTEMS SURVEILLANCE RE UIREMENTS Continued b.
If any periodic Type A test fails to meet
.75 L the test schedule for subsequent Type A tests shall be reviewed and approved by the Commission.
If two consecutive Type A tests fail to meet
.75 L a Type A test shall be performed at least every 18 months until two consecutive Type A tests meet
.75 L~, at which time the above test schedule may be resumed.
c.
The accuracy of each Type A test shall be verified by a supple-mental test which:
1.
Confirms the accuracy of the Type A test by verifying that the difference between supplemental and Type A test data is within 0.25 L, 2.
3.
Has a duration sufficient to establish accurately the change in leakage between the Type A test and the supplemental test.
Requires the quantity of gas injected into the contain-ment or bled from the containment during the supplemental test to be equivalent to at least 25 percent of the total measured leakage rate at P~, 12.0 psig.
d.
Type B and C tests shall be conducted at P~, 12.0 psig, at intervals no greater than 24 months except for tests involving air locks.f e.
Each containment air lock shall be verified to be in compliance with the requirements of Specification 3.6.1.3.
f.
All test leakage rates shall be calculated using observed data converted to absolute values.
Error analyses shall be periormed to select a balanced integrated leakage measurement system.
g.
The provisions of Specification 4.0.2 are not applicable.
f One-time exemption to 10 CFR 50, Appendix J, Sections III.D.2(a) and III.D.3, which allows the provisions of Technical Specification 4.0.8 to be applicable.
COOK NUCLEAR PLANT - UNIT 2 3/4 6-3 AMENDMENT NO.