ML17332A285
| ML17332A285 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/29/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17332A282 | List: |
| References | |
| NUDOCS 9409070299 | |
| Download: ML17332A285 (5) | |
Text
~
~P,4 4E00 ci
~o II i 0
4y*yW UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
1 1
TO FACILITY OPERATING LICENSE NO. DPR-58 AND AMENDMENT NO.
165 TO FACILITY OPERATING LICENSE NO.
DPR-74 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 September 24, 1992 and supplemented March 2, 1994, 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 remove the containment isolation valve lists from the Technical Specifications.
In addition, the Technical Specification requirements have been modified such that all references to these lists have been removed.
Finally, the Technical Specifications have been modified to state requirements in general terms that include the containment isolation valves that have been removed from the Technical Specifications.
Guidance on the proposed Technical Specification change was provided by NRC Generic Letter 91-08, dated May 1, 1991.
2.0 EVALUATION The licensee has proposed the removal of Table 3.6-1, "Containment Isolation Valves," that is referenced in TS 3/4.6.3.
With the removal of this table, the licensee has proposed to include the following statement of the limiting condition for operation (LCO) under TS 3.6.3. 1:
Each containment isolation valve shall be OPERABLE.
In addition, the licensee has proposed to revise the definition of Containment Integrity in TS 1.8, the action requirements under TS 3.6.3. 1, and the surveillance requirements under TS 4.6. 1. 1 and 4.6.3. 1. 1 through 4.6.3. 1.3 to remove all references to Table 6.3-1.
The definition of Containment Integrity and TS 4.6. 1. 1 refer to TS 3.6.3. 1 for an exception that would now be included in the text of the LCO rather than by the table removed from the Technical Specifications.
With the removal of the reference to Table 6.3-1, the licensee has proposed to state this exception as:
r 9409070299 940829 PDR ADOCK 050003i5 P
PDR I
except for valves that are open under administrative control as permitted by Specification 3.6.3. 1.
The table of containment isolation valves identified specific manually-operated locked or sealed closed valves with a footnote stating that these valves may be opened on an i'ntermittent basis under administrative control.
These valves are locked or sealed closed consistent with the regulatory requirements for manually-operated valves that are used as containment isolation valves.
Because opening these valves would be contrary to the operability requirements of these valves, the following addition to LCO 3.6.3.
1 has been proposed:
...locked or sealed closed valves may be opened on an intermittent basis under administrative control.
The surveillance requirements of TS 4.6.3. 1.1 through 4.6.3. 1.3 have been revised to state "Each containment isolation valve shall..." or "... each power-operated or automatic containment isolation valve shall..." rather than stating the requirements in relation to the valves specified in Table 3.6. 1.
Finally, the following statement is proposed to be added to the LCO for TS 3,6.3.1; The provisions of Specification 3.0.4 do not apply.
Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of Technical Specifications.
The rule requires that Technical Specifications include items in specific categories, including safety limits, limiting conditions for operation, and surveillance requirements;
- however, the rule does not specify the particular requirements to be included in a plant's Technical Specifications.
The NRC developed criteria, as described in the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors,"
(58 FR 39132) to determine which of the design conditions and associated surveillances need to be located in the Technical Specifications.
The Final Policy Statement adopted the subjective statement of the Atomic Safety and Licensing Appeal
- Board, ALAB 531, 9
NRC 263 (1979),
(Trojan Nuclear Plant) as the basis for the criteria.
The Appeal Board stated,
"... there is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or equivalent) be subject to a Technical Specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval.
- Rather, as best we can discern it, the contemplation of both the Act and the regulations is the Technical Specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an event giving rise to an immediate threat to the public health and safety."
Briefly, the criteria provided by the Final Policy Statement are (1) detection of abnormal degradation of the reactor coolant pressure
- boundary, (2) boundary conditions for design basis accidents and transients, (3) primary success paths to prevent or mitigate design basis accidents and transients, and (4) functions determined to be important to risk or operating experience.
The Commission's Final Policy Statement acknowledged that its implementation may result in the relocation of existing Technical Specification requirements to licensee controlled documents and programs.
The staff's review of the proposed change determined that the relocation of the list of containment isolation valves, Table 3.6-1, does not eliminate the requirements for the licensee to ensure that the containment isolation valves are capable of performing their safety function.
Although the list of containment isolation valves is relocated from the Technical Specifications to a controlled document referenced in the updated final safety analysis report (UFSAR), the licensee must continue to evaluate any changes to the list of valves required for containment isolation in accordance with 10 CFR 50,59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to UFSAR commitments and to take any remedial action that may be appropriate.
The staff's review concluded that 10 CFR 50.36 does not require the list of containment isolation valves to be retained in Technical Specifications.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure operability of the containment isolation function is retained due to the importance of containment isolation in mitigating the consequences of an accident.
- However, the staff determined that the inclusion of the containment isolation valve list is an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected list of containment isolation valves, Table 3.6-1, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that relocation of the list of containment isolation valves and the associated changes to remove references to the list is acceptable because (1) their inclusion in Technical Specifications is not specifically required by 10 CFR 50.36 or other regulations, (2) the list of containment isolation valves has been relocated to a controlled document referenced in the
- UFSAR, are adequately controlled by 10 CFR 50.59, and their inclusion in the Technical Specification is not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to
involve an unreviewed safety question, will require prior NRC approval in accordance with 10 CFR 50 '9(c)
~
In regards to the addition of the note exempting the containment isolation valves from the requirements of TS 3 ' '
this change was
- made, subsequent to this request, by an amendment dated March 16, 1993.
Therefore, this request is considered moot
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments'he 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 (58 FR 8773)
~
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51 '2(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 Contributor:
John B. Hickman, NRR Thomas G. Dunning, NRR Date:
August 29, 1994
A h