ML17334B088
| ML17334B088 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/06/1987 |
| From: | Wigginton D Office of Nuclear Reactor Regulation |
| To: | Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| Shared Package | |
| ML17325A213 | List: |
| References | |
| TASK-2.F.1, TASK-TM GL-83-37, NUDOCS 8705190593 | |
| Download: ML17334B088 (6) | |
Text
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50-315 50-316 UNITEDSTATES NUl;Lg+R RQQULATORY COMMISSION
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BRZNER J.
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FE.T'?fSTSIN R. F.
XROEGER B. SHINNOCK D.
Y. VIZLIAMSg JR.
JOHN E.
DOLAN Mr. John Dolan, Vfce President Indiana and Mfchfgan Electric Company c/o American Electric Power Service Corporation 1 Rfversfde Plaza
- Columbus, Ohf o 43216
Dear Mr. Dolan:
Sy letters dated July 19, 1984 and May 19, 1986, the Indiana and Michigan Electric Company submitted proposed changes to the Technical Specfffcatfons for the Donald C.
Cook tIuclear Plant, Vnft Nos.
1 and 2.
The changes were to respond to the requirements for TMI Action Items II.F.1.5. "Contaftaent Water l.evel Monitoring Instrumentatfon".
Qe have completed our revfew of the proposed changes and find that we cannot approve them as submitted.
A copy of our preliminary safety evaluation is enclosed.
It is requested that the IHEC review our posftfons in the safety evaluation and make the modfffcations to your proposal as necessary.
If you wish to further discuss this matter, we will be glad to do so.
Our goal fs to complete thfs TMI Item this fiscal year; therefore, the IMEC should establish a final acceptable position within 60 days of receipt of this letter.
Sincerely,
Enclosure:
Safety Evaluatfon cc:
See Next Page David L. Nfggfnton, Actfng Project Director Project Directorate III-3 Dfvisio f Reactor Pro e
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Mr. John Dolan Indiana and Michigan Electric Company Oonald C.
Cook Nuclear Plant CC:
Mr, M, P. Alexfch yfce President Nuclear Operations American Electric Power Service Corporation I Riverside Plaza
- Columbus, Ohio 43215 Attorney General Oepartment of Attorney General 525 MesC Ottawa Street Lansing, Michigan 48913 Township Supervisor Lake Township, Hall Post Office Box 818
,Brfdgeean, Mfchfgan 49106 M. 6. Smfth, Jr., Plant Manager Oonald C.
Cook Nuclear Plant Post Office Box 458 Brfdgman, Mfchfgan 49106 U.S. Nuclear Regulatory Comnfssfon Resfdent Inspectors Office 7700 Red Arrow Highway Stevensvflle, Mfchfgan 49127 Gerald Charnoff, Esquire, Shaw, Pfttman, Potts and Trowbridge 1800 M Street, N.W.
Mashfngton, OC 20037 Mayor, Cfty of Brfdgeman Post Office Box 366 Brfdgeman, Mfchfgan 49106 Specfal Assfstant to the Governor Room I - State Capitol Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Ofvfsfon of Radiological Health Oepartment of Publfc Health 3500 N. Logan Street Post Office Box 30035
. Lansfng, Michigan 48909 The Honorable John E. Grotberg United States House of Representatives Mashfngton, OC 20515 Regfonal Adjwfnfstrator, Region lr[
U.S. Nuclear Regulatory Coaefssfon 799 Roosevelt Road Glen El lyn, I11fnois 60137 J. Fefnstefn Aeerfcan Electr fc Power Service Corporation I Riversfde Plaza
- Columbus, Ohfo 43216
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UNITED STATES NUCLEAR REGULATORY COMM)$$ )QN WASHINGTON. O. C. 2065$
PRELIMINARY SAFETY EVALUATION Rv THE OFFICE OF NUCLEAR REACTOR REGULATIOH iHDIANA AND MICHIGAN ELECTRIC COMPANY DONALD C.
COOK NUCLEAR PLANT, UNIT HOS. 1 AND P DOCKET NOS.
50-315 AND 50-316 BACKGROUND NUREG-0737, "Clarification of TMI Action Plan Requfrements,"
sets forth all required post TMI-related modfffcatfons to operatfng plants fncludfng schedules, applfcability, method of implementation revfew, and licensee submittal dates.
Section II.F.1.5 of HUREG-0737 requires that a contfnuous fndfcatfon of containment water level be provided in the control room for all plants, both PQR's and BMR's.
For PMR's, narrow range instruments must be provfded to measure from the bottom to the top of the containment sump.
A wide range instrument must be available to measure from the bottom of the contafnment to the elevatfon equivalent to 600,000 gallons capacity.
HUREG-0737 also requires that technical specifications (TS) be developed which provide assurance that facility operation is maintafned within limits determined acceptable following the implementation of specific TMI action items.
including containment water level monitoring.
Generic Letter 83-37 (GL), dated November 1, 1983, set forth guidance on the scope and content of TS covering HUREG-0737 items.
The GL provfded sample TS with blanks or parentheses appearing where information would be plant-specific.
Among the samples provided was a proposed specification which set forth minimum channel requirements, limiting conditions for operation (LCO), and surveillance requirements for containment water level monitoring.
The generic letter called for.one channel for narrow range monitoring of containment sump level, and two channels for wide range monitoring of containment water level.
The generic letter also set forth an LCO Action Statement, for narrow range monftors, which requires that an inoperable channel be restored to operable status within 30 days or the plant be brought to hot shutdown as required for other accident monitorfng instrumentatfon.
The suggestion for wide range monitoring instrumentation placed no specific outage time constraint on inoperable channels.
The guidance suggested that the LCO Action Statement for wide range should be similar to that for other accident monitoring instrumentation included in a plant's exfstfng technical specifications.
On July 19> 1984, the licensee submitted proposed technfca1 specfffcatfons governing changes made pursuant to NUREG-0737,Section II.F.1.5.
These changes deviated from the guidance contained in the generic letter by proposing that only one channel be required for wide range monitoring.
The proposed changes further neglected to impose reauirements for perfodic checks of either wide or narrow range instrument channels as part of required surveillance procedures.
Subsequent to a January 13, 1986 meeting between the staff and the lfcensee, the licensee's proposa1s were modified and resubmitted by letter dated Hay 19, 1986.
. EVALUATION Unlike the orfgfnal proposal, the revfsed proposal requests TS changes to require (1) routine monthly channel checks for both sump and containment level fnstrumentatfon (0. C.
Cook Unit 1, TS Table 4.3-7 and 0. C. Cook Unft 2, TS Table 4.3-10),
and (2) the addition of two instrumentatfon channels to monitor containment water level rather than the single channel as originally proposed by the licensee (0. C.
Caak Unit 1, TS Table 3.3-11 and 0. C.
Caok Unft 1, TS Table 3.3-10).
The revised proposal also requests that the existing 30-day action statement fn the Units 1 and 2
TS for other accident monitoring instrumentatfon be applied to containment water level fnstrueentatfon (wide range).
These revfsfons bring the TS into accard with the guidance of the generfc letter as far as recoanended fnstrumentatfon and requfred survefllances are concerned.
However, with respect to limiting condftfons for operation and associated action statements for containment sump level, the licensee's revised proposal continues to deviate fram the guidance contained fn the generic letter.
The generic letter calls for the Action statement associated with the LCO for sump level fnstrumentatfon to include the requfrement that, the fnaperable channel be restored to operable status within 30 days or the plant be brought to hot shutdown condition as required for other accident monitoring fnstrumentatfon.
The 0. C. Cook Units'S require reactor shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following a 30-day period of fnoperabflfty of other accident monitoring fnstrumentatfan.
For inoperability of the sump level instrumentation
- channel, the licensee proposes to deviate from this shutdown requirement by substituting a requirement to submit a special report to the Regional Administrator.
This report would outline available backup equipment, the cause of the inoperability, and the plans and schedule for restorfng the system to operable status.
This report would be submitted pursuant to technical specfffcatfon 6.9.2, "Special Reports,"
which the licensee proposes to amend to reflect its applicability to suItp level in-strumentation.
The licensee feels justified in exempting containment sump level instrumentation from adhering to the 12-hour shutdown provision applied ta other fnstrumentatfon channels because of the number of backup instrumenta-tion systems available (humidity monitors, sump pump run time, containment atmosphere particulate radfoactfvfty monitoring channels, containment atmosphere gaseous radioactivity monitoring channels, the containment water level instrumen-
- tation, and Refueling Mater Storage Tank water level.)
The licensee also proposed changes to the Sases for Post-Accident Instrumentation (Section 3/4.3.3.8 for Unit 1 and Section 3/4.3.3.6 for Unit 2).
The licensee's proposal states that (1) an acceptable instrument drift for contailtent water level is 25 percent of full scale, and (2) for sump level channels, a difference between readings on the two parallel channels of not more than 25 percen:
o'. -.ull scale is acceptable..
CONCLUSION The staff has reviewed the licensee's proposed changes to the 0.
C.
Cook Units 1 and 2 technical specifications.
Our conclusions are as follows:
(1)
The licensee's proposed changes related to instrumentation and surveillance requirements generally follow the guidelines of Generic Letter 83-37 and the W Standard Technical Specifications, Rev. 4.
The staff can foresee no increase in the orobability or consequences of any previously evaluated accident as a result of these changes.
These changes will increase the amount of information available to the operator during accident conditions and assist him during the recovery period.
The staff finds these changes acceptable.
(2)
The staff denies the licensee's request to prepare a written repo+
in lieu of plant shutdown as stated in the licensee's proposed revisions to the conta'inment sump level Action Statements of Tab1e
.3 3-11 for Unit 1 and Table 3 3-10 for Unit 2.
The staff's view is that the licensee has failed to provide a valid rationale, including plant unique bases for deviating from the requirement that the plant be shut down following 30 days of inoperability of sump level instrumentation.
The instrumentation which the licensee implies as being sufficient to offset the loss of the sump instrumentation is not designed to measure sump level, as specifically required by NUREG-0737.
Furthermore, the guidance set forth in GL 83-37 specifically states that the plant be brought to Hot Shutdown following 30 days of inoperability of sump level instrumentation.
The staff has not been convinced that unique justification exists for exempting 0.
C.
Cook from compliance with this guidance.
The staff further denies licensee's proposal to modify TS Section 6.9.2, "Special Reports," to include "containment sump level instrumentation" as one of the topics for which special reports can be written in lieu of taking other Actions.
(3)
The staff denies the licensee's proposal to change the post-accident Instrumentation 8ases (TS Section 3/4.3.3.8 for Unit 1 and Section 3/4.3.3.6 for Unit 2) to allow the provision for a 25 percent instrument drift.
The licensee has failed to provide an adequate basis for considering 25 percent instrument drift as acceptable.
The staff's view is that a
25 percent drift is unreasonable and essentially defeats the intended purpose of the instrumentation, e.g., to give a true indication of the level of coolant in containment.
Attachment 2 to AEP:NRC:0856T I&fECo Letter No. AEP:NRC:0856I, dated Hay 19, 1986