ML20199M063
| ML20199M063 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/27/1986 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| AEP:NRC:1000, NUDOCS 8607100089 | |
| Download: ML20199M063 (4) | |
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s INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BO)W16631 PRIORITYRCdTIF~
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Donald,C. Cogk Nuclear ~ Plant Unit No. 2 e
Docket No. 50-316 License No. DPR-74 EMERGENCY DI$SEL GENERATOR;' REQUEST FOR' RELIEF FROM TECsNICAL SPECIFICATION REQUIREMENTS Mr. James G. Keppler, Regional' Director-U.S. Nuclear Regulatory Commission Region III e
799 Roosevelt Road 6
Glen Ellyn, IL 60137,
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Dear Mr. Keppler:
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r The purpose of this letter is to request a temporary waiver from the l'
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requireinents, of' our Technical Specification 3.8.1.1.
More specifically, we are requesting that the time the pl' ant gay continue to operete abode Mode 4 (Hot Shotdown) be temporarily ektended from,72'. hours to 120. hours.
The Unit 2 AB diesel generator was declared inoperable at 8:15 p.m. on June.26, 1986.
D'uring a routine laboratory sampling of the lubrication oil, visual Abnormalities were noted.
Laboratory analyses indicated that the water content'was at the upper, limit of lube oil specifications.
Further testing is being conduc.ted by an outside laboratory.,to verify our preliminary ~ analysis results and.to determine the cause of the contaminatlon.
The two d,ay extension is required because we estimate'it will take a total of 5 days from tlie' time of the event to perform and evaluate the necessary laboratory analysis, change the, oil as appropriate,
' and take the necessary action to. assure this will not' be a recurriftg
- problem.
in Mode 3 (Hot Standby), pending
- We are currently holding the unit return of.the diesel to s,ervice and, resolution of our request.for relief.
Prior tp the event, the" unit'was in Mode 3, returning'to power operation' following a refueling outage.
If relief is not 6 ranted,'it will bs
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necessary for us to bring.th'e u' nit to the Moda 4 (Hot Shutdown) condition within. 6 ho'urs of expiration of.the currently allotted 72. hours, and in Mode
' S (Cold Silutdown) within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after that.
This will have the effect of
,, making our outage approximately 5 d'ays longer than if we were to remain.in Mode'. 3.
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Mr.'3amas G. Keppler AEP:NRC:1000
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We believe the additional 5 d,ays wou1d cause significant burden on our rat'epayers..The American Electric Power (AEP)* grid, as well as t8ose of our s
neighboring utilities to whom we have committed to supply power,
- h'istorically experie'nce' peak demand during the month of Jttly.
Each unit of.
the Cook Plaht supplies approximately 5% of AEP"s total generation when operating at full power. The differential fuel cost associated with loss of
' the generating capacity of Unit 2^ amounts to'a'pproximately $1 milli'on over
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the 5-day period.
.j Because the probability,of an accident occurring dpr,ing the additional 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />s-is very small (especially an' accident requiring the diesel), it is our belief that the public health and safety will not be adversely impacted.
Additionally,.we note that the change will allow us to avoid exposing the unit to the risk inherent *in thermally cycling the unit from Mode 3.co. Mode
. 5 and then returning.
,Our currently allotted'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for operation above Mode 4 (Hot Shutdown) will expire at.8:15 p.'m.
on June 29, 1986. We have requested-relief through the regional' office,. at. the direction of m' embers of your staff,. because time did not allow us to process this as an emergency
- rechnical Specification change;
'Our safety review per ld CFR 50.59,is attacheil to this 1,etter,.
e This document,has b'een prepa, red following Corporate procedures which.
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incorporate a reasonable set of controls to insure,its< accuracy and completeness. prior,to signature by the undersigned',
e Very truly yo.
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.4 P. A xich Vice,P esident gb
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Att'achment,
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cc: John E. Dolan
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W; G. Smith, Jr. - Bridgman
. R.,C.- Callen e
G. Charnoff C. Bruchmann.-
6 NRC Rasident Inspector - Bridgman p
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e ATTACHMENT 1 TO AEP:NRC:1000
. SAFETY EVALUA,Ti'ON PER 10 CFR 50.59 e
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Attachment to AEP:NRC:1000 This att,achment present;s our evaluation 'of the reque'sted wa'iver per 10 CFR SD.59'.
e Per"10 CFR 50,.59,~a proposed change shafl be deeme'd to involve an unreviewed safety question:
.,(1)
If> the probability, of-occurrence or the consequences of an accident'or malfunction of eg'uipment important to safety l
previously;evalu*ated in the safety analysis report may be increased; or -
(2) if a possibility for an accident or-malfunction.of.a different.
type than any evaluated'previously in the-safety analysis report may 6e created; or (3) if the margin of safety as defined in the basis. for any pchnical specificat(on is reduced.
b criterion 1 The T/Ss currently allow a diese.1 generatior to be out of service for 7'2
, hours.
It is our belief that ths probability of a,n accident occurring during the ' additional time we have requested is not significant..The
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consequences of an accident would not change as a resuIt of our request, j,
since no new modes of plant operation or changes to fuel or equipment. sill-eccur.
Criterion 2-4 ~.
Since no new mddes of plant operation or changes to fuel or equipment will occur, these changes would not be expscted to create the possibility of a
. nef or diffe, rent kind of-accident from an.y previously analyzed or evaluat'ed.
Criterion 3-
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Because 1)"the probability of an accident occurring during the additipnal time is. expected to be very small, and 2) the risk involved in operating inl Mode 3 with one. diesel inoperable is fe.lt to be smaller than the risks
, inheren,t in thermally,, cycling the plant fropt Hot Stan'dby to Cold Shutdown, we believe tha't a significant; reductic,. in a ma*rgin of, safety will.not occur.,
Based o'n the above evaluation we. believe the requested waiver to T/S 3.8.1.1 does not constitute an unrevibwed safet'y ' question as defined in 10 CFR 1
50.59.
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