ML22307A004

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Slides - Pre-Application November 7, 2022 Meeting Slides
ML22307A004
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 11/07/2022
From:
American Electric Power Co
To:
Plant Licensing Branch III
Wall S
References
EPID L-2022-LRM-0089
Download: ML22307A004 (1)


Text

Amendment Request to Remove Neutron Flux from TS Table 3.3.3-1, Post Accident Monitoring Instrumentation November 7, 2022 1

Background

  • At Cook Plant Unit 2, one required channel of neutron flux instrumentation is unable to meet Environmental Qualification requirements, but otherwise fully functional
  • Vendor is winding down support for Gamma-Metrics instruments by end of 2024 and was not available for emergent support for repair/replacement during most recent U2 refueling outage
  • Industry precedent exists for neutron flux variable to be considered as Category 3 instrumentation 2

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Background===

3

Proposed Change

- This would eliminate need for Environmental Qualification of Wide Range Neutron Flux instrumentation 4

Justification

  • Function: Confirm initial Reactor Shutdown
  • With normal containment environment, WR NIs EQ requirements are not applicable
  • With harsh containment environment:

- adverse effects of steam or radiation are not immediate

- WR NIs operable for initial determination of reactor trip 5

Justification

  • Function: Critical Safety Function Status Monitoring
  • With normal containment environment, WR NIs EQ requirements are not applicable
  • With harsh containment environment

- Other means of indication available to determine if imminent threat to critical safety function exists

- e.g., Fully Environmentally Qualified Core Exit Thermocouples, RCS Hot Leg and Cold Leg instruments address this function provided by Wide Range NIs 6

Industry Review

  • At least five plants do not include Neutron Flux in their PAM TS

- Ginna,

- Byron/Braidwood,

- Comanche Peak and

- Farley 7