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{{#Wiki_filter:ACCESSION NBR FAC IL: 50-315 AUTH.NAME ALEX ICHOR M.P.RECIP.NAME MURLEYi T.E.REQULATO'NFORMATION DISTRIBUTION STEM (RIDS)8709170267 DOC.DATE: 87/O'P/1 1 NOTARIZED:
{{#Wiki_filter:REQULATO'NFORMATION DISTRIBUTION             STEM (RIDS)
NO DOCKET 0 Donald C.Cook Nuclear Poeer Planti Unit ii Indiana h 05000315 AUTHOR AFFILIATION Indiana 5 Michigan Electric Co.RECIPIENT AFFILIATION Document Control Branch<Document Control Desk)
ACCESSION NBR 8709170267           DOC. DATE: 87/O'P/1 1 NOTARIZED: NO           DOCKET 0 FAC IL: 50-315  Donald   C. Cook Nuclear Poeer     Planti Unit   ii Indiana h   05000315 AUTH. NAME            AUTHOR AFFILIATION ALEXICHOR M. P.        Indiana   5 Michigan Electric Co.
RECIP. NAME            RECIPIENT AFFILIATION MURLEYi T. E.            Document Control Branch <Document       Control Desk)


==SUBJECT:==
==SUBJECT:==
Requests one-time interpretation of Unit 1 Tech Spec 3.5.2.e to allow ECCS subsystem floe path to be considered operable w/floe fr om RHR pump aligned to deliver floe to only two of four reactor coolant sos loops.Fee paid.DISTRIBUTION CODE: A001D COPIES RECEIVED: LTR (ENCL 0 SIZE: TITLE: OR Submittal:
Requests   one-time interpretation of Unit     1 Tech Spec 3. 5. 2. e to allow   ECCS   subsystem floe path to be considered     operable w/floe fr om RHR pump aligned to deliver floe to only           two of four reactor coolant sos loops. Fee paid.
General Distribution NOTES: REC IP IENT ID CODE/NAME PD3-3 LA WIQQINGTONe D INTERNAL: ARM/DAF/LFMB NRR/DEST/CEB NRR/DEBT/RSB NRR LRB Q FILE 01 EXTERNAL: EGS(G BR USKEe S NRC PDR COPIES LTTR ENCL RECIPIENT ID CODE/NAME PD3-3 PD NRR/DEBT/ADS NRR/DEST/MTB NRR/DOEA/TSB OQC/HDS1 RES/DE/EIB LPDR NSIC COPIES LTTR ENCL TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL v''C.Q>>g'(-t p" h>>4'(I, INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O.BOX 16631 COLUMBUS, OHIO 43216 September 11, 1987 AEP'NRC:1024B Donald C.Cook Nuclear Plant Unit 1 Docket No.50-315 License No.DPR-58 RHR CROSS-TIE SURVEILLANCE:
DISTRIBUTION CODE: A001D         COPIES RECEIVED: LTR   ( ENCL   0   SIZE:
REQUEST FOR ONE-TIME TECHNICAL SPECIFICATION INTERPRETATION U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Attn: T.E.Murley
TITLE:   OR Submittal: General Distribution NOTES:
REC IP IENT         COPIES          RECIPIENT          COPIES ID CODE/NAME         LTTR ENCL      ID CODE/NAME        LTTR ENCL PD3-3 LA                             PD3-3 PD WIQQINGTONe D INTERNAL: ARM/DAF/LFMB                           NRR/DEBT/ADS NRR/DEST/CEB                         NRR/DEST/MTB NRR/DEBT/RSB                          NRR/DOEA/TSB NRR          LRB                    OQC/HDS1 Q  FILE        01                  RES/DE/EIB EXTERNAL:  EGS(G  BR USKEe S                    LPDR NRC PDR                              NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR           21   ENCL


==Dear Dr.Murley:==
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Pursuant to discussions with your staff on September ll, 1987, the purpose of this letter is to request a one-time interpretation of Unit 1 Technical Specification (T/S)3.5.2.e.The interpretation would allow an ECCS subsystem flow path to be considered operable with flow from a residual heat removal (RHR)pump aligned to deliver flow to only two of the four reactor coolant system loops, provided the safety injection (SI)system is aligned such that each SI pump can deliver flow to all four reactor coolant system loops.Back round T/S 3.5.2 states that two emergency core cooling system (ECCS)subsystems must be operable;it defines an operable ECCS subsystem as including one operable SI pump, one operable RHR pump, and associated flow paths.This T/S allows the operator to remove one ECCS subsystem for up to 72 hours while in Modes 1, 2, or 3 while maintaining an operable flow path for the opposing subsystem.
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The RHR and safety injection (SI)pump configuration at the D.C.Cook Plant is such that any one pump can deliver flow to all four reactor coolant loops.This is accomplished by means of cross-tie valves.With the cross-tie valves closed, each pump can only supply flow to two reactor coolant loops.The current small-break and large-break LOCA analyses for D.C.Cook Unit 1 assume that the cross-tie valves in the SI and RHR lines are open.This requires that the cross-tie valves be open to satisfy the operable flow path requirement of T/S 3.5.2.e for Modes 1, 2, and 3.I'109170'2'70'1>i PDR AQOCN, 05000315 P 00((g+A[pi<'s~i)o 4~~
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Dr.T.E.Murley-2-AEP:NRC:1024B In the past, there were instances where D.C.Cook Unit 1 was operated in Modes 1, 2, or 3 with the cross-tie valves closed.The valves were closed to allow maintenance work to be performed on various system components.
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Because this operation was not in agreement with the existing safety analyses, it was the subject of an Enforcement Conference held at Region III headquarters on January 21, 1987.Since some maintenance work can only be performed on the RHR or SI systems in Modes 1, 2, or 3 with the cross-tie valves closed, we decided to pursue new analyses which would support two-loop injection.
I,
The new analyses were submitted in our letters AEP:NRC:1024, dated March 23, 1987, and AEP:NRC:1024A, dated May 13, 1987.The analyses presented in these letters supported closing of either the SI system cross-tie valves or the RHR system cross-tie valves, but not both.The new analyses involved large-break LOCA evaluations for the RHR cross-tie valves, and small-break LOCA evaluations for the SI cross-tie valves.In discussions with your staff on July 29, 1987 we were informed that the staff had no problems with the RHR (large-break) analyses but had remaining questions on the SI (small-break) analyses.A draft response to the staff's questions on the SI evaluation has been received from Westinghouse Electric Corporation, and is currently under our review.The draft indicates that the small break LOCA analyses we submitted in our letters AEP:NRC:1024 and AEP:NRC:1024A remain valid, and that the SI cross-tie valves should be allowed to be closed.Reason For Re uest On September 11, 1987, it.was determined that a valve in the Unit 1 RHR system would need to be repaired.D.C.Cook Unit 1 is currently returning to operation following refueling.
 
Repairing the valve in Mode 3 (rather than Mode 4)will save approximately 36 hours of critical path time but will require the RHR cross-tie valves to be closed.We believe the analyses we have previously submitted support this operation (provided the SI cross-tie valves remain open).Additionally we note that since D.C.Cook Unit 1 is returning from a refueling outage, decay heat in the core is minimal which further supports our conclusion that the RHR cross-tie valves can safely be closed.Although we have been informally told that the staff has no problems with the RHR analysis, the new analysis has never been formally approved by the NRC.For this reason, we, are requesting a one-time interpretation of T/S 3.5.2.e such that we may operate with the RHR cross-tie valves closed while in Mode 3 incident to the required valve maintenance.
INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 September  11, 1987 AEP'NRC:1024B Donald C. Cook Nuclear Plant Unit      1 Docket No. 50-315 License No. DPR-58 RHR CROSS-TIE SURVEILLANCE:
Pursuant to the requirements of 10 CFR 170.12(c), we have enclosed an application fee of$150.00 for the proposed interpretation.
REQUEST FOR ONE-TIME TECHNICAL SPECIFICATION INTERPRETATION U.S. Nuclear Regulatory Commission Attn:  Document  Control Desk Washington, D.C.      20555 Attn: T. E. Murley
Dr.T.E.Murley-3-AEP'NRC:1024B This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
 
Very truly yours, M.P.Alexich Vice President cc: John E.Dolan W.G.Smith, Jr.-Bridgman R.C.Callen G.Bruchmann G.Charnoff NRC Resident Inspector-Bridgman A.B.Davis-Region III}}
==Dear Dr. Murley:==
 
Pursuant to discussions with your staff on September       ll, 1987, the purpose of this letter is to request a one-time interpretation of Unit 1 Technical Specification (T/S) 3.5.2.e. The interpretation would allow an ECCS subsystem flow path to be considered operable with flow from a residual heat removal (RHR) pump aligned to deliver flow to only two of the four reactor coolant system loops, provided the safety injection (SI) system is aligned such that each SI pump can deliver flow to all four reactor coolant system loops.
Back round T/S 3.5.2 states that two emergency core cooling system (ECCS) subsystems must be operable;     it   defines an operable ECCS subsystem as including one operable SI pump, one operable RHR pump, and associated flow paths. This T/S allows the operator to remove one ECCS subsystem for up to 72 hours while in Modes 1, 2, or 3 while maintaining an operable flow path for the opposing subsystem.       The RHR and safety injection (SI) pump configuration at the D. C. Cook Plant is such that any one pump can deliver flow to all four reactor coolant loops. This is accomplished by means of cross-tie valves. With the cross-tie valves closed, each pump can only supply flow to two reactor coolant loops.
The current small-break and large-break LOCA analyses for D. C. Cook Unit 1 assume that the cross-tie valves in the SI and RHR lines are open. This requires that the cross-tie valves be open to satisfy the operable flow path requirement of T/S 3.5.2.e for Modes 1, 2, and 3.
I'109170'2'70'1>i PDR AQOCN,   05000315                                                   00(
A[pi<'s~
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                                                                                          +
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Dr. T. E. Murley                                       AEP:NRC:1024B In the past, there were instances where D. C. Cook Unit 1 was operated in Modes 1, 2, or 3 with the cross-tie valves closed. The valves were closed to allow maintenance work to be performed on various system components. Because this operation was not in agreement with the existing safety analyses,   it was the subject of an Enforcement Conference held at Region   III headquarters on January 21, 1987.
Since some maintenance work can only be performed on the RHR or SI systems in Modes 1, 2, or 3 with the cross-tie valves closed, we decided to pursue new analyses which would support two-loop injection. The new analyses were submitted in our letters AEP:NRC:1024, dated March 23, 1987, and AEP:NRC:1024A, dated May 13, 1987. The analyses presented in these letters supported closing of either the SI system cross-tie valves or the RHR system cross-tie valves, but not both. The new analyses involved large-break LOCA evaluations for the RHR cross-tie valves, and small-break LOCA evaluations for the SI cross-tie valves.
In discussions with your staff on July 29, 1987 we were informed that the staff had no problems with the RHR (large-break) analyses but had remaining questions on the SI (small-break) analyses.     A draft response to the staff's questions on the SI evaluation has been received from Westinghouse Electric Corporation, and is currently under our review. The draft indicates that the small break LOCA analyses we submitted in our letters AEP:NRC:1024 and AEP:NRC:1024A remain valid, and that the SI cross-tie valves should be allowed to be closed.
Reason For Re   uest On September 11, 1987, it. was determined that a valve in the Unit 1 RHR system would need to be repaired. D. C. Cook Unit 1 is currently returning to operation following refueling. Repairing the valve in Mode 3 (rather than Mode 4) will save approximately 36 hours of critical path time but will require the RHR cross-tie valves to be closed. We believe the analyses we have previously submitted support this operation (provided the SI cross-tie valves remain open). Additionally we note that since D. C. Cook Unit 1 is returning from a refueling outage, decay heat in the core is minimal which further supports our conclusion that the RHR cross-tie valves can safely be closed. Although we have been informally told that the staff has no problems with the RHR analysis, the new analysis has never been formally approved by the NRC. For this reason, we, are requesting a one-time interpretation of T/S 3.5.2.e such that we may operate with the RHR cross-tie valves closed while in Mode 3 incident to the required valve maintenance.
Pursuant to the requirements of 10 CFR 170.12(c), we have enclosed an application fee of $ 150.00 for the proposed interpretation.
 
Dr. T. E. Murley                                   AEP'NRC:1024B This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, M. P. Alexich Vice President cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman A. B. Davis - Region III}}

Latest revision as of 02:21, 4 February 2020

Application for one-time Interpretation of Tech Spec 3.5.2.e to Allow ECCS Subsystem Flow Path to Be Considered Operable W/Flow from RHR Pump Aligned to Deliver Flow to Only Two of Four RCS Loops.Fee Paid
ML17325A285
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 09/11/1987
From: Alexich M
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To: Murley T
NRC, NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
AEP:NRC:1024B, NUDOCS 8709170267
Download: ML17325A285 (6)


Text

REQULATO'NFORMATION DISTRIBUTION STEM (RIDS)

ACCESSION NBR 8709170267 DOC. DATE: 87/O'P/1 1 NOTARIZED: NO DOCKET 0 FAC IL: 50-315 Donald C. Cook Nuclear Poeer Planti Unit ii Indiana h 05000315 AUTH. NAME AUTHOR AFFILIATION ALEXICHOR M. P. Indiana 5 Michigan Electric Co.

RECIP. NAME RECIPIENT AFFILIATION MURLEYi T. E. Document Control Branch <Document Control Desk)

SUBJECT:

Requests one-time interpretation of Unit 1 Tech Spec 3. 5. 2. e to allow ECCS subsystem floe path to be considered operable w/floe fr om RHR pump aligned to deliver floe to only two of four reactor coolant sos loops. Fee paid.

DISTRIBUTION CODE: A001D COPIES RECEIVED: LTR ( ENCL 0 SIZE:

TITLE: OR Submittal: General Distribution NOTES:

REC IP IENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 LA PD3-3 PD WIQQINGTONe D INTERNAL: ARM/DAF/LFMB NRR/DEBT/ADS NRR/DEST/CEB NRR/DEST/MTB NRR/DEBT/RSB NRR/DOEA/TSB NRR LRB OQC/HDS1 Q FILE 01 RES/DE/EIB EXTERNAL: EGS(G BR USKEe S LPDR NRC PDR NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL

vC

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( -t p" h>>

4'(

I,

INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 September 11, 1987 AEP'NRC:1024B Donald C. Cook Nuclear Plant Unit 1 Docket No. 50-315 License No. DPR-58 RHR CROSS-TIE SURVEILLANCE:

REQUEST FOR ONE-TIME TECHNICAL SPECIFICATION INTERPRETATION U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: T. E. Murley

Dear Dr. Murley:

Pursuant to discussions with your staff on September ll, 1987, the purpose of this letter is to request a one-time interpretation of Unit 1 Technical Specification (T/S) 3.5.2.e. The interpretation would allow an ECCS subsystem flow path to be considered operable with flow from a residual heat removal (RHR) pump aligned to deliver flow to only two of the four reactor coolant system loops, provided the safety injection (SI) system is aligned such that each SI pump can deliver flow to all four reactor coolant system loops.

Back round T/S 3.5.2 states that two emergency core cooling system (ECCS) subsystems must be operable; it defines an operable ECCS subsystem as including one operable SI pump, one operable RHR pump, and associated flow paths. This T/S allows the operator to remove one ECCS subsystem for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> while in Modes 1, 2, or 3 while maintaining an operable flow path for the opposing subsystem. The RHR and safety injection (SI) pump configuration at the D. C. Cook Plant is such that any one pump can deliver flow to all four reactor coolant loops. This is accomplished by means of cross-tie valves. With the cross-tie valves closed, each pump can only supply flow to two reactor coolant loops.

The current small-break and large-break LOCA analyses for D. C. Cook Unit 1 assume that the cross-tie valves in the SI and RHR lines are open. This requires that the cross-tie valves be open to satisfy the operable flow path requirement of T/S 3.5.2.e for Modes 1, 2, and 3.

I'109170'2'70'1>i PDR AQOCN, 05000315 00(

A[pi<'s~

(g

+

P i)o

4~ ~

Dr. T. E. Murley AEP:NRC:1024B In the past, there were instances where D. C. Cook Unit 1 was operated in Modes 1, 2, or 3 with the cross-tie valves closed. The valves were closed to allow maintenance work to be performed on various system components. Because this operation was not in agreement with the existing safety analyses, it was the subject of an Enforcement Conference held at Region III headquarters on January 21, 1987.

Since some maintenance work can only be performed on the RHR or SI systems in Modes 1, 2, or 3 with the cross-tie valves closed, we decided to pursue new analyses which would support two-loop injection. The new analyses were submitted in our letters AEP:NRC:1024, dated March 23, 1987, and AEP:NRC:1024A, dated May 13, 1987. The analyses presented in these letters supported closing of either the SI system cross-tie valves or the RHR system cross-tie valves, but not both. The new analyses involved large-break LOCA evaluations for the RHR cross-tie valves, and small-break LOCA evaluations for the SI cross-tie valves.

In discussions with your staff on July 29, 1987 we were informed that the staff had no problems with the RHR (large-break) analyses but had remaining questions on the SI (small-break) analyses. A draft response to the staff's questions on the SI evaluation has been received from Westinghouse Electric Corporation, and is currently under our review. The draft indicates that the small break LOCA analyses we submitted in our letters AEP:NRC:1024 and AEP:NRC:1024A remain valid, and that the SI cross-tie valves should be allowed to be closed.

Reason For Re uest On September 11, 1987, it. was determined that a valve in the Unit 1 RHR system would need to be repaired. D. C. Cook Unit 1 is currently returning to operation following refueling. Repairing the valve in Mode 3 (rather than Mode 4) will save approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of critical path time but will require the RHR cross-tie valves to be closed. We believe the analyses we have previously submitted support this operation (provided the SI cross-tie valves remain open). Additionally we note that since D. C. Cook Unit 1 is returning from a refueling outage, decay heat in the core is minimal which further supports our conclusion that the RHR cross-tie valves can safely be closed. Although we have been informally told that the staff has no problems with the RHR analysis, the new analysis has never been formally approved by the NRC. For this reason, we, are requesting a one-time interpretation of T/S 3.5.2.e such that we may operate with the RHR cross-tie valves closed while in Mode 3 incident to the required valve maintenance.

Pursuant to the requirements of 10 CFR 170.12(c), we have enclosed an application fee of $ 150.00 for the proposed interpretation.

Dr. T. E. Murley AEP'NRC:1024B This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, M. P. Alexich Vice President cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman A. B. Davis - Region III