|
|
Line 17: |
Line 17: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:.ACCELERATED DIRIBUTIONDEMONSTTIONSYSTEMv~~pREGULATORY INFORMATXON DISTRIBUTION SYSTEM(RIDS).ACCESSION NBR:9103060047 DOC.DATE: | | {{#Wiki_filter:.ACCELERATED DI RIBUTION DEMONST TION SYSTEM v~~p REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS).ACCESSION NBR:9103060047 DOC.DATE: 91/02/27 NOTARIZED: |
| 91/02/27NOTARIZED: | | NO DOCKET g FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana&05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P. |
| NODOCKETgFACIL:50-315 DonaldC.CookNuclearPowerPlant,Unit1,Indiana60500031550-316DonaldC.CookNuclearPowerPlant,Unit2,Indiana&05000316AUTH.NAMEAUTHORAFFILIATION ALEXICH,M.P.
| | Indiana Michigan Power Co.(formerly Indiana 6 Michigan Ele RECXP.NAME RECIPXENT AFFILIATION R MURLEY,T.E. |
| IndianaMichiganPowerCo.(formerly Indiana6MichiganEleRECXP.NAME RECIPXENT AFFILIATION RMURLEY,T.E.
| | Document Control Branch (Document Control Desk) |
| DocumentControlBranch(Document ControlDesk)
| |
|
| |
|
| ==SUBJECT:== | | ==SUBJECT:== |
| Application foramendstoLicensesDPR-586DPR-74,modifying TechSpecSection3.6.3.1recontainment isolation valvestoprovideexemption fromrequirements ofTechSpec3.0.4undercertaincircumstances. | | Application for amends to Licenses DPR-58 6 DPR-74,modifying Tech Spec Section 3.6.3.1 re containment isolation valves to provide exemption from requirements of Tech Spec 3.0.4 under certain circumstances. |
| DISTRIBUTION CODE:AOOIDCOPIESRECEIVED:LTR tENCLLSIZE:TITLE:ORSubmittal: | | DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR t ENCL L SIZE: TITLE: OR Submittal: |
| GeneralDistribution NOTESIIDARECIPIENT IDCODE/NAME PD3-1LACOLBURN,T.
| | General Distribution NOTES I I D A RECIPIENT ID CODE/NAME PD3-1 LA COLBURN,T. |
| INTERNAL: | | INTERNAL: NRR/DET/ECMB 9H NRR/DOEA/OTS B1 1 NRR/DST/SELB 8D NRR/DST/SRXB 8E OC G F 01 EXTERNAL: NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 0 1 1 1 1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 0 1 1 1 1 D 1 S I D NOTE TO ALL"RIDS" RECIPIENTS: |
| NRR/DET/ECMB 9HNRR/DOEA/OTS B11NRR/DST/SELB 8DNRR/DST/SRXB 8EOCGF01EXTERNAL: | | D D PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 16 t |
| NRCPDRCOPIESLTTRENCL112211111111101111RECIPIENT IDCODE/NAME PD3-1PDNRR/DET/ESGB NRR/DST8E2NRR/DST/SICB 7ENUDOCS-ABSTRACT OGC/HDS2RES/DSIR/EIB NSICCOPIESLTTRENCL1111111111101111D1SIDNOTETOALL"RIDS"RECIPIENTS:
| | Indiana Michigan Power Company P.O.Box 16631 Columbus, OH 43216 IIHSMSIHSl PvZCNEGQH PQWM AEP: NRC: 1036B Donald C.Cook Nuclear Plant Units 1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 TECHNICAL SPECIFICATION 3'.4 EXEMPTION FOR CONTAINMENT ISOLATION VALVES U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Attn: T.E.Murley February 27, 199l |
| DDPLEASEHELPUSTOREDUCEWASTE!CONTACTTHEDOCUMENTCONTROLDESK,ROOMPl-37(EXT.20079)TOELIMINATE YOURNAMEFROMDISTRIBUTION LISTSFORDOCUMENTS YOUDON'TNEED!TOTALNUMBEROFCOPIESREQUIRED:
| |
| LTTR18ENCL16 t
| |
| IndianaMichiganPowerCompanyP.O.Box16631Columbus, OH43216IIHSMSIHSl PvZCNEGQH PQWMAEP:NRC:1036BDonaldC.CookNuclearPlantUnits1and2DocketNos.50-315and50-316LicenseNos.DPR-58andDPR-74TECHNICAL SPECIFICATION 3'.4EXEMPTION FORCONTAINMENT ISOLATION VALVESU.S.NuclearRegulatory Commission DocumentControlDeskWashington, D.C.20555Attn:T.E.MurleyFebruary27,199l
| |
|
| |
|
| ==DearDr.Murley:== | | ==Dear Dr.Murley:== |
| Thisletteranditsattachments constitute anapplication foramendment totheTechnical Specifications (T/Ss)fortheDonaldC.CookNuclearPlantUnits1and2.Specifically, weproposeto~modifySection3.6.3.1(Containment Isolation Valves)toprovideanexemption totherequirements ofT/S3.0.4undercertaincircumstances.
| | This letter and its attachments constitute an application for amendment to the Technical Specifications (T/Ss)for the Donald C.Cook Nuclear Plant Units 1 and 2.Specifically, we propose to~modify Section 3.6.3.1 (Containment Isolation Valves)to provide an exemption to the requirements of T/S 3.0.4 under certain circumstances. |
| Ourreasonsfortheproposedchanges,aswellasouranalysesconcerning significant hazardsconsiderations, arecontained inAttachment 1tothisletter,TheproposedrevisedT/Sspagesarecontained inAttachment 2.ThecurrentT/Ssmarked-up toreflecttheproposedchangesarecontained inAttachment 3.Webelievethattheproposedchangeswillnotresultin(1)asignificant changeinthetypesofeffluents orasignificant increaseintheamountsofanyeffluents thatmaybereleasedoffsite,or(2)asignificant increaseinindividual orcumulative occupational radiation exposure.
| | Our reasons for the proposed changes, as well as our analyses concerning significant hazards considerations, are contained in Attachment 1 to this letter, The proposed revised T/Ss pages are contained in Attachment 2.The current T/Ss marked-up to reflect the proposed changes are contained in Attachment 3.We believe that the proposed changes will not result in (1)a significant change in the types of effluents or a significant increase in the amounts of any effluents that may be released offsite, or (2)a significant increase in individual or cumulative occupational radiation exposure.These changes have been reviewed by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee. |
| ThesechangeshavebeenreviewedbythePlantNuclearSafetyReviewCommittee andbytheNuclearSafetyandDesignReviewCommittee.
| | In compliance with the requirements of 10CFR50.91(b)(1), copies of this letter and its attachments have been transmitted to Mr.J.R.Padgett of the Michigan Public Service Commission and to the Michigan Department of Public Health.9i03060047 910227 PDR ADOCK 05000315 P PDR Dr.T.E.Murley AEP:NRC:1036B This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned. |
| Incompliance withtherequirements of10CFR50.91(b)(1),
| | Sincerely, M.P.Alexich Vice President dfw cc: D.H.Williams, Jr.A, A, Blind-Bridgman J.R.Padgett G.Charnoff A.B.Davis'-Region III NRC Resident Inspector-Bridgman NFEM Section'Chief ATTACHMENT 1 TO AEP:NRC:1036B REASONS AND 10CFR50.92 ANALYSIS FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT TECHNICAL SPECIFICATIONS ATTACHMENT 1 TO AEP:NRC:1036B Page 2 We are proposing to add an exemption to the requirements of Technical Specification (T/S)3.0.4 for containment isolation valves required to be operable pursuant to T/S 3/4.6.3.1. |
| copiesofthisletteranditsattachments havebeentransmitted toMr.J.R.PadgettoftheMichiganPublicServiceCommission andtotheMichiganDepartment ofPublicHealth.9i03060047 910227PDRADOCK05000315PPDR Dr.T.E.MurleyAEP:NRC:1036B Thisdocumenthasbeenpreparedfollowing Corporate procedures thatincorporate areasonable setofcontrolstoensureitsaccuracyandcompleteness priortosignature bytheundersigned.
| | The T/S 3.0.4 exemption will allow mode change with inoperable containment isolation valves (provided the action requirements of the T/Ss are met).The action statement requirements of T/S 3.6.3.1 are that, within 4 hours, the valve must be restored to operable status or the affected penetration isolated by at least one deactivated automatic valve secured in the isolation position or at least one closed manual valve or blind flange.lf a valve is found inoperable in Mode 1, the affected penetration could simply be isolated and power operation could proceed (provided, of course, that the isolation of the penetration does not require entry into another T/Ss action statement because of impact on a particular-system's operability). |
| Sincerely, M.P.AlexichVicePresident dfwcc:D.H.Williams, Jr.A,A,Blind-BridgmanJ.R.PadgettG.CharnoffA.B.Davis'-RegionIIINRCResidentInspector | | However, if the problem surfaces in a mode other than Mode 1, the ascent to power operation is precluded because of the lack of an exemption of the requirements of T/S 3.0.4.This is an inconsistency in the T/Ss which is corrected by our proposed addition of the T/S 3.0.4 exemption. |
| -BridgmanNFEMSection'Chief ATTACHMENT 1TOAEP:NRC:1036B REASONSAND10CFR50.92 ANALYSISFORCHANGESTOTHEDONALDC.COOKNUCLEARPLANTTECHNICAL SPECIFICATIONS ATTACHMENT 1TOAEP:NRC:1036B Page2Weareproposing toaddanexemption totherequirements ofTechnical Specification (T/S)3.0.4forcontainment isolation valvesrequiredtobeoperablepursuanttoT/S3/4.6.3.1. | | From a safety perspective, assurance that the containment penetration is properly isolated is accomplished by following the action requirements of T/S 3.6.3.1.This is recognized by the present T/S, which allows continued operation in Mode 1 with an isolated penetration. |
| TheT/S3.0.4exemption willallowmodechangewithinoperable containment isolation valves(provided theactionrequirements oftheT/Ssaremet).Theactionstatement requirements ofT/S3.6.3.1arethat,within4hours,thevalvemustberestoredtooperablestatusortheaffectedpenetration isolatedbyatleastonedeactivated automatic valvesecuredintheisolation positionoratleastoneclosedmanualvalveorblindflange.lfavalveisfoundinoperable inMode1,theaffectedpenetration couldsimplybeisolatedandpoweroperation couldproceed(provided, ofcourse,thattheisolation ofthepenetration doesnotrequireentryintoanotherT/Ssactionstatement becauseofimpactonaparticular-system'soperability).
| | Problems with inconsistent application of T/S 3.0.4 exemptions were recognized by the NRC in Generic Letter 87-09.1n that generic letter, the staff stated: Specification 3.0.4...precludes entering a mode or specified condition if an LCO is not met, even if the Action Requirements would permit continued operation of the facility for an unlimited period of time.Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply.However, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well documented. |
| However,iftheproblemsurfacesinamodeotherthanMode1,theascenttopoweroperation isprecluded becauseofthelackofanexemption oftherequirements ofT/S3.0.4.Thisisaninconsistency intheT/Sswhichiscorrected byourproposedadditionoftheT/S3.0.4exemption. | | For example, approximately two-thirds of the actions which permit continued operation in the Westinghouse STS are exempt from Specification 3.0.4.Although the staff ATTACHMENT 1 TO AEP:NRC:1036B Page 3 encourages the maintenance of all plant systems and components in an operable condition as a good practice, the T/Ss generally have not precluded entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operation. |
| Fromasafetyperspective, assurance thatthecontainment penetration isproperlyisolatedisaccomplished byfollowing theactionrequirements ofT/S3.6.3.1.Thisisrecognized bythepresentT/S,whichallowscontinued operation inMode1withanisolatedpenetration.
| | Generic Letter 87-09 states that nothing in the staff's position discussed above"should be interpreted as endorsing or encouraging tha a plant startup with inoperable equipment. |
| Problemswithinconsistent application ofT/S3.0.4exemptions wererecognized bytheNRCinGenericLetter87-09.1nthatgenericletter,thestaffstated:Specification 3.0.4...precludes enteringamodeorspecified condition ifanLCOisnotmet,eveniftheActionRequirements wouldpermitcontinued operation ofthefacilityforanunlimited periodoftime.Generally, theindividual specifications thathaveActionRequirements whichallowcontinued operation notethatSpecification 3.0.4doesnotapply.However,exceptions toSpecification
| | The staff beli e eves at good practice should dictate that the plant startup should normally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rule." The following discussion describes the controls established at the Cook Nuclear Plant that address the NRC's concern.Control of maintenance at Cook Nuclear Plant is accomplished via Plant Manager Instruction (PMI)2290,"Job Orders." This instruction includes a prioritized system of control which divides corrective maintenance into prioritized categories with regard to urgency, and designates the individual or organization authorized to assign the job priority.The following summarizes the highlights of the corrective maintenance priorities: |
| | | Priorit-10 A job order specifying work that must be initiated and worked immediately to eliminate danger of personnel injury, damage to the facility, loss of generating capacity, or to protect the public health and safety.Priorit-20 A.A job order which specifies work that must be initiated promptly and which, if delayed beyond the time or event indicated, will seriously jeopardize plant operation. |
| ==3.0. 4havenotbeenconsistently==
| | B.A job order, which does not meet the criteria of priority 10, that concerns T/Ss-related equipment that has been declared inoperable and is in an action statement. |
| appliedandtheirbasesarenotwelldocumented.
| | ATTACHMENT 1 TO AEP:NRC: 1036B Page 4 C, A job order involving T/Ss-related equipment, failure of which will cause the initiation of an"event initiated" T/Ss surveillance requirement. |
| Forexample,approximately two-thirds oftheactionswhichpermitcontinued operation intheWestinghouse STSareexemptfromSpecification 3.0.4.Althoughthestaff ATTACHMENT 1TOAEP:NRC:1036B Page3encourages themaintenance ofallplantsystemsandcomponents inanoperablecondition asagoodpractice, theT/Ssgenerally havenotprecluded enteringamodewithinoperable equipment whentheActionRequirements includeremedialmeasuresthatprovideanacceptable levelofsafetyforcontinued operation.
| | k~Pri ori t-30 A.A job order on T/Ss-related or safety-related equipment that, by definition, does not fit into Priority 10 or 20.B.A job order that does not fit into Priority 10 or 20 but is listed in the Control Room Open items listing.Maintenance job orders written to repair inoperable equipment that is required by the T/Ss to be operable will receive a Priority 10 or 20.Priority 10 is reserved for items of an immediate safety or plant availability concern and requires action to begin immediately and to continue on a 24-hour basis until the problem is under control.Priority 10 maintenance orders are rarel written.Therefore, Priority 20 maintenance job orders are generally the highest priority to be worked.This ensures that maintenance work to satisfy an LCO receives high priority.The following are the controls currently in place to ensure that mode changes do not occur with an LCO in a degraded mode without the required review and approval: Syc>,I 4tj~,li 1.The"Plant Heatup From Cold Shutdown to Hot Standb" an y procedure (OHP 4021.001.001) and the"Reactor Startup Procedure" (OHP 4021.001.002) require signoff by the responsible department heads that all T/Ss surveillance requirements for the mode to be entered have been completed. |
| GenericLetter87-09statesthatnothinginthestaff'spositiondiscussed above"shouldbeinterpreted asendorsing orencouraging thaaplantstartupwithinoperable equipment.
| | Entry into Modes 4 and 3 requires an Equipment Checklist to be completed and signed off by a supervisor and entry into Mode 3 requires a review of the following logs with respect to Mode 3 T/Ss and other administrative requirements. |
| Thestaffbelieevesatgoodpracticeshoulddictatethattheplantstartupshouldnormallybeinitiated onlywhenallrequiredequipment isoperableandthatstartupwithinoperable equipment mustbetheexception ratherthantherule."Thefollowing discussion describes thecontrolsestablished attheCookNuclearPlantthataddresstheNRC'sconcern.Controlofmaintenance atCookNuclearPlantisaccomplished viaPlantManagerInstruction (PMI)2290,"JobOrders."Thisinstruction includesaprioritized systemofcontrolwhichdividescorrective maintenance intoprioritized categories withregardtourgency,anddesignates theindividual ororganization authorized toassignthejobpriority.
| | ATTACHMENT 1 TO AEP:NRC:1036B Page 5 o Temporary modification'log book o Control room surveillance book o Control room log o Shift supervisor's log o T/S open items log o Clearance permit log o Caution tag log o Non T/Ss-related equipment status log 2.Per PMI-4030,"Technical Specifications Review and Surveillance," mode changes while in a T/Ss action statement, when permitted by T/S 3.0.4, can only be made after review and approval by the operations department superintendent and the plant manager.Efforts to return the equipment to operability will continue unaffected by the mode change.The above-described administrative controls to limit the use of T/S 3.0.4 exceptions are currently in place.Our plant operators are aware of and have been instructed in the controls established to limit the use of the 3.0.4 exceptions. |
| Thefollowing summarizes thehighlights ofthecorrective maintenance priorities:
| | 10CFR50.92 Evaluation Per 10CFR50.92, a proposed amendment will not involve a significant hazards consideration if the proposed amendment does not: 1)Involve a significant increase in the probability or consequences of an accident previously analyzed, 2)Create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated, or 3)Involve a significant reduction in a margin of safety.Criterion 1 Adequate isolation of affected containment penetrations is ensured by following the requirements of the action statement in T/S 3.6.3.1.This requires the penetration be isolated by at J'f W Pg Jl' ATTACHMENT 1 TO AEP:NRC:1036B Page 6 least one deactivated automatic valve secured in the isolation position or by use of at least one closed manual valve or blind flange.Continued power operation is permitted in Mode 1 with an inoperable containment isolation valve provided 0he requirements of the action statement are followed.The T/Ss requirements are inconsistent, however, in that mode change is prohibited even though continuous power operation is permitted. |
| Priorit-10Ajoborderspecifying workthatmustbeinitiated andworkedimmediately toeliminate dangerofpersonnel injury,damagetothefacility, lossofgenerating | | Since the T/Ss action requirements specify an adequate level of protection, we believe the change does not involve a significant increase in the probability or consequences of an accident previously analyzed.Criterion 2 The change involves no physical modifications to Cook Nuclear Plant, nor any changes in the design basis.The change should not, therefore, create the possibility of a new or different kind of accident from any previously analyzed or evaluated. |
| : capacity, ortoprotectthepublichealthandsafety.Priorit-20A.Ajoborderwhichspecifies workthatmustbeinitiated promptlyandwhich,ifdelayedbeyondthetimeoreventindicated, willseriously jeopardize plantoperation.
| | Criterion 3 Adequate isolation of affected containment penetrations is ensured by following the requirements of the T/S 3.6.3.1 action statement. |
| B.Ajoborder,whichdoesnotmeetthecriteriaofpriority10,thatconcernsT/Ss-related equipment thathasbeendeclaredinoperable andisinanactionstatement. | | This requires the penetration to be isolated by at least one deactivated automatic valve secured in the isolation position or by use of at least one closed manual valve or blind flange.Continued power operation is permitted in Mode 1 with an of th inoperable containment isolation valve, provided the requirem t o e action statement are followed.The T/Ss requirements are iremen s inconsistent, however, in that mode change is prohibited even though continuous power operation is permitted. |
| ATTACHMENT 1TOAEP:NRC:1036BPage4C,Ajoborderinvolving T/Ss-related equipment, failureofwhichwillcausetheinitiation ofan"eventinitiated" T/Sssurveillance requirement. | | Since the T/Ss action requirements specify an adequate level of protection, we'believe the change will not involve a significant reduction in a margin of safety.The Commission has provided guidance concerning the determination of significant hazards by providing examples (48FR14870) of amendments considered not likely to involve significant hazards consideration. |
| k~Priorit-30A.AjoborderonT/Ss-related orsafety-related equipment that,bydefinition, doesnotfitintoPriority10or20.B.AjoborderthatdoesnotfitintoPriority10or20butislistedintheControlRoomOpenitemslisting.Maintenance joborderswrittentorepairinoperable equipment thatisrequiredbytheT/SstobeoperablewillreceiveaPriority10or20.Priority10isreservedforitemsofanimmediate safetyorplantavailability concernandrequiresactiontobeginimmediately andtocontinueona24-hourbasisuntiltheproblemisundercontrol.Priority10maintenance ordersarerarelwritten.Therefore, Priority20maintenance jobordersaregenerally thehighestprioritytobeworked.Thisensuresthatmaintenance worktosatisfyanLCOreceiveshighpriority. | | The first example refers to changes that are administrative in nature: for example, a change to achieve consistency throughout the technical specifications. |
| Thefollowing arethecontrolscurrently inplacetoensurethatmodechangesdonotoccurwithanLCOinadegradedmodewithouttherequiredreviewandapproval:
| | Although this change is not purely administrative in nature, it is related to this example in that it achieves consistency within T/S 3.6.3.1 in that mode change is not precluded, consistent with the allowance of continuous power operation in Mode 1.The sixth example refers to a change which may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results ATTACHMENT 1 TO AEP:NRC:1036B Page 7 of the change are clearly within limits established as acceptable. |
| Syc>,I4tj~,li1.The"PlantHeatupFromColdShutdowntoHotStandb"anyprocedure (OHP4021.001.001) andthe"ReactorStartupProcedure" (OHP4021.001.002) requiresignoffbytheresponsible department headsthatallT/Sssurveillance requirements forthemodetobeenteredhavebeencompleted. | | Problems with inconsistent application of T/S 3.0.4 exemptions have been noted previously by the NRC in Generic Letter 87-09.The acceptability of continuous power operation with containment penetrations isolated per the action statement requirements has already been established. |
| EntryintoModes4and3requiresanEquipment Checklist tobecompleted andsignedoffbyasupervisor andentryintoMode3requiresareviewofthefollowing logswithrespecttoMode3T/Ssandotheradministrative requirements.
| | This change only extends that acceptability to'allow mode change.Thus, we conclude that the sixth example is applicable to this change.}} |
| ATTACHMENT 1TOAEP:NRC:1036B Page5oTemporary modification'log bookoControlroomsurveillance bookoControlroomlogoShiftsupervisor's logoT/SopenitemslogoClearance permitlogoCautiontaglogoNonT/Ss-related equipment statuslog2.PerPMI-4030, "Technical Specifications ReviewandSurveillance," | |
| modechangeswhileinaT/Ssactionstatement, whenpermitted byT/S3.0.4,canonlybemadeafterreviewandapprovalbytheoperations department superintendent andtheplantmanager.Effortstoreturntheequipment tooperability willcontinueunaffected bythemodechange.Theabove-described administrative controlstolimittheuseofT/S3.0.4exceptions arecurrently inplace.Ourplantoperators areawareofandhavebeeninstructed inthecontrolsestablished tolimittheuseofthe3.0.4exceptions.
| |
| 10CFR50.92 Evaluation Per10CFR50.92, aproposedamendment willnotinvolveasignificant hazardsconsideration iftheproposedamendment doesnot:1)Involveasignificant increaseintheprobability orconsequences ofanaccidentpreviously | |
| : analyzed, 2)Createthepossibility ofanewordifferent kindofaccidentfromanyaccidentpreviously analyzedorevaluated, or3)Involveasignificant reduction inamarginofsafety.Criterion 1Adequateisolation ofaffectedcontainment penetrations isensuredbyfollowing therequirements oftheactionstatement inT/S3.6.3.1.Thisrequiresthepenetration beisolatedbyat J'fWPgJl' ATTACHMENT 1TOAEP:NRC:1036B Page6leastonedeactivated automatic valvesecuredintheisolation positionorbyuseofatleastoneclosedmanualvalveorblindflange.Continued poweroperation ispermitted inMode1withaninoperable containment isolation valveprovided0herequirements oftheactionstatement arefollowed.
| |
| TheT/Ssrequirements areinconsistent, however,inthatmodechangeisprohibited eventhoughcontinuous poweroperation ispermitted.
| |
| SincetheT/Ssactionrequirements specifyanadequatelevelofprotection, webelievethechangedoesnotinvolveasignificant increaseintheprobability orconsequences ofanaccidentpreviously analyzed.
| |
| Criterion 2Thechangeinvolvesnophysicalmodifications toCookNuclearPlant,noranychangesinthedesignbasis.Thechangeshouldnot,therefore, createthepossibility ofanewordifferent kindofaccidentfromanypreviously analyzedorevaluated. | |
| Criterion 3Adequateisolation ofaffectedcontainment penetrations isensuredbyfollowing therequirements oftheT/S3.6.3.1actionstatement. | |
| Thisrequiresthepenetration tobeisolatedbyatleastonedeactivated automatic valvesecuredintheisolation positionorbyuseofatleastoneclosedmanualvalveorblindflange.Continued poweroperation ispermitted inMode1withanofthinoperable containment isolation valve,providedtherequiremtoeactionstatement arefollowed.
| |
| TheT/Ssrequirements areiremensinconsistent, however,inthatmodechangeisprohibited eventhoughcontinuous poweroperation ispermitted.
| |
| SincetheT/Ssactionrequirements specifyanadequatelevelofprotection, we'believethechangewillnotinvolveasignificant reduction inamarginofsafety.TheCommission hasprovidedguidanceconcerning thedetermination ofsignificant hazardsbyproviding examples(48FR14870) ofamendments considered notlikelytoinvolvesignificant hazardsconsideration.
| |
| Thefirstexamplereferstochangesthatareadministrative innature:forexample,achangetoachieveconsistency throughout thetechnical specifications.
| |
| Althoughthischangeisnotpurelyadministrative innature,itisrelatedtothisexampleinthatitachievesconsistency withinT/S3.6.3.1inthatmodechangeisnotprecluded, consistent withtheallowance ofcontinuous poweroperation inMode1.Thesixthexamplereferstoachangewhichmayresultinsomeincreasetotheprobability orconsequences ofapreviously analyzedaccidentormayreduceinsomewayasafetymargin,butwheretheresults ATTACHMENT 1TOAEP:NRC:1036B Page7ofthechangeareclearlywithinlimitsestablished asacceptable.
| |
| Problemswithinconsistent application ofT/S3.0.4exemptions havebeennotedpreviously bytheNRCinGenericLetter87-09.Theacceptability ofcontinuous poweroperation withcontainment penetrations isolatedpertheactionstatement requirements hasalreadybeenestablished.
| |
| Thischangeonlyextendsthatacceptability to'allowmodechange.Thus,weconcludethatthesixthexampleisapplicable tothischange.}}
| |
Similar Documents at Cook |
---|
Category:OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING
MONTHYEARML17335A5551999-10-12012 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.6.2.2.d for Spray Additive Sys to Relocate Details Associated with Acceptance Criteria & Test Parameters to Associated TS Bases ML17335A5591999-10-11011 October 1999 Supplement to Application for Amends to Licenses DPR-58 & DPR-74,replacing Correct TS Pages Inadvertently Included in 990923 Submittal.Attached Pages Also Include Appropriate Administrative Changes ML17335A5411999-10-0101 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Containment Recirculation Sump Water Inventory.Calculation & non-proprietary WCAP-15302 Rept Also Encl ML17326A1571999-09-23023 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,involving Movement of Loads in Excess of Design Basis Seismic Capability of Auxiliary Bldg Load Handling Equipment & Structures ML17326A1421999-09-17017 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,to Allow Credit of Rod Cluster Control Assemblies for Cold Leg Large Break LOCA Subcriticality.Ts Pages & non-proprietary Versions of WCAP-15246 Encl.Proprietary Version Withheld ML17326A1161999-09-10010 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.4.7,TS Tables 4.4-3,3.4-1 & TS Surveillance Requirement 4.11.2.2 Re RCS & Gas Storage Tank Sampling ML17326A0921999-08-17017 August 1999 Application for Amend to License DPR-58,to Change TS 3/4.4.5 & Bases for TS 3/4.4.5,3/4.4.6.2 & 3/4.4.8 to Remove voltage-based Repair Criteria,F* Repair Criteria & Sleeving Methodologies from Unit 1 TS & Clarify Bases Sections ML17325B6041999-05-21021 May 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Limitations of Positive Reactivity Additions in Several TS Action Statements ML17325B5511999-04-19019 April 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3/4.8.1.2, Electrical Power Systems & Associated Bases to Provide one-time Extension of 18-month Surveillance Interval for Specific SRs ML17335A3661998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,adding TS for Distributed Ignition Sys ML17335A3631998-12-0303 December 1998 Application for Amend to License DPR-58,revising TS 3/4.7.7, Sealed Source Contamination & Associated Bases to Address Testing Requirements for Fission Detectors ML17335A3591998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,making Administrative Changes to Remove Obsolete Info,To Provide Consistency Between Units 1 & 2,to Provide Consistency with Std Tech Specs,To Provide Clarification & to Correct Typos ML17335A3561998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.6.5.1, Ice Condenser,Ice Bed & Associated Bases to Reflect Max Ice Condenser Flow Channel Blockage Assumed in Accident Analyses ML17335A2631998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Containment Sys Bases 3/4.6.1.4 Re Internal Pressure & 3/4.6.1.5 Re Air Temp ML17335A2761998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,placing Tighter Restrictions on Amount of Time RWST Water Level Instrumentation Can Be Out of Svc Before Compensatory Actions Are Required ML17335A2671998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3.4.1.3, RCS - Shutdown & Associated Bases to Provide Separate Requirements for Modes 4 & 5 with Loops Filled & Mode 5 with Loops Not Filled ML17335A2311998-09-14014 September 1998 Application for Amends to Licenses DPR-58 & DPR-74,changing Runout Limits for Safety Injection Pump to 675 Gpm Unless Pump Is Specifically Tested to Higher Flow Rate Not Exceeding 700 Gpm ML17335A1901998-08-28028 August 1998 Application for Amend to License DPR-58,requesting Extension of SG Surveillance,Which TSs Require to Be Performed on or Before 990408,until End of Current Refuel Cycle Currently Scheduled for Mar 2000.W/assessment of SG Degradation & TSs ML17334A7471998-06-10010 June 1998 Application for Amends to Licenses DPR-54 & DPR-78,changing Implementation Date to Reduce Boric Acid Concentration in Boric Acid Storage Sys.Attachment 1 to Ltr Contains Description of Proposed Change & Justification for Change ML17334B7011998-03-0303 March 1998 Application for Amends to TS for Licenses DPR-58 & DPR-74, Removing Word Immediately from Unit 1 Hydrogen Recombiner Surveillance Requirement 4.6.4.2.b.4 & Revising Plants TS 3/4.6.4 Bases ML17334B6561997-10-0808 October 1997 Application for Amends to Licenses DPR-58 & DPR-78,changing TSs 3/4.6.5 & 3/4.5.5 to Increase Both Minimum Required Ice Mass Per Ice Basket & Total Minimum Required Ice Mass. Proprietary Summary of Sump Inventory Calculations,Encl ML17333B0431997-09-19019 September 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Requirement for Automatic Valve Closure Feature on RHR Sys Suction from RCS ML17333A9831997-08-11011 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,allowing Filling of ECCS Accumulators W/O Declaring ECCS Equipment Inoperable ML17335A2101997-08-0101 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Wording When Secondary Steam Supply Pressure Is Greater than 310 Psig from TS ML17333A8281997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74, Modifying TS 4.7.5.1.e.2 Which Describes Control Room Ventilation Sys Autostart Functions ML17333A8311997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74,changing Grammatical Correction to Wording of Unit 2 TS 3.4.8,Action a for Modes 1,2 & 3 & Returning Frequency Requirement to TS 4.7.1.2.c & 4.7.1.2.d That Was Inadvertently Deleted ML17333A7121996-12-20020 December 1996 Application for Amends to Licenses DPR-58 & DPR-74, Requesting Rev of Reactor Coolant Pump Flywheel Insp Frequency ML17334B5941996-07-11011 July 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Support Operation of Unit 2 at Increased Core Rated Thermal Power of 3,588 Mwt.Rev 1 to WCAP-14489, ...Unit 2 3,600 Mwt Uprating Program Licensing Rept Encl ML17334B5901996-06-19019 June 1996 Application for Amend to License DPR-58,addressing Applicable Requirements of NRC GL 95-05, Voltage-Based Repair Criteria for Repair of Westinghouse SG Tubes Affected by Outside Diameter Stress Corrosion Cracking. ML17334B5891996-06-11011 June 1996 Application for Amends to Licenses DPR-58 & DPR-74,removing TSs Certain Requirements for Administrative Controls,Related to QA Requirements,Per Administrative Ltr 96-05 ML17333A4201996-04-0808 April 1996 Application for Amends to Licenses DPR-58 & DPR-74,moving TS 4.0.4 Exemption Statement for MSSVs Into Section 4.7.1.1 ML17333A3551996-03-12012 March 1996 Application for Amend to License DPR-74,removing TSs Re Shutdown & Control Rod Position Indication While in Modes 3, 4 & 5 ML17334B5751996-02-29029 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Reduce Boric Acid Concentration in Boric Acid Storage Sys from Approx 12 Percent to Approx 4 Percent by Weight. Technical Rept Presenting Justificaion for Changes Encl ML17334B5741996-02-26026 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.6.2 to Increase Current Limit on Nominal Fuel Assembly Enrichment for New,Westinghouse - Fabricated Fuel Stored in New Fuel Storage Racks ML17333A3201996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Remove Requirement That Operations Superintendent Must Hold or Have Held Sol at Plant or Similar Reactor ML17333A3151996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying Table 4.8-1,DG Test Schedule by Ref Rg 1.9,Rev 3 Rather than Rg 1.108,Rev 1 Criteria for Determination of Valid DG Test ML17333A2641996-01-12012 January 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Section 4.4.11 to Eliminate SR Demonstrating Operability of Emergency Power Supply for Pressurizer PORVs & Block Valves ML17333A2391995-12-19019 December 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 3/4.6.1.2,3/4.6.1.3,3/4.6.1.6 & 3/4.6.1.6 to Require Types A,B & C Tests (Overall Integrated & Local Containment Leakage Rate) to Be Performed Per 10CFR50,App J Option B ML17332B0111995-11-10010 November 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising Ts,By Modifying Surveillance Testing of EDG During Refueling & Normal Operations ML17332A9971995-10-20020 October 1995 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Add Exemption to TS 4.0.4 in Surveillance Requirements for MSIV ML17332A9111995-08-0606 August 1995 Application for Amends to Licenses DPR-58 & DPR-74,informing That Licensee Has 45 Days from Date of Issuance to Implement Amend Unless Otherwise Specified ML17334B5561995-08-0404 August 1995 Application for Exigent Amend to License DPR-58,modifying TS 4.4.5.4 & 4.4.5.5 for Repair of Hybrid Expansion Joint Sleeved SG Tubes.Proprietary W Rept WCAP-14446, Repair...Of Hybrid Expansion Joint...Tubes Encl.W Rept Withheld ML17332A8271995-06-30030 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,changing TS Section 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02, Suppl 1 ML17334B5501995-06-20020 June 1995 License Amend Request to Licenses DPR-58 & DPR-74,to Remove Requirements for Fire Protection Systems from Licenses & Guidance in GL 86-10,GL 88-12 & GL 93-07 ML17332A7991995-06-15015 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.8.1.1.2.e.7 to Reduce Duration of Surveillance Testing for EDGs During Refueling Operations from 24 H to 8 H ML17334B5481995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Support Operation of Unit 1 at SG Tube Plugging Levels Up to 30%,make One Unit 1 TS More Nearly Like Corresponding Unit 2 TS & Maintain Consistency of Unit 2 Criteria ML17334B5461995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying Tech Specs 3/4.3.1 (Reactor Trip Sys Instrumentation) & 3/4.3.2 (ESFAS Instrumentation) & Bases to Relocate Tables of Response Time Limits to Ufsar,Per GL 93-08 ML17332A7661995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty ML17332A7741995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02,Suppl 1 ML17332A7771995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Table 4.3-2 to Change Main Steam Line Isolation Valve Manual Actuation Sys Surveillance Frequency from Monthly to Quarterly 1999-09-23
[Table view] Category:TEXT-LICENSE APPLICATIONS & PERMITS
MONTHYEARML17335A5551999-10-12012 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.6.2.2.d for Spray Additive Sys to Relocate Details Associated with Acceptance Criteria & Test Parameters to Associated TS Bases ML17335A5591999-10-11011 October 1999 Supplement to Application for Amends to Licenses DPR-58 & DPR-74,replacing Correct TS Pages Inadvertently Included in 990923 Submittal.Attached Pages Also Include Appropriate Administrative Changes ML17335A5411999-10-0101 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Containment Recirculation Sump Water Inventory.Calculation & non-proprietary WCAP-15302 Rept Also Encl ML17326A1571999-09-23023 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,involving Movement of Loads in Excess of Design Basis Seismic Capability of Auxiliary Bldg Load Handling Equipment & Structures ML17326A1421999-09-17017 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,to Allow Credit of Rod Cluster Control Assemblies for Cold Leg Large Break LOCA Subcriticality.Ts Pages & non-proprietary Versions of WCAP-15246 Encl.Proprietary Version Withheld ML17326A1161999-09-10010 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.4.7,TS Tables 4.4-3,3.4-1 & TS Surveillance Requirement 4.11.2.2 Re RCS & Gas Storage Tank Sampling ML17326A0921999-08-17017 August 1999 Application for Amend to License DPR-58,to Change TS 3/4.4.5 & Bases for TS 3/4.4.5,3/4.4.6.2 & 3/4.4.8 to Remove voltage-based Repair Criteria,F* Repair Criteria & Sleeving Methodologies from Unit 1 TS & Clarify Bases Sections ML17325B6041999-05-21021 May 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Limitations of Positive Reactivity Additions in Several TS Action Statements ML17325B5511999-04-19019 April 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3/4.8.1.2, Electrical Power Systems & Associated Bases to Provide one-time Extension of 18-month Surveillance Interval for Specific SRs ML17335A3661998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,adding TS for Distributed Ignition Sys ML17335A3631998-12-0303 December 1998 Application for Amend to License DPR-58,revising TS 3/4.7.7, Sealed Source Contamination & Associated Bases to Address Testing Requirements for Fission Detectors ML17335A3591998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,making Administrative Changes to Remove Obsolete Info,To Provide Consistency Between Units 1 & 2,to Provide Consistency with Std Tech Specs,To Provide Clarification & to Correct Typos ML17335A3561998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.6.5.1, Ice Condenser,Ice Bed & Associated Bases to Reflect Max Ice Condenser Flow Channel Blockage Assumed in Accident Analyses ML17335A2631998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Containment Sys Bases 3/4.6.1.4 Re Internal Pressure & 3/4.6.1.5 Re Air Temp ML17335A2761998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,placing Tighter Restrictions on Amount of Time RWST Water Level Instrumentation Can Be Out of Svc Before Compensatory Actions Are Required ML17335A2671998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3.4.1.3, RCS - Shutdown & Associated Bases to Provide Separate Requirements for Modes 4 & 5 with Loops Filled & Mode 5 with Loops Not Filled ML17335A2311998-09-14014 September 1998 Application for Amends to Licenses DPR-58 & DPR-74,changing Runout Limits for Safety Injection Pump to 675 Gpm Unless Pump Is Specifically Tested to Higher Flow Rate Not Exceeding 700 Gpm ML17335A1901998-08-28028 August 1998 Application for Amend to License DPR-58,requesting Extension of SG Surveillance,Which TSs Require to Be Performed on or Before 990408,until End of Current Refuel Cycle Currently Scheduled for Mar 2000.W/assessment of SG Degradation & TSs ML17334A7471998-06-10010 June 1998 Application for Amends to Licenses DPR-54 & DPR-78,changing Implementation Date to Reduce Boric Acid Concentration in Boric Acid Storage Sys.Attachment 1 to Ltr Contains Description of Proposed Change & Justification for Change ML17334B7011998-03-0303 March 1998 Application for Amends to TS for Licenses DPR-58 & DPR-74, Removing Word Immediately from Unit 1 Hydrogen Recombiner Surveillance Requirement 4.6.4.2.b.4 & Revising Plants TS 3/4.6.4 Bases ML17334B6561997-10-0808 October 1997 Application for Amends to Licenses DPR-58 & DPR-78,changing TSs 3/4.6.5 & 3/4.5.5 to Increase Both Minimum Required Ice Mass Per Ice Basket & Total Minimum Required Ice Mass. Proprietary Summary of Sump Inventory Calculations,Encl ML17333B0431997-09-19019 September 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Requirement for Automatic Valve Closure Feature on RHR Sys Suction from RCS ML17333A9831997-08-11011 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,allowing Filling of ECCS Accumulators W/O Declaring ECCS Equipment Inoperable ML17335A2101997-08-0101 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Wording When Secondary Steam Supply Pressure Is Greater than 310 Psig from TS ML17333A8281997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74, Modifying TS 4.7.5.1.e.2 Which Describes Control Room Ventilation Sys Autostart Functions ML17333A8311997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74,changing Grammatical Correction to Wording of Unit 2 TS 3.4.8,Action a for Modes 1,2 & 3 & Returning Frequency Requirement to TS 4.7.1.2.c & 4.7.1.2.d That Was Inadvertently Deleted ML17333A7121996-12-20020 December 1996 Application for Amends to Licenses DPR-58 & DPR-74, Requesting Rev of Reactor Coolant Pump Flywheel Insp Frequency ML17334B5941996-07-11011 July 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Support Operation of Unit 2 at Increased Core Rated Thermal Power of 3,588 Mwt.Rev 1 to WCAP-14489, ...Unit 2 3,600 Mwt Uprating Program Licensing Rept Encl ML17334B5901996-06-19019 June 1996 Application for Amend to License DPR-58,addressing Applicable Requirements of NRC GL 95-05, Voltage-Based Repair Criteria for Repair of Westinghouse SG Tubes Affected by Outside Diameter Stress Corrosion Cracking. ML17334B5891996-06-11011 June 1996 Application for Amends to Licenses DPR-58 & DPR-74,removing TSs Certain Requirements for Administrative Controls,Related to QA Requirements,Per Administrative Ltr 96-05 ML17333A4201996-04-0808 April 1996 Application for Amends to Licenses DPR-58 & DPR-74,moving TS 4.0.4 Exemption Statement for MSSVs Into Section 4.7.1.1 ML17333A3551996-03-12012 March 1996 Application for Amend to License DPR-74,removing TSs Re Shutdown & Control Rod Position Indication While in Modes 3, 4 & 5 ML17334B5751996-02-29029 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Reduce Boric Acid Concentration in Boric Acid Storage Sys from Approx 12 Percent to Approx 4 Percent by Weight. Technical Rept Presenting Justificaion for Changes Encl ML17334B5741996-02-26026 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.6.2 to Increase Current Limit on Nominal Fuel Assembly Enrichment for New,Westinghouse - Fabricated Fuel Stored in New Fuel Storage Racks ML17333A3201996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Remove Requirement That Operations Superintendent Must Hold or Have Held Sol at Plant or Similar Reactor ML17333A3151996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying Table 4.8-1,DG Test Schedule by Ref Rg 1.9,Rev 3 Rather than Rg 1.108,Rev 1 Criteria for Determination of Valid DG Test ML17333A2641996-01-12012 January 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Section 4.4.11 to Eliminate SR Demonstrating Operability of Emergency Power Supply for Pressurizer PORVs & Block Valves ML17333A2391995-12-19019 December 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 3/4.6.1.2,3/4.6.1.3,3/4.6.1.6 & 3/4.6.1.6 to Require Types A,B & C Tests (Overall Integrated & Local Containment Leakage Rate) to Be Performed Per 10CFR50,App J Option B ML17332B0111995-11-10010 November 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising Ts,By Modifying Surveillance Testing of EDG During Refueling & Normal Operations ML17332A9971995-10-20020 October 1995 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Add Exemption to TS 4.0.4 in Surveillance Requirements for MSIV ML17332A9111995-08-0606 August 1995 Application for Amends to Licenses DPR-58 & DPR-74,informing That Licensee Has 45 Days from Date of Issuance to Implement Amend Unless Otherwise Specified ML17334B5561995-08-0404 August 1995 Application for Exigent Amend to License DPR-58,modifying TS 4.4.5.4 & 4.4.5.5 for Repair of Hybrid Expansion Joint Sleeved SG Tubes.Proprietary W Rept WCAP-14446, Repair...Of Hybrid Expansion Joint...Tubes Encl.W Rept Withheld ML17332A8271995-06-30030 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,changing TS Section 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02, Suppl 1 ML17334B5501995-06-20020 June 1995 License Amend Request to Licenses DPR-58 & DPR-74,to Remove Requirements for Fire Protection Systems from Licenses & Guidance in GL 86-10,GL 88-12 & GL 93-07 ML17332A7991995-06-15015 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.8.1.1.2.e.7 to Reduce Duration of Surveillance Testing for EDGs During Refueling Operations from 24 H to 8 H ML17334B5481995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Support Operation of Unit 1 at SG Tube Plugging Levels Up to 30%,make One Unit 1 TS More Nearly Like Corresponding Unit 2 TS & Maintain Consistency of Unit 2 Criteria ML17334B5461995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying Tech Specs 3/4.3.1 (Reactor Trip Sys Instrumentation) & 3/4.3.2 (ESFAS Instrumentation) & Bases to Relocate Tables of Response Time Limits to Ufsar,Per GL 93-08 ML17332A7661995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty ML17332A7741995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02,Suppl 1 ML17332A7771995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Table 4.3-2 to Change Main Steam Line Isolation Valve Manual Actuation Sys Surveillance Frequency from Monthly to Quarterly 1999-09-23
[Table view] |
Text
.ACCELERATED DI RIBUTION DEMONST TION SYSTEM v~~p REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS).ACCESSION NBR:9103060047 DOC.DATE: 91/02/27 NOTARIZED:
NO DOCKET g FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana&05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
Indiana Michigan Power Co.(formerly Indiana 6 Michigan Ele RECXP.NAME RECIPXENT AFFILIATION R MURLEY,T.E.
Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to Licenses DPR-58 6 DPR-74,modifying Tech Spec Section 3.6.3.1 re containment isolation valves to provide exemption from requirements of Tech Spec 3.0.4 under certain circumstances.
DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR t ENCL L SIZE: TITLE: OR Submittal:
General Distribution NOTES I I D A RECIPIENT ID CODE/NAME PD3-1 LA COLBURN,T.
INTERNAL: NRR/DET/ECMB 9H NRR/DOEA/OTS B1 1 NRR/DST/SELB 8D NRR/DST/SRXB 8E OC G F 01 EXTERNAL: NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 0 1 1 1 1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS2 RES/DSIR/EIB NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 0 1 1 1 1 D 1 S I D NOTE TO ALL"RIDS" RECIPIENTS:
D D PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL 16 t
Indiana Michigan Power Company P.O.Box 16631 Columbus, OH 43216 IIHSMSIHSl PvZCNEGQH PQWM AEP: NRC: 1036B Donald C.Cook Nuclear Plant Units 1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 TECHNICAL SPECIFICATION 3'.4 EXEMPTION FOR CONTAINMENT ISOLATION VALVES U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Attn: T.E.Murley February 27, 199l
Dear Dr.Murley:
This letter and its attachments constitute an application for amendment to the Technical Specifications (T/Ss)for the Donald C.Cook Nuclear Plant Units 1 and 2.Specifically, we propose to~modify Section 3.6.3.1 (Containment Isolation Valves)to provide an exemption to the requirements of T/S 3.0.4 under certain circumstances.
Our reasons for the proposed changes, as well as our analyses concerning significant hazards considerations, are contained in Attachment 1 to this letter, The proposed revised T/Ss pages are contained in Attachment 2.The current T/Ss marked-up to reflect the proposed changes are contained in Attachment 3.We believe that the proposed changes will not result in (1)a significant change in the types of effluents or a significant increase in the amounts of any effluents that may be released offsite, or (2)a significant increase in individual or cumulative occupational radiation exposure.These changes have been reviewed by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee.
In compliance with the requirements of 10CFR50.91(b)(1), copies of this letter and its attachments have been transmitted to Mr.J.R.Padgett of the Michigan Public Service Commission and to the Michigan Department of Public Health.9i03060047 910227 PDR ADOCK 05000315 P PDR Dr.T.E.Murley AEP:NRC:1036B This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M.P.Alexich Vice President dfw cc: D.H.Williams, Jr.A, A, Blind-Bridgman J.R.Padgett G.Charnoff A.B.Davis'-Region III NRC Resident Inspector-Bridgman NFEM Section'Chief ATTACHMENT 1 TO AEP:NRC:1036B REASONS AND 10CFR50.92 ANALYSIS FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT TECHNICAL SPECIFICATIONS ATTACHMENT 1 TO AEP:NRC:1036B Page 2 We are proposing to add an exemption to the requirements of Technical Specification (T/S)3.0.4 for containment isolation valves required to be operable pursuant to T/S 3/4.6.3.1.
The T/S 3.0.4 exemption will allow mode change with inoperable containment isolation valves (provided the action requirements of the T/Ss are met).The action statement requirements of T/S 3.6.3.1 are that, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the valve must be restored to operable status or the affected penetration isolated by at least one deactivated automatic valve secured in the isolation position or at least one closed manual valve or blind flange.lf a valve is found inoperable in Mode 1, the affected penetration could simply be isolated and power operation could proceed (provided, of course, that the isolation of the penetration does not require entry into another T/Ss action statement because of impact on a particular-system's operability).
However, if the problem surfaces in a mode other than Mode 1, the ascent to power operation is precluded because of the lack of an exemption of the requirements of T/S 3.0.4.This is an inconsistency in the T/Ss which is corrected by our proposed addition of the T/S 3.0.4 exemption.
From a safety perspective, assurance that the containment penetration is properly isolated is accomplished by following the action requirements of T/S 3.6.3.1.This is recognized by the present T/S, which allows continued operation in Mode 1 with an isolated penetration.
Problems with inconsistent application of T/S 3.0.4 exemptions were recognized by the NRC in Generic Letter 87-09.1n that generic letter, the staff stated: Specification 3.0.4...precludes entering a mode or specified condition if an LCO is not met, even if the Action Requirements would permit continued operation of the facility for an unlimited period of time.Generally, the individual specifications that have Action Requirements which allow continued operation note that Specification 3.0.4 does not apply.However, exceptions to Specification 3.0.4 have not been consistently applied and their bases are not well documented.
For example, approximately two-thirds of the actions which permit continued operation in the Westinghouse STS are exempt from Specification 3.0.4.Although the staff ATTACHMENT 1 TO AEP:NRC:1036B Page 3 encourages the maintenance of all plant systems and components in an operable condition as a good practice, the T/Ss generally have not precluded entering a mode with inoperable equipment when the Action Requirements include remedial measures that provide an acceptable level of safety for continued operation.
Generic Letter 87-09 states that nothing in the staff's position discussed above"should be interpreted as endorsing or encouraging tha a plant startup with inoperable equipment.
The staff beli e eves at good practice should dictate that the plant startup should normally be initiated only when all required equipment is operable and that startup with inoperable equipment must be the exception rather than the rule." The following discussion describes the controls established at the Cook Nuclear Plant that address the NRC's concern.Control of maintenance at Cook Nuclear Plant is accomplished via Plant Manager Instruction (PMI)2290,"Job Orders." This instruction includes a prioritized system of control which divides corrective maintenance into prioritized categories with regard to urgency, and designates the individual or organization authorized to assign the job priority.The following summarizes the highlights of the corrective maintenance priorities:
Priorit-10 A job order specifying work that must be initiated and worked immediately to eliminate danger of personnel injury, damage to the facility, loss of generating capacity, or to protect the public health and safety.Priorit-20 A.A job order which specifies work that must be initiated promptly and which, if delayed beyond the time or event indicated, will seriously jeopardize plant operation.
B.A job order, which does not meet the criteria of priority 10, that concerns T/Ss-related equipment that has been declared inoperable and is in an action statement.
ATTACHMENT 1 TO AEP:NRC: 1036B Page 4 C, A job order involving T/Ss-related equipment, failure of which will cause the initiation of an"event initiated" T/Ss surveillance requirement.
k~Pri ori t-30 A.A job order on T/Ss-related or safety-related equipment that, by definition, does not fit into Priority 10 or 20.B.A job order that does not fit into Priority 10 or 20 but is listed in the Control Room Open items listing.Maintenance job orders written to repair inoperable equipment that is required by the T/Ss to be operable will receive a Priority 10 or 20.Priority 10 is reserved for items of an immediate safety or plant availability concern and requires action to begin immediately and to continue on a 24-hour basis until the problem is under control.Priority 10 maintenance orders are rarel written.Therefore, Priority 20 maintenance job orders are generally the highest priority to be worked.This ensures that maintenance work to satisfy an LCO receives high priority.The following are the controls currently in place to ensure that mode changes do not occur with an LCO in a degraded mode without the required review and approval: Syc>,I 4tj~,li 1.The"Plant Heatup From Cold Shutdown to Hot Standb" an y procedure (OHP 4021.001.001) and the"Reactor Startup Procedure" (OHP 4021.001.002) require signoff by the responsible department heads that all T/Ss surveillance requirements for the mode to be entered have been completed.
Entry into Modes 4 and 3 requires an Equipment Checklist to be completed and signed off by a supervisor and entry into Mode 3 requires a review of the following logs with respect to Mode 3 T/Ss and other administrative requirements.
ATTACHMENT 1 TO AEP:NRC:1036B Page 5 o Temporary modification'log book o Control room surveillance book o Control room log o Shift supervisor's log o T/S open items log o Clearance permit log o Caution tag log o Non T/Ss-related equipment status log 2.Per PMI-4030,"Technical Specifications Review and Surveillance," mode changes while in a T/Ss action statement, when permitted by T/S 3.0.4, can only be made after review and approval by the operations department superintendent and the plant manager.Efforts to return the equipment to operability will continue unaffected by the mode change.The above-described administrative controls to limit the use of T/S 3.0.4 exceptions are currently in place.Our plant operators are aware of and have been instructed in the controls established to limit the use of the 3.0.4 exceptions.
10CFR50.92 Evaluation Per 10CFR50.92, a proposed amendment will not involve a significant hazards consideration if the proposed amendment does not: 1)Involve a significant increase in the probability or consequences of an accident previously analyzed, 2)Create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated, or 3)Involve a significant reduction in a margin of safety.Criterion 1 Adequate isolation of affected containment penetrations is ensured by following the requirements of the action statement in T/S 3.6.3.1.This requires the penetration be isolated by at J'f W Pg Jl' ATTACHMENT 1 TO AEP:NRC:1036B Page 6 least one deactivated automatic valve secured in the isolation position or by use of at least one closed manual valve or blind flange.Continued power operation is permitted in Mode 1 with an inoperable containment isolation valve provided 0he requirements of the action statement are followed.The T/Ss requirements are inconsistent, however, in that mode change is prohibited even though continuous power operation is permitted.
Since the T/Ss action requirements specify an adequate level of protection, we believe the change does not involve a significant increase in the probability or consequences of an accident previously analyzed.Criterion 2 The change involves no physical modifications to Cook Nuclear Plant, nor any changes in the design basis.The change should not, therefore, create the possibility of a new or different kind of accident from any previously analyzed or evaluated.
Criterion 3 Adequate isolation of affected containment penetrations is ensured by following the requirements of the T/S 3.6.3.1 action statement.
This requires the penetration to be isolated by at least one deactivated automatic valve secured in the isolation position or by use of at least one closed manual valve or blind flange.Continued power operation is permitted in Mode 1 with an of th inoperable containment isolation valve, provided the requirem t o e action statement are followed.The T/Ss requirements are iremen s inconsistent, however, in that mode change is prohibited even though continuous power operation is permitted.
Since the T/Ss action requirements specify an adequate level of protection, we'believe the change will not involve a significant reduction in a margin of safety.The Commission has provided guidance concerning the determination of significant hazards by providing examples (48FR14870) of amendments considered not likely to involve significant hazards consideration.
The first example refers to changes that are administrative in nature: for example, a change to achieve consistency throughout the technical specifications.
Although this change is not purely administrative in nature, it is related to this example in that it achieves consistency within T/S 3.6.3.1 in that mode change is not precluded, consistent with the allowance of continuous power operation in Mode 1.The sixth example refers to a change which may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results ATTACHMENT 1 TO AEP:NRC:1036B Page 7 of the change are clearly within limits established as acceptable.
Problems with inconsistent application of T/S 3.0.4 exemptions have been noted previously by the NRC in Generic Letter 87-09.The acceptability of continuous power operation with containment penetrations isolated per the action statement requirements has already been established.
This change only extends that acceptability to'allow mode change.Thus, we conclude that the sixth example is applicable to this change.