ML17334A504
| ML17334A504 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/30/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| AEP:NRC:0420E, AEP:NRC:420E, NUDOCS 8402030472 | |
| Download: ML17334A504 (4) | |
Text
(REGULATORY NFORMATION DISTRIBUTION SY "M (RIDS)
ACCESSION NOR:8402030472 DOC ~ DATE: 84/01/30 NOTARIZED:
NO DOCKET FACIL:50 315 Donald C ~
Cook Nuclear Power Pl anti Unit 1i Indiana 8
0500OL3 50 316 Donal a C, Coax. Nuclear Power Plantr Uni t 2i Inaiana AUTH BYNAME AUTHOR AFFILIATION AL KXICHgM ~ D ~
Indiana-8 Michigan Electric Co ~
REC IP ~ NAMF-REC IP IENT AF F ILIATION DKNTONrH~ Re Office of Nuclear Reactar Regulationr Directar
SUBJECT:
Forwar ds r'equest far clar i ficatian re Tech Spec 3 ~
9.10'n reactor vessel water level r equir ements for aper ation in-MODE 6 issued w/Amends 59 8, 78 issued, DISTRIBUTION CODEe A001S COPIES RECEIVEDSLTR ENCL SIZE
/
Q TITLE:
OR Submittal:
Gener'al Distribution NOTES:
REC IP IKNT GOOK/NAME NRR ORB 1 BC 01 COPIES i.TTR ENCL RECIPIENT ID CODE/NAME COP IFS LTTR ENCL INTERNALS ELD/HDS3 NRR/DL DIR NRR/DSI/METB EXTERNAL'CRS NRG PDR NTIS 04 09 02 NRR/DE/MTEB NRR/DL/ORAB NRR/DSI/RAB RGN3 LPDR NSIG 03 05 TOTAL NUMBER OF COPIES REQUIRED ~
LTTR 26 ENCl
INDIANA 8 MICHIGAN ELECTRIC CON PANY P.O. BOX 16631 COLUMBUS, OHIO 43216 January 30, 1984 AEP:NRC:0420E Donald C. Cook Nucleax'lant Unit Nos.
1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 REQUEST FOR TECHNICAL SPECIFICATION CLARIFICATION REACTOR VESSEL WATER LEVEL Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Deax'r.
Denton:
Pursuant to our conversation with your staff, this letter provides our formal request for your clarification of Technical Specification (T/S) 3.9.10, on the reactoz vessel water level requirements for operations in MODE 6, which was issued under Amendment Nos.
78 and 59 for our Unit Nos.
1 and 2, respectively.
The need for this clarification became apparerit because Rod Cluster Control Assembly (RCCA) movements within fuel assemblies are zequired during the removal and installation of the Upper Internals in MODE 6.
This is performed with less than 23 feet of water above the reactor pressure vessel flange.
Below is a description of some of the operations which are performed in MODE 6 to remove the upper internals.
Please consider these operations when making your clarification of T/S 3.9.10.
Prior to the removal of the Upper Internals, the control rod drive shafts must be unlatched.
The unlatching is accomplished using a tool suspended from the refueling crane.
During this operation, there is about 12 to 14 feet of water ovex the reactor pressure vessel flange, and 24 feet of water over the fuel.
The control zod drive shaft is "grabbed" by the unlatching tool, then both the RCCA and its drive shaft are lifted approximately 8 feet, and then are weighed.
The RCCA and its drive shaft are then lowered and decoupled from one another.
The control rod drive shaft is then lifted and weighed to verify that it had been unlatched from the RCCA.
The reverse of this operation is required for reinstallation of the Upper Internals.
The RCCA and its drive shaft are physically restrained from being lifted more than approximately 13 feet, or 1 foot above the fuel by the Upper Internals.
There are guides in the Upper Internals that direct the rodlets back into the fuel, and thereby prevent 'any misalignment.
8402030472 840130 PDR ADOCN OS0003ZS P
Mr. Harold R.
De n
2>>
During normal operation, the fuel will absorb the energy of the falling RCCA via a dash pot arrangement at the lower portion of the rod travel and the spring "shock absorber" in the RCCA hub. If the RCCA is dropped and the rodlets were misaligned, it is our opinion that they would bend and absorb most of the energy.
It is obvious from the above description that there are operations during MODE 6 when we are not able to maintain at least 23 feet of'water over the top of the reactor pressure vessel flange.
We believe this type of operation was considered and allowed by the NRC staff when they included the statement in the BASES for T/S Section 3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL AND STORAGE POOL that stated:
"Water level above the vessel flange in MODE 6 will vary as the reactor vessel head and the system internals are removed.
The 23 feet of water are required before any subsequent movement of fuel assemblies or control rods.."
Based on the above statement in the BASES, in conjunction with our own internal review process, we believe this Technical Specification to mean that operations in the above described manner are permitted, do not constitute an unreviewed safety question as defined in 10 CPR 50.59, and will not adversely affect the health and safety of the public.
Your concurrence in this interpretation is requested principally because the words of the Technical Specification itself do not address such operations.
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, p 54 X~....
Vice President MPA/cm cc:
John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff E.
R.
- Swenson, NRC Resident Inspector - Bridgman