ML040130682

Application for Technical Specification Change Regarding Mode Change Limitations Additional Information

ML040130682
Person / Time
Site:	Cook
Issue date:	12/15/2003
From:	Jensen J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:3304-01
Download: ML040130682 (5)

Text

Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1395 INDIANA MICHIGAN POWER December 15, 2003 AEP:NRC:3304-01 10 CFR 50.90 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P 1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant, Units 1 and 2 APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING MODE CHANGE LIMITATIONS ADDITIONAL INFORMATION

Reference:

"Donald C. Cook Nuclear Plant Units I and 2, Application for Technical Specification Change Regarding Mode Change Limitations, and Adoption of a Technical Specifications Bases Control Program and Standard Technical Specification Surveillance Requirement 3.0.1 and Associated Bases, Using The Consolidated Line Item Improvement Process," letter AEP:NRC:3304, dated August 27, 2003.

In the referenced document, Indiana Michigan Power Company (I&M),

requested a license amendment utilizing the Consolidated Line Item Improvement Process (CLIIP). The license amendment adopted the industry Technical Specification Task Force (TSTF) standard technical specification (TS) change TSTF-359, Revision 9. TSTF-359, Revision 9 allows mode changes with inoperable equipment provided one of three conditions specified in the TS is met. Although TSTF-359, Revision 9 was written for the Improved Technical Specifications (ITS), the CLIIP can be used by all licensees.

In a telephone conversation with Nuclear Regulatory Commission (NRC) personnel on November 24, 2003, the NRC personnel noted two differences between the Donald C. Cook Nuclear Plant (CNP) TS and the ITS in the areas of low temperature overprotection (LTOP) and auxiliary feedwater (AFW). The NRC requested that CNP provide additional information addressing the effect of these differences on the adoption of TSTF-359, Revision 9 for CNP.

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U. S. Nuclear Regulatory Commission AEP:NRC:3304-01 Page 2 The ITS requires that LTOP be operable in Mode 4. The ITS changes in TSTF-359, Revision9 prohibit entering Mode 4 from Mode 5 with LTOP inoperable. CNP's TS require LTOP to be operable in Mode 5 with any Reactor Coolant System (RCS) cold leg temperature less than or equal to 152 degrees Fahrenheit ( 0 F) and in Mode 6. The CNP TS do not require LTOP to be operable in Mode 4 and entry into Mode 4 with LTOP inoperable is not prohibited by the current TS and will not be prohibited by the TS after adoption of TSTF-359.

CNP is in the process of converting to the ITS with submittal expected in the Spring of 2004. As part of the ITS conversion, the applicability of the LTOP specification is being revised to include Mode 4 with any RCS cold leg temperature < 2660 F (Unit 1) or < 2990 F (Unit 2). In the interim, plant procedures prohibit entering Mode 4 with LTOP inoperable. The current procedural controls and the future adoption of the ITS for CNP provide an appropriate level of control over Mode 4 entry with LTOP inoperable.

The ITS requires that one motor driven AFW pump be operable in Mode 4.

CNP uses AFW for normal startup and, therefore, the ITS changes in TSTF-359, Revision 9 prohibit entering Mode 4 from Mode 5 without an operable motor driven AFW pump. The CNP TS require AFW to be operable in Modes 1, 2, and 3. The CNP TS do not require AFW to be operable in Mode 4 and entry into Mode 4 with AFW inoperable is not prohibited by the current TS and will not be prohibited by the TS after adoption of TSTF-359.

As part of the ITS conversion, the applicability of the AFW specification is being revised to Modes 1, 2, and 3 and Mode 4 when a steam generator is being used for heat removal. In the ITS, the Limiting Condition for Operation is modified by a Note stating that only one AFW train, which includes a motor driven AFW pump, is required to be operable in Mode 4. This will prohibit entry into Mode 4 from Mode 5 without an operable motor driven AFW pump.

In the interim, plant procedures prohibit entering Mode 4 without an operable motor driven AFW pump. The current procedural controls and the future adoption of the ITS for CNP provide an appropriate level of control over Mode 4 entry with AFW inoperable.

U. S. Nuclear Regulatory Commission AEP:NRC:3304-0 1 Page 3 This letter contains no new commitments. Should you have any questions, please contact Mr. Brian D. Mann, Acting Manager of Regulatory Affairs, at (269) 697-5806.

Sincerely, c: J. L. Caldwell, NRC Region III K. D. Curry, Ft. Wayne AEP J. T. King, MPSC MDEQ - WHMD/HWRPS NRC Resident Inspector J. F. Stang, Jr., NRC Washington, DC

JANl-08-2004 14:34 EN 33IET AEPNG WEST P. 02/02 U. S. Nuclear Regulatory Commission AEP:NRC:3304-01 Page 4 bc: D. C. Baker G. E. Carlson M. J. Finissi D. W. Jenkins J. N. Jensen B. D. Mann D. A. Moul M. K. Nazar J. E. Newmiller D. J. Poupard M. K. Scarpello T. K. Woods J. A. Zwolinski TOTAL P.02

U. S. Nuclear Regulatory Commission AEP:NRC:3304-01 Page 5 AFFIRMATION I, Joseph N. Jensen, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS /< DAY OF Sea r , 2003 JULIE E.NEWMILLER Notary Public, Berrien County, Ml

-/ /- Notark Public My Commission Expires Aug 22, 2004 My Commission Expires 9 -S OM