ML041380415

RAI, License Amendment Request to Delete Surveillance Requirements for Power Range, Intermediate Range, and Source Range Neutron Flux Monitors

ML041380415
Person / Time
Site:	Cook
Issue date:	05/20/2004
From:	John Lamb NRC/NRR/DLPM/LPD3
To:	Nazar M Indiana Michigan Power Co
Lamb J, NRR/DLPM, 415-1446
References
TAC MC2474, TAC MC2475
Download: ML041380415 (5)

Text

May 20, 2004 Mr. Mano K. Nazar Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company 500 Circle Drive Buchanan, Michigan 49107

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING LICENSE AMENDMENT REQUEST TO DELETE SURVEILLANCE REQUIREMENTS FOR POWER RANGE, INTERMEDIATE RANGE, AND SOURCE RANGE NEUTRON FLUX MONITORS FOR THE DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MC2474 AND MC2475)

Dear Mr. Nazar:

The Nuclear Regulatory Commission (NRC) staff has reviewed Indiana Michigan Power Companys February 14, 2004, application for Donald C. Cook Nuclear Plant Units 1 and 2, regarding the license amendment request to delete surveillance requirements for power range, intermediate range, and source range neutron flux monitors. The NRC staff has identified areas where additional information is needed to complete its review. Enclosed is the NRC staff's request for additional information.

The items in the enclosure were discussed with Mr. Steinmetz of your staff and a mutually agreeable target date of within 30 days of the date of this letter for your response was established. If you have any questions, please contact me at (301)-415-1446.

Sincerely,

/RA/

John G. Lamb, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

As stated cc w/encl: See next page

Mr. Mano K. Nazar Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company 500 Circle Drive Buchanan, Michigan 49107

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING LICENSE AMENDMENT REQUEST TO DELETE SURVEILLANCE REQUIREMENTS FOR POWER RANGE, INTERMEDIATE RANGE, AND SOURCE RANGE NEUTRON FLUX MONITORS FOR THE DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MC2474 AND MC2475)

Dear Mr. Nazar:

The Nuclear Regulatory Commission (NRC) staff has reviewed Indiana Michigan Power Companys February 14, 2004, application for Donald C. Cook Nuclear Plant Units 1 and 2, regarding the license amendment request to delete surveillance requirements for power range, intermediate range, and source range neutron flux monitors. The NRC staff has identified areas where additional information is needed to complete its review. Enclosed is the NRC staff's request for additional information.

The items in the enclosure were discussed with Mr. Steinmetz of your staff and a mutually agreeable target date of within 30 days of the date of this letter for your response was established. If you have any questions, please contact me at (301)-415-1446.

Sincerely,

/RA/

John G. Lamb, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

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REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT REQUEST TO DELETE SURVEILLANCE REQUIREMENTS FOR POWER RANGE, INTERMEDIATE RANGE, AND SOURCE RANGE NEUTRON FLUX MONITORS FOR THE D. C. COOK NUCLEAR PLANT, UNITS 1 AND 2

1. Limiting Condition for Operation (LCO) 3.9.2, Instrumentation, states that an audible indication from the source range neutron flux monitors is required in the containment during MODE 6. The license amendment request (LAR) proposes to delete the requirement of an audible indication in the containment and replace it with the requirement that an audible count rate circuit to be OPERABLE. According to the LAR, the proposed change to LCO 3.9.2 is consistent with NUREG-1431, Westinghouse Standard Technical Specifications. The staff requests the licensee provide justification, besides consistency with the NUREG-1431, for why an audible indication in the containment is no longer necessary for LCO 3.9.2.

2. LCO 3.9.2, Instrumentation, requires as a minimum, two source range neutron flux monitors to be operating during MODE 6. However, NUREG-1431 states that two source range neutron flux monitors shall be OPERABLE during MODE 6. The basis for two OPERABLE source range neutron flux monitors is to ensure that redundant monitoring capability is available to detect changes in core reactivity. Specifically, a system, subsystem, train, component, or device is declared OPERABLE when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). Therefore, operating does not represent a defined condition for the source range neutron flux monitors. The staff requests the licensee review the wording in LCO 3.9.2 to verify which terms (operating and/or OPERABLE) are applicable to D. C. Cook Units 1 and 2. NUREG-1431 recommends that when portions of the Standard Technical Specifications (TS) are adopted, the related requirements should be adopted, as applicable, to achieve a high degree of standardization and consistency.

3. LCO 3.10.4, Special Test Exceptions, contains surveillance requirements (SRs) 4.10.4.1 (Unit 1), and 4.10.3.2 (Unit 2), Physics Tests. These SRs require the licensee to perform an intermediate range and power range CHANNEL FUNCTIONAL TEST within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to initiating PHYSICS TESTS in MODE 2. The LAR requests to eliminate the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requirement to establish that the surveillance is only required prior to the PHYSICS TESTS. The justification for this change is that the intermediate range and power range flux monitors are required to be operable prior to the PHYSICS TESTS by other surveillance requirements associated with the Reactor Trip System (RTS).

Also, the LAR states that the initiation of PHYSICS TESTS does not affect the ability of the equipment to perform its function, does not affect the trip setpoints or the reactor trip system capability, and does not invalidate the previous surveillances. The licensee concludes that a CHANNEL FUNCTIONAL TEST within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior PHYSICS TESTS provides no benefit.

ENCLOSURE

Table 4.3-1 in TS 3/4.3 (Units 1 and 2) provides the RTS instrumentation SRs that the licensee will rely on to meet the actual requirements of LCO 3.10.4. According to that table, power range monitor CHANNEL FUNCTIONAL TEST is performed quarterly and prior to startup (if not performed 7 days prior to startup). In addition, an intermediate range monitor CHANNEL FUNCTIONAL TEST is performed prior to startup (if not performed 184 days prior to startup).

The United States Nuclear Regulatory Commission approved the deletion of the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time frame by means of the approval of the Technical Specification Task Force (TSTF)-108, Eliminate the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Channel Operational Test on power and intermediate range for Physics Test Exceptions." The justification for this change relied on two RTS SRs for the intermediate range and power range flux monitors with a frequency of 92 days. The approval of the TSTF is based, in part, on the fact that the 92 day frequency has been demonstrated to be sufficient for the verification that the power range and intermediate range are properly functioning.

The staff requests the licensee provide a technical justification to demonstrate that the frequencies of the SRs that will support the deletion of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> requirement (RTS SRs in Table 4.3-1) are sufficient for the verification that the intermediate range and power range monitors are properly functioning.

Donald C. Cook Nuclear Plant, Units 1 and 2 cc:

Regional Administrator, Region III Michigan Department of Environmental U.S. Nuclear Regulatory Commission Quality 801 Warrenville Road Waste and Hazardous Materials Div.

Lisle, IL 60532-4351 Hazardous Waste & Radiological Protection Section Attorney General Nuclear Facilities Unit Department of Attorney General Constitution Hall, Lower-Level North 525 West Ottawa Street 525 West Allegan Street Lansing, MI 48913 P. O. Box 30241 Lansing, MI 48909-7741 Township Supervisor Lake Township Hall David A. Lochbaum P.O. Box 818 Nuclear Safety Engineer Bridgman, MI 49106 Union of Concerned Scientists 1707 H Street NW, Suite 600 U.S. Nuclear Regulatory Commission Washington, DC 20036 Resident Inspectors Office 7700 Red Arrow Highway Michael J. Finissi, Plant Manager Stevensville, MI 49127 Indiana Michigan Power Company Nuclear Generation Group David W. Jenkins, Esquire One Cook Place Indiana Michigan Power Company Bridgman, MI 49106 One Cook Place Bridgman, MI 49106 Mr. Joseph N. Jensen, Site Vice President Indiana Michigan Power Company Mayor, City of Bridgman Nuclear Generation Group P.O. Box 366 One Cook Place Bridgman, MI 49106 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 Mr. John A. Zwolinski Director, Design Engineering and Regulatory Affairs Indiana Michigan Power Company Nuclear Generation Group 500 Circle Drive Buchanan, MI 49107