ML042100233

Application for Amendment to Delete Surveillance Requirements for Power Range, Intermediate Range, and Source Range Neutron Flux Monitors - Request for Additional Information

ML042100233
Person / Time
Site:	Cook
Issue date:	07/26/2004
From:	Jensen J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4392-01, TAC MC2474, TAC MC2475
Download: ML042100233 (8)

Text

Indiana Michigan V Power Company 500 Circle Drive Buchanan, Ml 49107 1373 INDIANA MICHIGAN POWER July 26, 2004 AEP:NRC:4392-01 10 CFR 50.90 Docket Nos: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units I And 2 APPLICATION FOR AMENDMENT TO DELETE SURVEILLANCE REQUIREMENTS FOR POWER RANGE, INTERMEDIATE RANGE, AND SOURCE RANGE NEUTRON FLUX MONITORS - REQUEST FOR ADDITIONAL INFORMATION (TAC Nos. MC2474 and MC2475)

By letter dated February 14, 2004 (Reference 1*), Indiana Michigan Power Company (I&M) requested Nuclear Regulatory Commission (NRC) approval of a license amendment to revise surveillance requirements for the power range, intermediate range, and source range neutron flux monitors. Subsequent to the Reference I submittal, the NRC requested additional information (Reference 2).

The NRC's requests and I&M's responses are provided below.

NRC Request I 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.

• References are provided at the end of this letter. .4 o1

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 2 I&M Response The safety function of the source range audible indication is to alert the operators to a reactivity change during refueling operations. In particular, the boron dilution analysis assumes that the operator has prompt and definite indication from the audible indication, alerting the operator to take actions to mitigate the event. However, the analysis does not assume a location for the audible indication. The proposed technical specification (TS) maintains this function, while providing flexibility in the audible indication's location (presently the control room and the containment).

The inclusion of the audible indication's location in LCO 3.9.2 is unnecessary because I&M is required to have both a plant design and procedures that allow the operators to meet the requirements of the safety analysis for a reactivity change during refueling operations. Thus, I&M is required to place the audible indication in locations that will allow the operators to take timely action.

Changes to the audible indication's current location would require processing a design change in accordance with established Donald C. Cook Nuclear Plant (CNP) procedures. The procedures require an assessment of the impacts that the change has on other functional areas and documents, including operations, training, procedures and the Updated Final Safety Analysis Report.

Additionally, a 10 CFR 50.59 review of the design change is required. The procedural requirements provide assurance that the safety function of the audible indication is maintained, and that the operator will be provided with a timely indication of the initiation of a boron dilution event.

The proposed change also makes the TS 3.9.2 LCO consistent with the Standard Technical Specification and eliminates a difference between the Unit I and Unit 2 TSs. Unit 2 requires an audible indication in both the containment and the control room while Unit I requires the indication only in the containment.

The cause of the difference between the two TSs is unknown, but is believed to have resulted from the evolution of the standard technical specifications during the licensing of each unit.

The proposed change includes replacement of requirements for a source range channel functional test with requirements for a source range calibration. During a telephone conversation to discuss the request for additional information, the NRC also asked I&M to explain why the proposed change excluded the neutron detectors from the source range channel calibration. Neutron detectors are excluded from TS calibrations because of the impracticability of obtaining a calibrated neutron source. This exclusion is consistent with the existing Note 6 in TS Table 4.3-1.

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 3 NRC Request 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 I 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.

I&M Response I&M considers the present TS 3.9.2 LCO wording, ... "two source range neutron flux monitors shall be operating . . .," to be synonymous with the phrase "shall be OPERABLE" used in the LCO for other Unit I and Unit 2 TSs. The TS basis, which discusses the OPERABILITY of the source range neutron flux monitors, and the CNP definition of operable and operability, confirm that the phrase "shall be operating" is synonymous with "shall be OPERABLE."

I&M is converting to the Westinghouse Standard Technical Specifications, and the source range monitors are required to be OPERABLE in the revised TS.

NRC Request 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.

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 4 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 to PHYSICS TESTS provides no benefit.

Table 4.3-1 in TS 3/4.3 (Units I 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 (NRC) approved the deletion of the 12 hour1.388889e-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 (COT) 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.

I&M Response The power range flux monitors are subject to a channel functional test every 92 days, and at startup if not performed within the previous 7 days. Thus, the channel functional test frequency is consistent with TSTF-l 08.

At the time that TSTF-108 was approved, a 92-day frequency for performing the channel functional test was considered adequate for demonstrating that the intermediate range neutron flux monitors were operable. TSTF-41 1, Revision I, "Surveillance Test Interval Extensions for Components of the Reactor Protection System (WCAP-15376-P), dated August 7, 2002, extended the surveillance

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 5 interval to 184 days. By letter dated August 30, 2002 (Reference 3), I&M submitted a license amendment request to extend Reactor Trip System and Engineered Safety Features Actuation System surveillance time requirements as evaluated in WCAP-15376. This request, which was approved by the NRC on May 23, 2003 (Reference 4), approved the extension of the intermediate range neutron flux monitor surveillance interval to 184 days In addition to the channel functional test, the intermediate range neutron flux monitors are subjected to a channel calibration test each refueling outage. The definition of a channel calibration includes the requirement to perform a channel functional test.

This letter contains no commitments. Should you have any questions, please contact Mr. John A. Zwolinski, Safety Assurance Director, at (269) 466-2428.

Sincerely ph N. Jensen Site Vice President RV/rdw

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 6

References:

1. Letter from J. N. Jensen, Indiana Michigan Power Company (I&M) to Nuclear Regulatory Commission (NRC) Document Control Desk, "D. C.

Cook Nuclear Plant Units I and 2, Docket Nos. 50-315 and 50-316, Application for Amendment to Delete Surveillance Requirements for Power Range, Intermediate Range, and Source Range Neutron Flux Monitors," AEP:NRC:4392, dated February 14, 2004.

2. Letter from John G. Lamb, NRC, to Mano K. Nazar, I&M, "Request for Additional Information (RAI) Regarding License Amendment to Delete Surveillance Requirements for Power Range, Intermediate Range, and Source Range Neutron Flux Monitors for the Donald C. Cook Nuclear Plant, Units I and 2 (TAC Nos. MC2474 and MC2475), dated May 20, 2004.

3. Letter from J. E. Pollock, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Amendment Request to Extend Reactor Trip System and Engineered Safety Features Actuation System Surveillance Requirements as Evaluated in WCAP-15376," AEP:NRC:23 11, dated August 30, 2002.

4. Letter from John F. Stang, NRC, to A. Christopher Bakken III, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments (TAC Nos. MB6324 and MB6325)," dated May 23, 2003.

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 7 c: J. L. Caldwell, NRC Region III K. D. Curry, Ft. Wayne AEP J. T. King, MPSC J. G. Lamb, NRC Washington, DC MDEQ - WHMD/HWRPS NRC Resident Inspector

U. S. Nuclear Regulatory Commission AEP:NRC:4392-01 Page 8 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 Joseph N. Jensen Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME JULIE E.NEWMILLER Notary Public, Berrien County, Ml My Commission Expires Aug 22,2004

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