ML051950020

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Correction of Administrative Error to Improved Technical Specifications
ML051950020
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 08/05/2005
From: Lyon C
NRC/NRR/DLPM/LPD3
To: Nazar M
Indiana & Michigan Electric Co
Lyon CF, NRR/DLPM, 415-2296
References
NUREG-1431, TAC MC7562, TAC MC7563
Download: ML051950020 (4)


Text

August 5, 2005 Mr. Mano K. Nazar Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - CORRECTION OF ADMINISTRATIVE ERROR TO IMPROVED TECHNICAL SPECIFICATIONS (TAC NOS. MC7562 AND MC7563)

Dear Mr. Nazar:

By letter dated June 1, 2005, the Nuclear Regulatory Commission staff issued License Amendment Nos. 287 and 269 for the Donald C. Cook Nuclear Plant, (CNP) Units 1 and 2, respectively. The amendment converted the current Technical Specifications (CTS) to Improved Technical Specifications (ITS) consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 2, dated April 30, 2001. By letter dated July 5, 2005, you identified an administrative error on ITS page 3.3.1-16, Table 3.3.1-1, Reactor Trip System Instrumentation, involving the plant-specific reactor trip setpoint for Overpower Delta T.

CTS Table 2.2-1, Reactor Trip System Instrumentation Trip Setpoints Notation, provides the formula for calculating the trip setpoint for Overpower Delta T. Included in this formula is the variable T3, which is defined as the time constant value of 10 seconds that is utilized in the rate lag controller for Tavg. T3 is used to determine the value of the function generated by the lag controller for the Tavg dynamic compensation. NUREG-1431, Rev. 2, Table 3.3.1-1, "Reactor Trip System Instrumentation," provides a formula to calculate the Overpower Delta T reactor trip setpoint. However, NUREG-1431, Rev. 2, uses the variable T7 to determine the value of the function generated by the rate lag controller for the Tavg dynamic compensation instead of the variable T3. T7 was given a value of > [*] seconds, where [*] is a value specified in the Core Operating Limits Report (COLR). NUREG-1431, Rev. 2 uses a variable T3, which is defined as

< [*] seconds, to adjust the value of the reactor coolant system temperature change.

By letter dated July 5, 2005, you indicated that, when converting from CTS to ITS, you had inadvertently adopted the inequality sign convention of T3 from NUREG-1431, Rev. 2, instead of the inequality sign convention of T7. Specifically, on both CNP Unit 1 and Unit 2 Technical Specification pages 3.3.1-16, the inequality associated with the T3 time constant should be >

instead of <. In the CNP Unit 1 and Unit 2 CTS, the T3 time constant (utilized in the rate lag controller for Tavg) is the same as the T7 time constant in NUREG-1431. In converting to the ITS, you inadvertently adopted the < inequality sign of the NUREG-1431 T3 time constant (utilized in the lag compensator for Delta T, which is not applicable for the CNP design), instead

M. Nazar of the > inequality sign of the equivalent NUREG-1431 T7 time constant. This error was confirmed by your application for ITS conversion dated April 6, 2004, which is identified as the origin of this error.

The correction of this error does not change the Safety Evaluation for the June 1, 2005, license amendment. In addition, this change was not addressed as a Beyond-Scope Change in the Notice of Consideration of Issuance of Amendments to Facility Operating Licenses and Opportunity for a Hearing published in the Federal Register on September 29, 2004 (69 FR 58205), nor did the notice otherwise specifically identify it. The licensee did request, in the ITS conversion, that the value of T3 be removed from the TS to the COLR. While the NRC staff reviewed the proposal to place the appropriate value in the COLR, rather than the TS, the staff did not review the associated inequality sign convention. Based on the foregoing, the staff is correcting this inadvertent error.

The corrected ITS page 3.3.1-16 for Unit 1 and Unit 2 is enclosed.

Sincerely,

/RA/

Carl F. Lyon, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

As stated cc w/encls: See next page

M. Nazar of the > inequality sign of the equivalent NUREG-1431 T7 time constant. This error was confirmed by your application for ITS conversion dated April 6, 2004, which is identified as the origin of this error.

The correction of this error does not change the Safety Evaluation for the June 1, 2005, license amendment. In addition, this change was not addressed as a Beyond-Scope Change in the Notice of Consideration of Issuance of Amendments to Facility Operating Licenses and Opportunity for a Hearing published in the Federal Register on September 29, 2004 (69 FR 58205), nor did the notice otherwise specifically identify it. The licensee did request, in the ITS conversion, that the value of T3 be removed from the TS to the COLR. While the NRC staff reviewed the proposal to place the appropriate value in the COLR, rather than the TS, the staff did not review the associated inequality sign convention. Based on the foregoing, the staff is correcting this inadvertent error.

The corrected ITS page 3.3.1-16 for Unit 1 and Unit 2 is enclosed.

Sincerely,

/RA/

Carl F. Lyon, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

As stated cc w/encls: See next page DISTRIBUTION TBoyce PUBLIC GHill(2) LRaghavan PD 3-1 r/f OGC EDuncan, RIII ACRS FLyon THarris Package Accession Number: ML052170104 Letter Accession Number: ML051950020 Technical Specifications Accession Number: ML052170208 OFFICE PM:PD3-1 LA:PD3-1 SC:SRXB SC:IROB OGC SC:PD3-1 NAME FLyon THarris JNakoski TBoyce SUttal LRaghavan DATE 07/14/05 07/14/05 07/15/05 07/25/05 08/3/05 08/5/05 OFFICIAL RECORD COPY

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

Regional Administrator, Region III Michigan Department of Environmental U.S. Nuclear Regulatory Commission Quality 2443 Warrenville Road, Suite 210 Waste and Hazardous Materials Div.

Lisle, IL 60532-4352 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 Michael J. Finissi, Plant Manager P.O. Box 818 Indiana Michigan Power Company Bridgman, MI 49106 Nuclear Generation Group One Cook Place U.S. Nuclear Regulatory Commission Bridgman, MI 49106 Resident Inspector's Office 7700 Red Arrow Highway Mr. Joseph N. Jensen, Site Vice President Stevensville, MI 49127 Indiana Michigan Power Company Nuclear Generation Group James M. Petro, Jr., Esquire One Cook Place Indiana Michigan Power Company Bridgman, MI 49106 One Cook Place Bridgman, MI 49106 Mayor, City of Bridgman P.O. Box 366 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 Mr. John A. Zwolinski Safety Assurance Director Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106