ML080770178

Issuance License Amendments 305 and 288 Regarding Maximum Ventilation System Filter Pressure Drop

ML080770178
Person / Time
Site:	Cook
Issue date:	04/28/2008
From:	Tam P NRC/NRR/ADRO/DORL/LPLIII-1
To:	Rencheck M Indiana Michigan Power Co
Shared Package
ML081270552	List: ML080770178
References
TAC MD5931, TAC MD5932
Download: ML080770178 (15)

Text

April 28, 2008 Mr. Michael W. Rencheck 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 - ISSUANCE OF AMENDMENTS TO RENEWED FACILITY OPERATING LICENSE REGARDING MAXIMUM VENTILATION SYSTEM FILTER PRESSURE DROP (TAC NOS. MD5931 AND MD5932)

Dear Mr. Rencheck:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 305 to Renewed Facility Operating License No. DPR-58, and Amendment No. 288 to Renewed Facility Operating License No. DPR-74 for Donald C. Cook Nuclear Plant, Units 1 and 2. The amendments change the Technical Specifications in response to your application dated June 13, 2007, as supplemented by letter dated February 13, 2008.

The amendments revised Section 5.5.9, Ventilation Filter Testing Program (VFTP), changing the specified pressure drop values for the combined high efficient particulate air filters and charcoal adsorbers for three engineered safety feature ventilation systems from less than 6 inches water gauge to less than 4 inches water gauge at the specified flow rates.

A copy of the associated safety evaluation is also enclosed. A Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Amendment No. 305 to DPR-58

2. Amendment No. 288 to DPR-74

3. Safety Evaluation cc w/encls: See next page

Mr. Michael W. Rencheck April 28, 2008 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 - ISSUANCE OF AMENDMENTS TO RENEWED FACILITY OPERATING LICENSE REGARDING MAXIMUM VENTILATION SYSTEM FILTER PRESSURE DROP (TAC NOS. MD5931 AND MD5932)

Dear Mr. Rencheck:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 305 to Renewed Facility Operating License No. DPR-58, and Amendment No. 288 to Renewed Facility Operating License No. DPR-74 for Donald C. Cook Nuclear Plant, Units 1 and 2. The amendments change the Technical Specifications in response to your application dated June 13, 2007, as supplemented by letter dated February 13, 2008.

The amendments revised Section 5.5.9, Ventilation Filter Testing Program (VFTP), changing the specified pressure drop values for the combined high efficient particulate air filters and charcoal adsorbers for three engineered safety feature ventilation systems from less than 6 inches water gauge to less than 4 inches water gauge at the specified flow rates.

A copy of the associated safety evaluation is also enclosed. A Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Amendment No. 305 to DPR-58

2. Amendment No. 288 to DPR-74

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC G. Hill(4) LPL3-1R/F RidsOgcRp E. Duncan, RIII RidsAcrsAcnw&mMailCenter RidsNrrPMPTam B. Heida, NRR RidsNrrLABTully RidsNrrLATHarris RidsNrrDorlDpr RidsRgn3MailCenter RidsNrrDirsItsb RidsNrrDorlLpl3-1 Package Accession Number: ML0 Amendment Accession Number: ML080770178 TS: ML081230269 OFFICE NRR/LPL3-1/PM NRR/LPL3-1/LA NRR/SCVB/BC OGC NRR/LPL3-1/BC NAME PTam THarris RDennig* NLO by MSpencer LJames DATE 04/17/08 04/16/08 4/2/08 4/24/08 4/28/08

• SE transmitted by memo of 4/2/08. OFFICIAL RECORD COPY

INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-315 DONALD C. COOK NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 305 License No. DPR-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Indiana Michigan Power Company (the licensee) dated June 13, 2007, as supplemented by letter dated February 13, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-58 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and Appendix B, as revised through Amendment No. 305 are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 45 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Lois M. James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License and Appendix A Date of Issuance: April 28, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 305 RENEWED FACILITY OPERATING LICENSE NO. DPR-58 DOCKET NO. 50-315 Replace the following page of Renewed Facility Operating License No. DPR-58 with the attached revised page. The change area is identified by a marginal line.

REMOVE INSERT 3 3 Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The change area is identified by a marginal line.

REMOVE INSERT 5.5-9 5.5-9

and radiation monitoring equipment calibration, and as fission detectors in amounts as required.

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3304 megawatts thermal in accordance with the conditions specified therein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and Appendix B, as revised through Amendment No. 305, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Less Than Four Loop Operation The licensee shall not operate the reactor at power levels above P-7 (as defined in Table 3.3.1-1 of Specification 3.3.1 of Appendix A to this renewed operating license) with less than four reactor coolant loops in operation until (a) safety analyses for less than four loop operation have been submitted, and (b) approval for less than found loop operation at power levels above P-7 has been granted by the Commission by amendment of this license.

(4) Indiana Michigan Power Company shall implement and maintain, in effect, all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for the facility and as approved in the SERs dated December 12, 1977, July 31, 1979, January 10, 1981, February 7, 1983, November 22, 1983, December 23, 1983, March 16, 1984, August 27, 1985 Renewed License No. DPR-58 Amendment No. 1 through 304, 305

INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-316 DONALD C. COOK NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 288 License No. DPR-74

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Indiana Michigan Power Company (the licensee) dated June 13, 2007, as supplemented by letter dated February 13, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-74 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and Appendix B, as revised through Amendment No. 288, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 45 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Lois M. James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License and Appendix A Date of Issuance: April 28, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 288 RENEWED FACILITY OPERATING LICENSE NO. DPR-74 DOCKET NO. 50-316 Replace the following page of Renewed Facility Operating License No. DPR-74 with the attached revised page. The change area is identified by a marginal line.

REMOVE INSERT 3 3 Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The change area is identified by a marginal line.

REMOVE INSERT 5.5-9 5.5-9

radiation monitoring equipment calibration, and as fission detectors in amounts as required.

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3468 megawatts thermal in accordance with the conditions specified therein and in attachment 1 to the renewed operating license.

The preoperational tests, startup and other items identified in Attachment 1 to this renewed operating license shall be completed. Attachment 1 is an integral part of this renewed operating license.

(2) Technical Specifications The Technical Specifications contained in Appendix A and Appendix B, as revised through Amendment No. 288, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Additional Conditions (a) Deleted by Amendment No. 76 (b) Deleted by Amendment No. 2 (c) Leak Testing of Emergency Core cooling System Valves Indiana Michigan Power Company shall prior to completion of the first inservice testing interval test each of the two valves in series in the Renewed License No. DPR-74 Amendment No. 1 through 287, 288

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 305 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-58 AND AMENDMENT NO. 288 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 (DCCNP-1 AND -2)

DOCKET NOS. 50-315 AND 50-316

1.0 INTRODUCTION

By letter dated June 13, 2007 (Agencywide Document and Management System (ADAMS)

Accession No. ML071730047), as supplemented by letter dated February 13, 2008 (ADAMS Accession No. ML080530395), Indiana Michigan Power Company (the licensee) submitted an application for license amendment to change the Technical Specifications (TS) surveillance testing acceptance criteria for the Ventilation Filter Testing Program for the DCCNP-1 and -2.

The proposed amendment will impose lower (more restrictive) limits on the maximum pressure drop across the combined high efficiency particulate air (HEPA) filters and charcoal adsorbers in three ventilation systems. The more restrictive pressure drop limits will be consistent with the required system flow rates and system requirements.

The licensee has determined that the existing acceptance values in the TS are non-conservative. Consequently, the licensee has implemented administrative controls to impose a more restrictive acceptance criterion for the TS surveillance testing pending the issuance of the requested license amendment.

The licensee's February 13, 2008, supplement provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on August 14, 2007.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations, Paragraph 50.36(d)(3) specifies that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants, dated June 2001, provides guidance for testing the air filtration and adsorption components.

The DCCNP-1 and -2 TS follow the Improved Technical Specifications format set forth in NUREG-1431 Volume 2, Standard Technical Specifications Westinghouse Plants. Thus, the post-accident engineered safety feature atmosphere cleanup system air filtration and adsorption units are considered OPERABLE when the individual components necessary to limit operator exposure are OPERABLE in both trains. Specifically, these conditions must be met::

(a) The fan is OPERABLE, (b) HEPA filters and charcoal adsorbers are not excessively restricting flow, and are capable of performing their filtration functions.

3.0 TECHNICAL EVALUATION

The licensee proposed to amend the DCCNP-1 and -2 TS to impose lower, i.e., more restrictive, limits on the maximum pressure drop across the combined HEPA filters and charcoal adsorbers in three ventilation systems. These ventilation systems are the Control Room Emergency Ventilation (CREV) System, the Engineered Safety Features (ESF) Ventilation System, and the Fuel Handling Area Exhaust Ventilation (FHAEV) System. The licensee stated that the more restrictive pressure drop limits will be consistent with the required system flow rates.

Section 5.5.9, Ventilation Filter Test Program (VFTP), sets forth requirements for the CREV System, ESF Ventilation System, and FHAEV System. Paragraph 5.5.9.d of this section requires that, for each of these systems, the pressure drop across the combined HEPA filter and charcoal adsorber bank (i.e., HEPA/charcoal assembly) be verified every 24 months to be less than (<) 6 inches water gauge, with the system flow rates within the stated system-specific bands. The proposed amendment would reduce the <6 inches water gauge criteria to <4 inches water gauge.

Surveillance Requirements 3.7.10.2, 3.7.12.2, and 3.7.13.3 at DCCNP-1 and -2 require filter testing in accordance with the VFTP. A change to the VFTP, therefore, effectively changes how these surveillance requirements are performed.

The licensee stated that during design reviews conducted as part of the 1997-2000 extended shutdown of DCCNP-1 and -2, the licensee determined that the existing <6 inch water gauge TS limits for the pressure drop across the HEPA/charcoal assemblies were non-conservative with respect to the required minimum flow rates for the associated systems. Failure to maintain the minimum specified flow rates may impact associated accident analysis.

The licensee initially indicated that the proposed <4 inch water gauge limit was based in accordance with filter vendor recommendations, and that flow rates could be met based on analysis. The NRC staff requested additional information to verify that regardless of the vendor recommendations for filter change-out pressure drop, the new TS filter pressure drop will assure that minimum flow rates as required for the accident analyses for the associated systems will be met.

In its letter of February 13, 2008, the licensee stated that the new TS acceptance values are less than the maximum calculated pressure drop across the filter assembly at minimum required system air flow. The new acceptance value also takes into consideration the pressure drop across other filter assembly elements such as pre-filters, even though those elements are not part of the TS acceptance criteria. The licensee also indicated that the as-measured air flow rates are consistent with the predictions from its calculations. This provides a measure of confidence in the component pressure drop values used in the calculations.

The NRC staff reviewed the licensees application and finds that it is acceptable to revise the acceptance criteria in TS Section 5.5.9.d to reflect the simulated dirty filter pressure drops measured across the CREV System, ESF Ventilation System, and FHAEV System. Therefore, the proposed maximum allowed pressure drops for the CREV System of <4 inches water gauge at a flow rate 5,400 and 6,600 cubic feet per minute (cfm), ESF Ventilation System of <4 inches water gauge at a flow rate 22,500 and 27,500 cfm, and FHAEV System of <4 inches water gauge at a flow rate 27,000 and 33,000 cfm, respectively, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued proposed findings that the amendments involve no significant hazards consideration and there has been no public comment on such finding (72 FR 45458). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Bruce Heida Date: April 28, 2008

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

Michigan Department of Environmental Attorney General Quality Department of Attorney General Waste and Hazardous Materials Div.

525 West Ottawa Street Hazardous Waste & Radiological Lansing, MI 48913 Protection Section Nuclear Facilities Unit Township Supervisor Constitution Hall, Lower-Level North Lake Township Hall 525 West Allegan Street P.O. Box 818 P. O. Box 30241 Bridgman, MI 49106 Lansing, MI 48909-7741 U.S. Nuclear Regulatory Commission Joel P. Gebbie, Plant Manager Resident Inspector's Office Indiana Michigan Power Company 7700 Red Arrow Highway Nuclear Generation Group Stevensville, MI 49127 One Cook Place Bridgman, MI 49106 Kimberly Harshaw, Esquire Indiana Michigan Power Company Mark A. Peifer, Site Vice President One Cook Place Indiana Michigan Power Company Bridgman, MI 49106 Nuclear Generation Group One Cook Place Mayor, City of Bridgman Bridgman, MI 49106 P.O. Box 366 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 James M. Petro, Jr.

Regulatory Affairs Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106