AEP-NRC-2016-65, License Amendment Request Regarding Technical Specification 3.9.3, Containment Penetrations

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License Amendment Request Regarding Technical Specification 3.9.3, Containment Penetrations
ML16351A198
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/14/2016
From: Lies Q
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2016-65
Download: ML16351A198 (15)
v • d • e


Text

Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 A unit of American Electric Power lndianaMichiganPower.com December 14, 2016 AEP-NRC-2016-65 10 CFR 50.90 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant, Unit 1 and Unit 2 License Amendment Request Regarding Technical Specification 3.9.3, Containment Penetrations In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Renewed Facility Operating Licenses DPR-58 and DPR-74. l&M proposes to amend TS 3.9.3, "Containment Penetrations," by revising the Note regarding applicability of the Limiting Condition for Operation. l&M has evaluated the proposed change in accordance with 1d CFR 50.92 and concluded that there is no significant hazards consideration. to this letter provides an affirmation statement pertaining to the information contained herein. Enclosure 2 provides l&M's evaluation of the proposed TS change. Enclosures 3 and 4 provide the existing CNP Unit 1 and Unit 2 TS pages, respectively, marked to show the proposed changes. New clean Unit 1 and Unit 2 TS pages with the proposed change incorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing Project Manager when requested.

l&M requests approval of the proposed license amendment commensurate with the NRC's normal review schedule. Once approved, the amendment will be implemented within 120 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan state officials.

There are no new or revised regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely,

~A .

Q. ne Lies Si ce President TLC/mll

U. S. Nuclear Regulatory Commission AEP-NRC-2016-65 Page 2 *

Enclosures:

1. Affirmation
2. Evaluation of Proposed Changes
3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked to Show Proposed Changes
4. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked to Show Proposed Changes
  • c: R. J. Ancona, MPSC A. W. Dietrich, NRG Washington DC MDEQ - RMD/RPS NRG Resident Inspector C. D. Pederson, NRG Region Ill A. J. Williamson - AEP Ft. Wayne, w/o enclosures

Enclosure 1 to AEP-NRC-2016-65 AFFIRMATION I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U. S. Nuclear Regulatory Commission on behalf of l&M, and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company 2~1Bi, DANIELLE BURGOVN~ .

Notary Public, State of M1ch1gan

  • County of Berrien My Commission Expires O~Oi~ ~"'-

Q. Cne Lies Acting In the county of -~

Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS

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Enclosure 2 to AEP-NRC-2016-65 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Renewed Facility Operating Licenses DPR-58 and DPR-74.

The proposed amendment would modify the CNP Unit 1 and Unit 2 TS by revising the Note regarding applicability of the Limiting Condition for Operation (LCO) for TS 3.9.3, Containment Penetrations.

2.0 DETAILED DESCRIPTION The CNP TS LCO 3.9.3.c.1. requires that, during movement of irradiated fuel within containment, each containment building penetration providing direct access from the containment atmosphere to the outside atmosphere be closed by a manual or automatic isolation valve, blind flange, or equivalent. The requirement for containment building penetration closure ensures that a release of radioactive material as the result of a fuel handling accident (FHA) within containment will not escape to the environment. A Note to CNP TS LCO 3.9.3 allows some of these containment penetrations to be opened under administrative controls during movement of irradiated fuel within containment.

CNP TS LCO 3.9.3 contains the following NOTE:

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere via the auxiliary building vent may be unisolated under administrative controls.

The insertion of this Note was requested by Reference 2 and approved by the NRC in Reference 3. In NUREG-1431, Standard Technical Specifications (STS) for Westinghouse plants (Reference 1), Revision 2, which is the revision used by l&M to convert to STS, a similar NOTE is provided: -

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

The Note in the CNP TS to allow only penetration flow paths that go through the auxiliary building vent to be unisolated during movement of irradiated fuel within containment is more restrictive than the industry standard text provided in Reference 1. In the STS, the Note allows for any penetration flow path from the containment atmosphere to the outside atmosphere to be unisolated under administrative controls during movement of irradiated fuel, whereas administrative controls for CNP containment penetrations are limited to _those that exit through the auxiliary building vent.

The restriction of allowing only those containment penetrations that flow through the auxiliary building vent to be unisolated during movement of irradiated fuel within containment reduces the flexibility for scheduling outage tasks.

to AEP-NRC-2016-65

  • Page 2 This restriction effectively eliminates some containment penetrations from being considered for administrative.controls. The option to allow ariy penetration to be open under administr;:ttive control is desired in order to allow concurrent performance of work activities during outages and extended shutdowns. For example, component cooling water system containment building penetrations that do not exit through the auxiliary building vent could be opened during fuel movement to support maintenance activities normally conducted during refueling outages, such as filling and venting of the system. Requiring penetrations that do not exit through the auxiliary building vent to be closed and allowing only an isolation valve, blind flange, or manual valve as the closure method also precludes conducting some leak rate surveillance activities during movement of irradiated fuel within containment. This has impacted scheduling of activities during past outages and will limit l&M efforts to shorten future refueling outages.

Proposed Change l&M proposes to revise the Note regarding TS LCO 3.9.3 to allow containment penetrations providing direct access from the containment atmosphere to the outside atmosphere that do not pass through the auxiliary building vent to be open under administrative control.

Removal of that restriction is appropriate because the FHA analysis contained in the license amendment request (LAR) to adopt full-scope alternative source term (AST) (Reference 4),

which was recently approved by the U. S. Nuclear Regulatory Commission (NRC)

(Reference 7), no longer assumes that activity released from containment goes through the auxiliary building vent. Therefore, l&M requests to remove the stipulation in the LCO Note that limits administrative controls only to those containment penetrations exiting to the outside atmosphere th~ough the auxiliary building vent.

3.0 TECHNICAL EVALUATION

By Reference 2, l&M requested approval for insertion of a Note to TS 3.9.3 that would allow penetrations to be open under administrative control. In Reference 2, l&M stated that the Note is similar to the Note contained in Reference 1 and application of the Note would be consistent with TSTF-312, Revision 1, "Administratively Control Containment Penetrations" (Reference 9).

Reference 1 incorporates TSTF-312, Revision 1. By Reference 3, the NRC approved the LAR in Reference 2. The change approved by Reference 3 to add the Note regarding TS LCO 3.9.3, allowing containment penetrations to be unisolated under administrative control, was based on criteria for granting this allowance as stated in Reference 9. These criteria require the following:

1. Confirmatory dose calculations for a FHA, as approved by the NRC Staff, which indicate acceptable radiological consequences, and
2. commitments to implement acceptable administrative procedures that ensure, in the event of a FHA (even though the containment fission product control function is not required to meet acceptable dose consequences), that the open penetration(s) can and will be promptly closed. The time to close such penetrations is to be included in the confirmatory dose calculations.

The only difference between the Note described in Reference 1 and the change requested by l&M in Reference 2 was addition of the restriction that limited CNP administrative controls only to those flow paths that exited containment through the auxiliary building vent. As described in to AEP-:-NRC-2016-65 Page 3 Reference 2, ifl1plementation of the Note regarding administrative controls for TS LCO 3.9.3 at CNP was in accordance with the criteria stated above.

Technical Basis for the Proposed Change The original request to insert the Note for TS LCO 3.9.3 was based on the FHA analysis in effect at that time. As described in Reference 2, the restriction related to ventilation paths that exit via the auxiliary building vent was necessary because the CNP FHA analysis for control room dose in effect at the time assumed that all activity released from containment would pass through the auxiliary building vent. This analysis did not bound releases from containment penetrations that do not communicate with the auxiliary building (e.g., main steam, blowdown, and main feed water). Therefore, the change proposed in Reference 2 allowing containment penetrations to be open under administrative control was limited to those penetrations "that communicate with the auxiliary building.

In contrast, the current CNP licensing basis, which uses AST accident analysis for the FHA in containment (Reference 7), assumes the activity release location for control room dose is a point on the external containment surface closest to the control room intakes. For releases to the exclusion area boundary (EAB) and low population zone (LPZ), the AST FHA analysis assumes the release location is the surface of containment. Dose consequence analyses

  • based on AST were submitted to the NRG by Reference 4 and supplemented by Reference 5. of Reference 6, which replaced Enclosure 9 of Reference 4, documents the calculations performed as part of the submittal. This revised FHA analysis no longer contains the assumption that all activity is released from containment through the auxiliary building vent.

The AST dose consequence analyses described in Reference 4, . and further explained in.

subsequent supplemental information, were approved by the NRG on October 20, 2016 (Reference 7). The dose calculations for the recently approved AST FHA analysis indicate acceptable radiological consequences.

The containment FHA dose consequence analysis release and receptor locations described in Reference 4 are illustrated below in Figure 1 for control room dose and Figure 2 for off-site dose. In Figure 1, points A through D represent the control room intakes and points E and F represent the closest point on each containment surface to the control room intakes. Points G and H are the release locations assumed in the previous analyses, the auxiliary building ventilation, which exhausts to the environment from the main containment vent. In Figure 2, points A and B represent release points directly on the containment surface for off-site dose consequence analyses. Points C and D are the release locations utilized in the previous analyses described in Reference 2.

Conclusion The proposed change is consistent with both Reference 1 and Reference 9. Since the FHA analysis now shows that the activity release from containment originates at a point closest to the control room rather than only through the auxiliary building vent, it is appropriate to remove that restriction from the Note for TS LCO 3.9.3. The proposed wording for the revised Note regarding administrative controls is consistent with the Note provided in Reference 1.

Implementation of administrative controls will be in accordance with the assumptions for containment closure contained in the NRG approved accident analyses (Reference 7) a,nd the conditions specified in the regulatory commitment identified in Reference 2. Therefore, revision of the Note associated with TS LCO 3.9.3 is technically justified.

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4.0 REGULATORY EVALUATION

Applicable Regulatory Requirements I Criteria TS 3.9.3, "Containment Penetrations," satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Criterion 3:

"A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."

The design basis accident of concern for this request is the FHA in containment. The regulatory basis for TS 3.9.3 is to ensure that the containment building is capable of containing fission product radioactivity that may be released from the reactor core following a FHA inside containment.

l&M revised the FHA analysis using the guidance provided in RG 1.183 (Reference 8) as part of its application to use AST. l&M concluded that the radiological consequences resulting from the postulated FHA using the AST at the EAB, LPZ, and in the control room are within the dose criteria specified in 10 CFR 50.67. In Reference 7, the NRC issued its safety evaluation with regards to using AST, which concluded the method, assumptions and parameters used in the analyses were consistent with the guidance provided in Reference 8.

This amendment request is based on a determination of acceptable dose consequences for the control room during a FHA in containment, which is consistent with the basis for the original amendment (Reference 3) that allowed containment penetrations to be unisolated under administrative control as discussed above. The proposed TS change does not modify the containment barrier functions.

No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, l&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend the Appendix A TS to Facility Operating Licenses DPR-58 and DPR-74. l&M proposes a change to TS 3.9.3, "Containment Penetrations," to revise the Note regarding the allowance of containment penetrations to .be unisolated under administrative controls during movement of irradiated fuel. l&M has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The accident in question for this submittal is the FHA. The analysis for the FHA was recently reviewed and approved by the NRC for a license amendment request regarding use of alternative source term. The proposed amendment to TS 3.9.3 does not impact the assumed release pathway for the accident and has no effect on the probability of the occurrence of any accident previously evaluated. The proposed change does not alter to AEP-NRC-2016-65 Page 6 any plant equipment or operating practices in such a manner that the probability of an accident previously evaluated is increased. The consequences of a FHA inside the containment building with open penetration flow paths is bounded by the current FHA analyses and administrative controls, so the probability of an accident is not affected by

. the status of the penetration flow paths. Therefore, the probability or consequences of an accident previously evaluated will not be significantly increased.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Allowing penetration flow paths to be open is not an initiator for any accident. The change impacts the containment requirements during refueling operations. The only accident which could result in significant releases of radioactivity during refueling is the FHA. The proposed change does not affect the design of containment, or alter plant operating practices such that it creates the possibility of a new or different kind of accident from any accident previously evaluated. The proposed allowance to open any containment penetration under administrative controls duririg fuel movement will not adversely affect plant safety functions such that a new or different accident could be created. No other initiators or accident precursors are created by this change.

Therefore, the possibility of a new or different kind of accident not previously evaluated is not created.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

TS 3.9.3 closure requirements for containment penetrations

  • ensure that the consequences of a postulated FHA inside containment during irradiated fuel handling activities are minimized. The LC.O establishes containment closure requirements, which limit the potential escape paths for fission products by ensuring that there is at least one barrier to the release of radioactive material. The proposed change to allow any containment penetration flow path to *be open during refueling operations under
  • administrative controls does not significantly affect the expected dose consequences of a FHA because the limiting FHA does not credit containment building closure or filtration.

The administrative controls provide assurance that closure of the applicable penetration flow paths will be accompllshed and that the offsite dose consequences will be minimized in the event of a FHA inside the containment building. Therefore, this proposed change does not involve a significant reduction in a margin of safety.

Based on the above, l&M concludes that the activities associated with the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

  • Enclosure 2 to AEP-NRC-2016-65 Page7

. ,, Conclusions In conclusion, based on the considerations discussed abov~. (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 amendment will not be inimical to the 'common defense and security
  • or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

    • 'A review has determined that the proposed amendment wo.uld change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the
  • proposed amendment does not !nvolve (i) a significant hazards consideration, (ii) a significant change *in the types or sighifi~aht increase iri the amounts of any effluent that may be released

,offsite, or (iii) a significant incr~ase in individual or cumulative occupational radiation exposure.

  • Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NUREG-1431, Revision 2, "Standard Technical Specifications -*Westinghouse Plants,"

published June 2001.

2. Letter from M. W. Hencheck, l&M, to NRC, "Donald C. Cook Nuclear Plant, Units 1 and 2 - License Amendment Request - Technical Specification Change for Inoperable AC.

or D.C. Distribution Systems in Modes 5 & 6 and for Containment Penetrations During Refueling, dated May 15, 2001, Agencywide Documents Access and Management System (ADAMS) Accession Number ML011380084.-

3. Letter from J. F. Stang, NRC, to R. P. Powers, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments (TAC Nos. MB1973 and MB1974), dated November 21, 2001, ADAMS Accession Number ML012770113.
4. Letter from J. P. Gebbie, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear Plant, Units 1 and 2, License Amendment Request to Adopt TSTF-490, Revision 0, "Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical

to AEP-NRC-2016-65 Page 8

5. Letter from J. P. Gebbie, l&M, to NRC, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2

- Supplemental Information for the License Amendment Request to Adopt TSTF-490, Revision 0, 'Deletion of E Bar Definition and Revision to Reactor Coolant System .

Specific Activity Technical Specification' and Implement Full-Scope Alternative Source Term," dated February 12, 2015, ADAMS Accession No. ML15050A247. *

6. Letter from Q. S. Lies, l&M, to NRC, "Donald C. Cook Plant Unit 1 and Unit 2, Response to Sixth Request for Additional Information Regarding the License Amendment Request to Adopt TSTf.-A90 and Implement Alternative Source Term," May 6, 201_6, ADAMS *.*'!

Accession No. ML 16t6aA115.

7. Letter from A. W. Dietrich, NRC, to J. P. Gebbie, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments Re: Adoption of TSTF-490, Rev. 0, "Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification" and Implementation of Full-Scope Alternative Source Term, (CAC Nos.

MF5184 and MF5185), dated October 20, 2016, ADAMS Accession No. ML t6242A 111. **

8. US NRC Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," July 2000.
9. Technical Specification Task Force (TSTF)-312, Revision 1, "Administratively Control Containment Penetrations," Approved August 16, 1999, ADAMS Accession No. ML040620147.

Enclosure 3 to AEP-NRC-2016-65 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked to Show Proposed Changes

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations

,)

LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch is closed and held in place by four bolts;
b. *, . One door in each air lock is capable of being closed; and

'*'I

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:
1. Closed by a manual or automatic isolation valve, blind flange, or .

equivalent; or

    • ~ .
2. Capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System.

N 0 TE--------------------------------------------

Pen etrat ion flow path(s) providing direct access from the containment atmosphere to the outside atmosphere via the auxiliary building vent may be unisolated under administrative controls.

APPLICABILITY: During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend movement of Immediately containment irradiated fuel assemblies penetrations not in within containment.

required status.

Cook Nuclear Plant Unit 1 3.9.3-1 Amendment No. 287

Enclosure 4 to AEP-NRC-2016-65 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked to Show Proposed Changes

. ~ .. :

Containment Penetrations 3.9.3

. 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch is closed and held in place by four bolts;
b. , One door*in each air lock is capable of being closed; a*nd
c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere is either:
  • ... 1. Closed by a manual or autornC!.ti,c isolation valve, 'blindflange, or equivalent; or .. * .** *
2. Capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System.

N 0 TE----------.:-~-.:-----------------------------

Pen etrat ion flow path(s) providing direct access from the containment atmosphere to the outside atmosphere via the auxiliary building vent may

  • be unisolated under administrative controls.

APPLICABILITY: During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETiON TIME A. One or more A.1 Suspend movement of Immediately

  • containment irradiated fuel assemblies penetrations not in within containment.

required status.

Cook Nuclear Plant Unit 2 3.9.3-1 Amendment No. 269

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