ML17328A151

Application for Amends to Licenses DPR-58 & DPR-74,modifying ESF & Storage Pool Ventilation Sys Tech Specs 3/4.7.6.1 & 3/4.9.12,respectively,such That Temp at Which Lab Testing of Charcoal Samples Conducted Decreased to 30 C

ML17328A151
Person / Time
Site:	Cook
Issue date:	09/15/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17328A152	List: ML17328A151 ML17328A153
References
AEP:NRC:0959B, AEP:NRC:959B, NUDOCS 8909220025
Download: ML17328A151 (8)

Text

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ACCESSION NBR:8909220025 DOC.DATE: 89/09/15 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana 6 05000316 AUTH. NAME AUTHOR AFFILIATION ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana 6 Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to Licenses DPR-58 & DPR-74,modifying Tech Specs 3/4;7.6.1 6 3/4.9.12. 'I DISTRIBUTION CODE: AOOID TITLE: OR Submittal: General Distribution COPIES RECEIVED:LTR ( ENCL L SIZE:

NOTES:

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Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 8

AEP:NRC:0959B Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos 50-315 and 50-316

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License Nos. DPR-58 and DPR-74 ESF AND STORAGE POOL VENTILATION SYSTEMS CHARCOAL LAB TEST TEMPERATURE TECHNICAL SPECIFICATION CHANGE U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Attn: T. E. Murley September 15, 1989

Dear Dr. Murley:

This letter and its attachments constitute an application for amendment to the Technical Specifications (T/Ss) for the Donald C. Cook Nuclear Plant Units 1 and 2. Specifically, we are proposing to modify the Engineered Safeguards Features (ESF) and Storage Pool Ventilation System T/Ss-(3/4.7.6.1 and 3/4.9.12, respectively) such that the temperature at which laboratory testing of charcoal0 samples0 is conducted is conservatively decreased from 130 C to 30 C. This change is in response to a recommendation from your staff. The reasons for the proposed change and our analysis concerning significant hazards considerations are contained in Attachment 1 to this letter. The proposed revised T/S pages are contained in Attachment 2.

We believe that the proposed changes will not result in (1) a significant change in the types of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

These changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee.

In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to Mr. R. C. Callen of the Michigan Public Service Commission and to the Michigan Department of Public Health.

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Dr. T. E. Murley AEP:NRC:0959B This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Sincerely, M. . Al xich Vice Pr sident MPA/eh Attachments cc: D. H. Williams, Jr.

W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff NFEM Section Chief A. B. Davis - Region III NRC Resident Inspector - Bridgman

ATTACHMENT 1 TO AEP:NRC:0959B REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS

Attachment To AEP:NRC:0959B Page 1 This letter proposes to change the temperature at which laboratory testing of charcoal samples is conducted for the ESF and storage pool ventilation systems from 130 C to 30 C. The specific technical specifications (T/Ss) that are affected for both units by this change are:

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Unit 1 Unit 2 3/4 7-24......3/4 7-18 '....4.7.6.1.b.4 3/4 7-24......3/4 7-18......4.7.6.1.c.l 3/4 7-24......3/4 7-18......4.7.6.1.c.2 3/4 9-14......3/4 9-13......4.9.12.b.4 3/4 9-14......3/4 9-14......4.9.12.c.l 3/4 9-15......3/4 9-14......4.9.12.c.2 The staff's concern, expressed in a meeting held in the NRC's office in January 1986< was that the efficiencies determined under test conditions of 130 C might not be indicative of efficiencies that could be anticipated under accident conditions. This was because the high laboratory test temperature might cause vaporization of volatile filter contaminants, including moisture, thus increasing the indicated charcoal efficiency.

In the January 1986 0 meeting, members of your staff recommended 0 that we adopt 30 C as the test temperature. The change from 130 C to 030 0 C is in the conservative direction. The temperature of 130 C in our present T/Ss was related to a previous T/S requirement to perform the laboratory testing of the charcoal samples in accordance with the 1975 version of ANSI N510. ANSI N510-1975, referenced the RDT M 16-1T-1973 standard for the laboratory test. This standard specified a test condition of 130 C. In T/S Amendments 124 (Unit 1) and ill (Unit 2) we received approval to change from the 1975 version to the 1980 version. The 1980 version references ASTM D 3803 1979 as the laboratory testing standard, and states that test conditions shall be in accordance with the plant's T/Ss. In our letter AEP:NRC:0959, dated May 28, 1987, we committed to conducting testing (at 30 C and 130 C) to evaluate the staff's 'arallel concern. The testing was conducted over a period of approximately 18 months and involved 9 parallel tests. The testing confirmed that at 30 0 C, the measured charcoal efficiency is lower, and therefore we are proposing to adopt your staff's recommendation.

A similar change was recently proposed for the control room ventilation system in our letter AEP:NRC:0398R, dated June 29, 1989.

Attachment To AEP:NRC:0959B Page 2 We are also proposing a related administrative change in this letter. We are proposing to delineate ASTM D 3803-1979 as the test standard for the charcoal laboratory test. This was proposed for the control room ventilation system in AEP:NRC:0398R at the recommendation of your staff. Since it is equally applicable to the ESF and storage pool ventilation systems, we are proposing it for those units also.

Per 10 CFR 50.92, a proposed amendment will not involve significant hazards consideration if the proposed amendment does not:

(1) involve a significant increase in the probability or consequences of a previously evaluated accident, (2) create the possibility of a new or different kind of accident from any previously analyzed or evaluated, or (3) involve a significant reduction in a margin of safety.

Criterion 1 The change from 130 0 C to 30 0 C for the charcoal laboratory test is in the conservative direction, since the change will make it more difficult for the charcoal to meet the T/S-required efficiency. Thus, the change should increase the margin of safety, and should not involve an increase in the probability or consequences of a previously evaluated accident. The delineation of ASTM D 3803-1979 as the test standard for the charcoal is administrative in nature, and will not impact plant safety.

Criterion 2 The changes involve no physical changes to the plant nor any changes in plant operations. Therefore, the change should not create the possibility of a new or different kind of accident from any previously analyzed or evalu'ated.

Criterion 3 See Criterion 1, above.

Lastly, we note that the Commission has provided guidance concerning the determination of significant hazards by providing examples (48 FR 14870) of amendments considered not likely to involve significant hazards consideration. The second of these .

Attachment To AEP:NRC:0959B Page 3 examples refers to changes which constitute additional limitations, restrictions, or controls not presently included0 in the0 T/Ss. This example is applicable to the change from 130 C to 30 C for the charcoal laboratory test, since the change will make it more difficult for the charcoal to meet the T/S-required efficiency. The first example refers to changes which are purely administrative in nature. This example is applicable to the delineation of ASTM D 3803 - 1979 as the laboratory test standard for the charcoal, since ASTM D 3803-1979 is the standard referenced by ANSI N510-1980. For these reasons, we believe the examples cited are relevant and conclude that the changes should not require significant hazards consideration.