ML17332A500
| ML17332A500 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/05/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17332A499 | List: |
| References | |
| NUDOCS 9501100241 | |
| Download: ML17332A500 (3) | |
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 187 TO FACILITY OPERATING LICENSE NO.
DPR-58 AND AMENDMENT NO.
173 TO FACILITY OPERATING LICENSE NO.
DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 AND 2 DOCKET NOS.
50-315 AND 50-316
1.0 INTRODUCTION
By letter dated July 19, 1994, the Indiana Michigan Power Company (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License Nos.
DPR-58 and DPR-74 for the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2.
The proposed amendments would remove the specific scheduling requirements for Types A, B, and C containment leakage rate tests from the TS and replace these requirements with a requirement to perform Types A, B, and C testing in accordance with Appendix J to 10 CFR Part 50.
Additional editorial and administrative changes were also proposed.
- 2. 0 EVALUATION Cook TS 4.6. 1.2.a. currently requires that a set of three Type A tests be performed specifically at 40 2 10-month intervals during each 10-year service period, with the third test of each set performed during the shutdown for the 10-year plant inservice inspection.
Section III.D. of Appendix J to 10 CFR Part 50 requires that Type A tests of the containment be scheduled as a set of three tests, to be performed at approximately equal intervals, during each 10-year service period, with the third'et to coincide with the shutdown for the 10-year plant inservice inspection.
While the Cook TS essentially duplicate the requirements of Appendix J to 10 CFR Part 50, the TS contain the additional requirement that Type A testing be performed at 40 k 10 month intervals.
For units, such as
- Cook, on 18-month fuel cycles the 40 + 10 month requirement essentially requires performance of a test every two fuel cycles as three cycles would be 54 months which exceeds the allowance.
Since a test is required every two cycles over a 10-year period, this necessitates either the performance of a fou}th test or the request for a period extension between two of the tests.
Due to this scheduling difficulty the licensee has proposed to revise the TS requirement for Type A tests to simply reference the requirements of Appendix J to 10 CFR Part 50, as modified by approved exemptions.
Satisfactory leakage results are a requirement for the establishment of containment operability.
Neither the general frequency nor the required number of Type A tests would be changed by the proposed changes.
Also, the maximum allowable leakage rate at the calculated peak containment
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pressure would not be changed.
Only the dethiled 40 + 10-month test interval would be changed to provide more flexibility.
Type A test acceptance criteria would not be changed.
The proposed changes do not impact the design basis of the containment and would not change the response of containment during a
design basis accident.
Finally, the testing method, acceptance
- criteria, and the Bases to the TS are not changed by the proposed revisions to the TS.
Therefore, based on all of the above, the staff finds the revision to TS 4.6.1.2.a.
to be acceptable.
TS 4.6.1.2.b., 4.6.1.2.c.l.,
4.6.1.2.c.2.
contain additional testing requirements regarding the schedule for retesting if a test faily to meet the 0.75 L, requirement and supplemental testing to verify accuracy of Type A tests.
These testing requirements in the TS and in Appendix J to 10 CFR Part 50 are virtually identical except for minor grammatical differences.
The licensee has proposed to delete these TS for simplicity.
Since the regulatory and TS requirements are essentially identical, the proposed deletion is administrative and acceptable.
TS 4.6. 1.2.c.3.
and TS 4.6. 1.2.f. provide specific testing direction regarding the quantity of gas to be displaced during a supplemental Type A test, and calculational methodologies for leakage rates and error analyses.
The licensee stated that these Type A test requirements are also specified in Appendix J to 10 CFR Part 50 and need not be reiterated in the TS.
- However, Surveillance Requirements 4.6. 1.2.c.3.
and 4.6. 1.2.f. are not specified in Appendix J to the same level of detail.
While 4.6. 1.2.c.3.
mandates a
specific quantity of gas to be displaced from containment during a
supplemental
- test, Appendix J refers to Appendix C of ANSI N45.4-1972 for guidance on an acceptable supplemental test.
TS 4.6. 1.2.f. requires an error analysis for leakage rate calculations while Appendix J only requires correcting for instrument error.
Although the requirements are not specified in the same level of detail in Appendix J as in the TS surveillance requirements, the requirement for a supplemental test and general requirements for the accuracy of the test are specified in Appendix J.
In addition, it is not necessary for the TS to contain the level of detail specified in sections 4.6. 1.2.c.3.
and 4.6. 1.2.f.
For example, the improved Standard Technical Specifications for Westinghouse
- Plants, NUREG-1431,are consistent with the licensee's proposal in this respect.
Based on the above, the staff finds the deletion of TS 4.6. 1.2.c.3.
and TS 4.6. 1.2.f. to be acceptable.
The licensee has also proposed that TS 4.6. 1.2.e.,
which specifies requirements for pressure and intervals for Type B and C tests, be replaced with a requirement that Type 8 and C testing be conducted in accordance with Appendix J to 10 CFR Part 50, as modified by approved exemptions.
Since the requirements for Type B and C testing are specified in greater detail in Appendix J, the deletion from the TS has no impact on the requirement imposed on the licensee and is, therefore, acceptable.
Finally, the licensee has proposed as an addition to the Unit 1 TS, the statement that the provisions of Specification 4.0.2 are not applicable.
Unit 2's TS already contain this statement.
TS 4.0.2 specifies that surveillances shall be performed within the required time interval with a maximum extension of 25M.
However, the requirements of Appendix J to 10 CFR Part 50 would be violated if this extension were used.
Therefore, since the addition of Specification 4.0.2 inapplicability is conservative by maintaining a more stringent schedule requirement, the staff finds the change acceptable.
3.0 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.
- 4. 0 ENVIRONMENTAL CONSIDERATION The amendments change the requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and 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 a
proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (59 FR 49430).
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 conn'ection with the issuance of the amendments.
5.0 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:
John B. Hickman, NRR Date:
january 5, 1995