ML17332A969
| ML17332A969 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/10/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17332A968 | List: |
| References | |
| NUDOCS 9510170035 | |
| Download: ML17332A969 (5) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
202TO FACILITY OPERATING LICENSE NO.
DPR 58 ND AMENDMENT NO.
>87 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 May 26,
- 1995, 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 change the TS to modify the requirements of TS 3/4.3. 1 and TS 3/4.3.2 and relocate Tables
'3.3-2 and 3.3-5, which provide the response time limits for the reactor trip system (RTS) and the engineered safety features actuation system (ESFAS) instruments, from the TS to the Updated Final Safety Analysis Report (UFSAR).
The licensee has stated that the next update of the UFSAR will include these tables.
The NRC provided guidance to all holders of operating licenses or construction permits for nuclear power reactors on the proposed TS changes in Generic Letter 93-08, "Relocation of Technical Specification Tables of Instrument
Response
Time Limits," dated December 29, 1993.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TS as part of the license.
The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36.
That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
Ho'wever, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission provided guidance for the contents of TS in its "Final Policy Statement on T'echnical Specifications Improvements for Nuclear Power Reactors"
("Final Policy Statement" ), 58'R 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
These criteria were subsequently incorporated into the regulations by an amendment to 10 CFR 50.36, 60 FR 36953 (July 19, 1995).
In particular, the Commission indicated that certain items could be relocated 95fOf70035 95fOfO PDR ADOCK 050003f5;i P'
from the.TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant),
ALAB-531, 9
NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that "technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the four criteria defined by 10 CFR 50.36, for determining whether a particular matter is required to be included in the TS limiting conditions for operation, are as follows:
(1) Installed instrumentation that is used to detect, and indicate in the control
- room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process
- variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (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; (4) a structure,
- system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the above criteria must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
- 3. 0 EVALUATION The licensee has proposed changes to TS 3.3. 1. 1 and 3.3.2. 1 to remove references to Tables 3.3-2 and 3.3-5, which are being deleted from the TS.
The licensee committed to relocate the tables on response time limits to the UFSAR in the next periodic update.
k Tables 3.3-2 and 3.3-5 contain the values of the response time limits for the
'TS and ESFAS instruments.
The limiting conditions for operation for the RTS and ESFAS instrumentation specify these systems shall be operable with the.
response times as specified in these tables.
These limits are the acceptance criteria for the response time tests performed to satisfy the surveillance requirements of TS 4.3. 1 and 4.3.2 for each applicable RTS and ESFAS trip function.
These surveillances ensure that the response times of the RTS and ESFAS instruments are consistent with the assumptions for the safety, analyses performed for design basis accidents and transients.
The changes associated with the implementation of Generic Letter 93-08 involve only the relocation of the RTS and ESFAS response time tables but retain the surveillance requirement to perform response time testing.
The UFSAR will now contain the acceptance criteria for the required RTS and ESFAS response time surveillances.
Because it does not alter the TS requirements to ensure that the response times of the RTS and ESFAS instruments are within their limits, the staff has concluded that relocation of these response time limit tables from the TS to UFSAR is acceptable.
The staff's determination is based on the fact that the removal of the specific response time tables does not eliminate the requirements for the licensee to ensure that the protection instrumentation is capable of performing its safety function.
Although the tables containing the specific response time requirements are relocated from the TS to the UFSAR, the licensee must continue to evaluate any changes to response time requirements in accordance with 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously,'r (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
The staff's review concluded that 10 CFR 50.36 does not require the response time tables to be retained in technical specifications.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure response times, for RTS and ESFAS systems are retained due to those systems'mportance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of specific response time requirements for the various instrumentation channels and components addressed by Generic Letter 93-08 was not required.
The response times are considered to be an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore,
'the continued processing of license amendments related to revisions of the affected instrument or component response
- times, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
- Further, the response time requirements do not constitute a condition or limitation on operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, in that the ability of the RTS and ESFAS systems to perform their safety functions are not adversely impacted by the relocation of the response time tables from the TS to the UFSAR.
In addition to removing the response times from the TS, the licensee is modifying the TS Bases Sections 3/4.3.1 and 3/4.3.2 to reflect these changes and has stated that the plant procedures for response time testing include acceptance criteria that reflect the RTS and ESFAS response time limits in the tables being relocated to the UFSAR.
These changes are acceptable in that they merely constitute administrative changes required to implement the TS change discussed above.
These TS changes are consistent with the guidance provided in Generic Letter 93-08 and the TS requirement of 10 CFR 50.36.
The staff has determined
I
that the 'proposed changes to the TS for the D.C.
Cook Nuclear Plant, Units 1
and 2, are acceptable.
4.0 STA E
CONSU TATIO In accordance with the Commission's regulations, the State of Michigan official was notified of the proposed issuance of the amendment.
The State official had no comments'.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements.
The NRC staff has determined that the amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (59 FR 629).
Accordingly, the amendment meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51 '2(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 amendment
6.0 CONCLUSION
The Commission 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 amendment will not be inimical to the common defense and security or to the health and safety of the public Principal Contributors:
William Reckley Janet Kennedy Date:
October 10, 1995