ML17333A239

Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 3/4.6.1.2,3/4.6.1.3,3/4.6.1.6 & 3/4.6.1.6 to Require Types A,B & C Tests (Overall Integrated & Local Containment Leakage Rate) to Be Performed Per 10CFR50,App J Option B

ML17333A239
Person / Time
Site:	Cook
Issue date:	12/19/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17333A240	List: ML17333A239 ML17333A241
References
AEP:NRC:1215B, NUDOCS 9512260230
Download: ML17333A239 (12)

Text

F'RI CHARITY (ACCELERATED RIDS PROCESSIiC REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9512260230 DOC.DATE: 95/12/19 FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana NOTARIZED: YES DOCKET I M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION P FITZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Application for amends to licenses DPR-58 & DPR-74,modifying TS 3/4.6.1.2,3/4.6.1.3,3/4.6.1.6 & 3/4.6.1.6 to require Types A,B & C tests (overall integrated & local containment leakage rate) to be performed per 10CFR50,App J Option B. 0 DISTRIBUTION CODE: A017D COPIES RECEIVED:LTR ! ENCL J SIZE:

TITLE: OR Submittal: Append J Containment Leak Rate Testing NOTES:

RECIPIENT COPIES RECIPIENT COPIES

'E ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 0 PD3-1 PD 1 1 HICKMAN,J 1 1 INTERNA . HR~ 1 1 1 NRR/DE/ECGB 1 1 NRR/DSSA/SCSB 1 1 OGC/HDS2 1 1 RES/DE/SEB 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT TI IE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELlihIINATEYOUR NAME PRO.'iI DISTRIBUTION LISTS I'OR DOCI 'MENTS YOU DON"I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 10 ENCL 9

!f Indiana Michigan power Company PO Box 16631 Columbus, OH 43216 N

INSIANA NICHISAN PQWKR December 19, 1995 AEP'NRC:1215B Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

'Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION SECTIONS

/4.6.1.2, 3/4.6.1.3, 3/4.6.1 ~ 6, AND 3/4.6.1.7 FOR CONTAINMENT LEAKAGE AND INSPECTION REQUIREMENTS This letter and its attachments constitute an application for amendment to the technical specifications (T/Ss) for Donald C. Cook Nuclear Plant units 1 and 2 Specifically, we are

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proposing to modify T/Ss 3/4.6.1.2, 3/4.6.1. ,

3/4.6.1.7 by replacing the existing (Option A) scheduling

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requirements for Types A, B, and C tests (overall integrated and local containment leakage rate) with a requirement to perform A B d C testing in accordance with 10 CFR 50 Appendix J Option B. The final rule for Appendix J Option B was publisshed e

in the Federal Register on September 26, 1995, (60 FR 49495) and was effective October 26, 1995. The rule provides a performance-based option for leakage-rate testing of light water reactor containments. The changes are consistent with guidance provided in SECY-95-181, Rulemakin Issue Affirmatio , dated Jul u y 17, 1995, from James M. Taylor to the Commissioners. The changes being proposed were also discussed with Mr. r. J. B. Hickman in a November 17, 1995, teleconference.

Attachment 1 provides a detailed description of the proposed

'fchanges, the justification for the changes, and our determination no significant hazards consideration performed pursuant to 10 CFR 50.92. Attachment 2 contains the existing T/S pages marked to reflect the proposed changes. Attachment 3 contains the proposed T/S pages.

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

LQ 95i2260230 95i219 PDR ADOCK OS000315 P PDR

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gc U.S. Nuclear Regulatory Commission AEP:NRC:1215B Page 2 These proposed 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)(1), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.

We request NRC approval of the proposed amendment by February 28, 1996, to facilitate scheduling of work for the March 1996 outage on Cook Nuclear Plant Unit 2.

Sincerely, E. E. Fitzpatrick Vice President.

SWORN TO AND SUBSCRIBED BEFORE ME THIS ~~ DAY OF 1995 Notary Public My Commission Expires: 4 -Wd'-

99'ttachments CC: A. A. Blind G. Charnoff J. B. Martin NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett

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ATTACHMENT 1 TO AEP:NRC:1215B DESCRIPTION AND JUSTIFICATION OF CHANGES 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS

f to AEP:NRC 1215B Page 1 DESCRIPTION OF CHANGES The proposed amendment to Technical Specifications (T/Ss) 3/4.6.1:2, 3/4.6.1.3, 3/4.6.1.6, and 3/4.6.1.7 makes the following specific changes to the Cook Nuclear Plant Units 1 and 2 T/Ss:

A. Revises the wording in the Unit 1 T/Ss Action Statements for T/Ss 3.6.1.2, 3.6.1.6, and Limiting Condition For Operation for T/S 3.6.1.3.b to make the wording consistent with Unit 2.

These are administrative changes that do not change the content of the T/Ss.

B. Removes Surveillance Requirement 4.6.1.2.a, renumbers 4.6.1.2.b and 4.6.1.2.c, and replaces the general statement of T/S 4.6.1.2 for Unit 1 and Unit 2 with the following:

"Perform leakage rate testing in accordance with 10 CFR 50 Appendix J Option B and Regulatory Guide 1.163, dated September 1995."

Removes the note at the bottom of page 3/4.6-2 for T/S 4.6.1.2 for Unit 1 that would have required a Type A test to be performed at the end of Cycle 15. This test will be performed in accordance with the scheduling requirements of Appendix J Option B.

D. Removes a note from the bottom of page 3/4.6-2 for T/S 4.6.1.2 of Unit 2 that allowed a one-time exemption to Appendix J to extend the test interval to the end of the Cycle 9-10 refueling outage. The exemption has expired and is no longer needed in the T/Ss.

Reverses, Surveillance Requirement 4.6.1.3 to remove the specific requirements for Airlock Door Testing and replaces the general statement of T/S 4.6.1.3.a for Unit 1 and Unit 2 with the following:

"In accordance with 10 CFR 50 Appendix J Option B and Regulatory Guide 1.163, dated September 1995, and" The modified statement proposed above incorporates Surveillance Requirements 4.6.1.3.a, b, and c for Air Lock Leak Rate Testing into the single statement and renumbers requirement 4.6.1.3.d. It also removes the exemption to Appendix J that currently exists. These testing requirements are specified in Appendix J to 10 CFR 50 by reference to Regulatory Guide 1.163 and NEI 94-01, Revision 0, "industry Guideline For Im lementin er ormance-Based 0 tion of 10 C Part 50 A endix J." Therefore, it is not necessary to repeat these requirements in the T/Ss given the above to AEP:NRC:1215B Page 2 suggested change. Due to the amount of verbiage being deleted, Page 3/4 6-5 of both Units 1 and 2 T/Ss will be left blank.

Revises Surveillance Requirement 4.6.1.6 for containment inspection criteria for Unit 1 and Unit 2 with the following statement:

"The structural integrity of the containment structure and steel liner shall be determined in accordance with 10 CFR 50 Appendix J Option B and Regulatory Guide 1 ~ 163, dated September 1995."

Unit 1 and Unit 2 T/Ss 4.6.1.7.1 were revised to add the surveillance requirements of T/Ss 3/4.6.1.2 to it. Type C testing, as disseminated in Appendix J, is required for the containment purge exhaust and isolation valves. This testing has always been completed but was never specifically addressed in the T/Ss.

II. JUSTIFICATION FOR CHANGES The changes proposed to the T/Ss are based on the NRC's Marginal-to-Safety Program to make regulatory requirements more efficient by eliminating those with marginal impact on safety. Appendix J was identified in 1986 as a candidate for update based on this program.

A concerted effort has taken place over the past three years to revise Appendix J to give utilities the option of a performance-based rule.

The justification for changing to a performance-based leakage-rate testing approach for light water reactor containments is discussed in detail in the Federal Register (60 FR 49495) final rule notification for Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, dated September 26, 1995. The rule change is based on analytical efforts documented in NUREG-1493, which confirms previous observations of insensitivity of population risks from severe reactor accidents to containment leakage rates.

Basically, the rule allows utilities to adopt a performance-based testing approach to Types A, B, and C tests. The specific testing requirements are instituted in the Code of Federal Regulations by reference to Regulatory Guide 1.163 (September 1995), which in turn references industry guideline NEI 94-01, "Industr Guideline For Im lementin Performance-Based 0 tion Of 10 CFR Part 50 A endix J"', and ANSI/ANS-56.8-1994, "Conta nment S stem Leaka e Testin Re uirements." These documents provide the guidance for establishing a performance-based leakage-rate testing program. Listed below are some of the specifics of the rule change that are taken from the Federal Register publication of the final rule:

to AEP:NRC:1215B Page 3 Type A Test Interval (1) Based on the limited value of integrat:ed leakage-rate test:s (ILRTs) in detecting significant:

leakages from penetrations and isolation valves, est:ablish the test interval based on the performance of the containment system structure; (2) The performance criterion of the test will continue to be the allowable leakage rate (La); (3) The industry guideline allows extension of the Type A test interval to once every t:en years based on satisfactory performance of two previous tests, inclusive of the pre-operational ILRT; (4) In the regulatory guide, the NRC takes exception to industry guidance for the extension of the interval of the general visual inspection of the containment system, and limits the interval to 3 times every 10 years, in accordance with current practice.

Type B 6 C Test Interval (1) Allow local leakage-rate test (LLRTs) int:ervals to be established based on the performance history of each component; (2) The performance criterion for the tests will continue to be (0.60 of] the allowable leakage rate (La); (3) Specific performance factors for establishing extended test intervals (up t:o 10 years for Type B components, and 5 years for Type C components) are contained in the regulatory guide and industry guideline. In the regulatory guide, the NRC has taken exception t:o the NEI guideline allowing t'e extension of Type C test intervals up to 10 years, and limits such extensions to 5 years.

All of these requirements are being implemented in the Cook Nuclear Plant T/Ss by reference to Appendix J Option B and Regulatory Guide 1.163. Some particular points to address include our understanding of the requirements for testing of the containment air locks and the containment purge exhaust and isolation valves. The current T/Ss at Cook Nuclear Plant have an exemption to Appendix J to perform a between the seals test on the doors at least once per 3 days. This exemption is no longer necessary because the new rule allows doors that are utilized for multiple containment entries (more than once every 7 days) to have their seals tested once per 30 days. In addition to this, the overall airlock test will now be performed once every 30 months, as opposed to once every six months. With regards to the containment purge and exhaust isolation valves, understood that the test interval is limited to 30 months as it is specified in Section 3.3.4 of ANSI/ANS-56.8-1994.

understood that the detailed licensee programs for conducting It is also testing under Option B will be available at the plant site for NRC inspection. This program will include the necessary procedures for performing Types A, B, and C tests, as well as the history of Types A, B, and C tests used to establish the test intervals.

to AEP:NRC:1215B Page 4 III. 10 CFR 50 92 CRITERIA Per 10 CFR 50.92, a proposed change does not involve a significant hazards consideration if the change does not:

involve a significant increase in the probability or consequences of an accident previously evaluated,

2. create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant redu'ction in a margin of safety.

Criterion 1 This amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes to the T/Ss do not affect the assumptions, parameters, or results of any UFSAR accident analysis.

The proposed changes do not change the acceptance criteria for containment leakage limits and do not modify the response of the containment during' design basis accident. The proposed amendment does not add or modify any existing equipment. The proposed Types A, B, and C testing schedules will be consistent with Appendix J, Option B to 10 CFR 50 which was developed based on analytical efforts documented in NUREG-1493. The analysis confirms previous observations of insensitivity of population risks from severe reactor accidents to containment leakage rates. Based on these considerations, it is concluded that the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2 The proposed changes do not involve physical changes to the plant or changes in plant operating configuration. The proposed changes only remove the restrictive schedular requirements for..conducting Types A, B, and C testing from the T/Ss and substitute the schedule specified in Appendix J Option B to 10 CFR 50 and Regulatory Guide 1.163. Thus, it is concluded that the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3 Based on NUREG-1493, Regulatory Guide 1,163, and the rule posting in the Federal Register (60 FR 49495), the margin for safety presently provided is not significantly reduced by the proposed change to a performance-based test interval for Types A, B, and C tests.

Although the changes allow more flexibilityin scheduling tests, the

I k to AEP:NRC:1215B Page 5 proposed amendment continues to ensure reactor containment system reliability by periodic testing in full compliance with 10 CFR 50, Appendix J Option B. Based on these considerations, it is concluded that the changes do not involve a significant reduction in a margin of safety.