ML17334B499
| ML17334B499 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/22/1994 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17331B279 | List: |
| References | |
| AEP:NRC:1196, GL-93-05, GL-93-5, NUDOCS 9403040299 | |
| Download: ML17334B499 (13) | |
Text
~ACCELERATED DI, UTION DEMONS TION SYSTEM REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9403040299 DOC.DATE: 94/02/22 NOTARIZED: YES DOCKET g
FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana 6 Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) g
SUBJECT:
Application for amends to licenses DPR-58 6 DPR-74,reducing ns g I surveillance requirements for testing during power
/ecg+Q operation,per
DISTRIBUTION CODE:
AOOID COPIES RECEIVED:LTRj ENCL I
SIZE:
8 4 TITLE: OR Submittal:
General Distribution
/
NOTES:
RECIPIENT ID CODE/NAME PD3-1 LA HICKMAN,J INTERNAL: NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT OGC/HDS2 EXTERNAL: NRC PDR COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
0 1
1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DORS/OTS B NRR/DRPW NRR/DSSA/SRXB OC LFDCB G FIL 01 NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
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NOTE TO ALL"RIDS" RECIPIENTS:
PL ASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISI'RIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 16 ENCL 14 D
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Power Company P.O. Box 16631 Columbus, OH 43216 8
AEP: NRC: 1196 Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 LINE ITEM TECHNICAL SPECIFICATIONS IMPROVEMENTS TO REDUCE SURVEILLANCE REQUIREMENTS FOR TESTING DURING POWER OPERATION (GENERIC LETTER 93-05)
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
T ~
E. Murley February 22, 1994
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 implement changes that reduce surveillance requirements for testing during power operation, in accordance with Generic Letter 93-05.
Attachment 1 provides a detailed description of the proposed
- changes, the justification for the changes, and our determination of 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.
In addition, this is our second Cost Beneficial Licensing Action (CBLA) submittal and represents our highest priority item.
The lifetime cost savings associated with this CBLA are approximately
$4,600,000, as detailed in Attachment 4.
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.
These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee.
, 940304029"P 940222 tr l
PDR ADOCK 05000315 P
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Dr. T. E. Murley 2-AEP:NRC:1196 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.
This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached.
E.
E. Fitzp trick Vice President dr Attachments cc:
A. A. Blind G. Charnoff J.
B. Martin - Region III NFEM Section Chief NRC Resident Inspector J.
R. Padgett
A(
h<
\\
STATE OF OHIO)
COUNTY OF FRANKLIN)
E.
E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power
- Company, that he has read the foregoing TECHNICAL SPECIFICATION CHANGE REQUEST'INE ITEM TECHNICAL SPECIFICATIONS IMPROVEMENTS TO REDUCE SURVEILLANCE REQUIREMENTS FOR TESTING DURING POWER OPERATION (GENERIC LETTER 93-05) and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to before me this ~~~
day of 19~8 OTARY PUBLIC
~ RITA D. HILL
~ 80TAIIY PUBLIC. STATE OF OIIIO N
~.r
<r QQk
ATTACHMENT 1 TO AEP:NRC: 1196 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
.9403040299
Attachment 1 to AEP:NRC:1196 Page 1
A.
DESCRIPTION OF CHANGES The changes proposed by this letter are consistent with those endorsed by the NRC in Generic Letter 93-05, entitled "Line Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation."
This generic letter was the result of a comprehensive examination of surveillance requirements in Technical Specifications (T/Ss) that require testing during power operation.
This effort was a part of the NRC Technical Specifications Improvement Program.
The changes proposed in Generic Letter 93-05 are based on the results of the NRC's study, published as NUREG
- 1366, "Improvements to Technical Specifications Surveillance Requirements,"
in December 1992.
The changes are described individually as follows:
Control Rod Movement Test Generic Letter Section:
4.2 T/S:
4.1.3.1.2 (Units 1 and 2)
Page:
3/4 1-19 (Units 1 and 2)
The requirement to move full length rods at least eight steps in any one direction is changed from once per 31 days to once.
per 92 days.
2.
Radiation Monitors Generic Letter Section:
5.14 T/S:
Tables 4.3-2 and 4.3-3 (Units 1 and 2)
Page:
3/4 3-32, 3/4 3-38, 3/4 3-38a, 3/4 3-38b (Unit 1) 3/4 3-31, 3/4 3-37, 3/4 3-37a, 3/4 3-37b (Unit 2)
The requirement to perform channel functional testing for radiation monitoring channels is changed from monthly to quarterly.
3.
Containment Spray System Generic Letter Section:
8.1 T/S:
4.6.2.1.d (Units 1 and 2)
Page:
3/4 6-10 (Units 1 and 2)
The requirement to perform an air or smoke test through each spray header to verify the spray nozzles are unobstructed is changed from once per five years to once per ten years. It is noted that the spray nozzles employed at the Cook Nuclear Plant are stainless
- steel, not carbon steel.
Therefore, the
Attachment 1 to AEP:NRC:1196 Page 2
problems experienced at San Onofre Unit 1,
discussed in Generic Letter 93-05, are not applicable to the Cook Nuclear Plant.
4.
Hydrogen Recombiners Generic Letter Section:
8.5 T/S:
4.6.4.2.a (Units 1 and 2)
Page:
3/4 6-24 (Unit 1) 3/4 6-34 (Unit 2)
The requirement to perform a recombiner system functional test is changed from once per six months to once per eighteen months.
5.
Emergency Diesel Generator Surveillance Requirements Generic Letter Section:
10.1 T/S:
3.8.1.1 Actions a, b, c, and d; 4.8.1.1.2.e.7 (Units 1 and 2)
Page:
3/4 8-1, 3/4 8-2, 3/4 8-6 (Units 1 and 2) 1)
The action statements are modified to eliminate requirements to perform diesel generator testing due to inoperability of. offsite circuits.
2)
The action statements are rewritten to explicitly state that. testing of the redundant diesel generator is not required ifthe other diesel generator became inoperable due to an inoperable support system or a component that can be independently tested.
- Also, testing of the redundant diesel generator is not required if the absence of any potential common mode failure is demonstrated.
For action statement b,
the time to demonstrate operability of the remaining diesel is conservatively changed from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
3)
Following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> diehel run required by surveillance requirement 4.8.1.1.2.e.7, the requirement to 'perform surveillance requirement 4.8.1.1.2.e.4 (simulated loss of offsite power start and load test) is replaced with surveillance requirement 4.8.1.1.2.a.4 (diesel generator start test).
Surveillance requirement 4.8.1.1.2.a.4 specifically states that the diesel start is to be performed at ambient (i.e., cold) conditions.
Therefore, we have added a note to the proposed revised surveillance requirement 4.8.1.1.2.e.7 stating that the diesel generator start performed within five minutes of
Attachment 1 to AEP:NRC:1196 Page 3
the 24-hour run is conducted at "existing" conditions.
- Also, a
footnote is added indicating that if surveillance requirement 4.8.1.1.2.a.4 is not performed satisfactorily following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, the diesel generator may be operated at 3500 kw (continuous rating) for two hours or until operating temperature has stabilized prior to retest (i.e., the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run does not have'o be repeated).
6.
Special Test Exceptions
- Shutdown Margin Generic Letter Section:
12 T/S:
4.10.1.2 (Units 1 and 2)
Page:
3/4 10-1 (Units 1 and 2)
The requirement to perform a rod drop test for full length rods that are not fully inserted is changed from within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to within 7 days prior to reducing shutdown margin below the limits of T/S 3.1.1.1.
7.
Radioactive Effluents - Waste Gas Storage Tanks Generic Letter Section:
13 T/S:
4.11.2.6 (Units 1 and 2)
Page:
3/4 11-14 (Units 1 and 2)
The requirement to verify the quantity of radioactive material contained in each gas storage tank is changed from once per 4 days to once per 7 days whenever radioactive materials are added to the tank and to once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> during primary coolant system degassing operations.
B.
JUSTIFICATION FOR CHANGES The changes proposed in this letter are consistent with guidance provided in Generic Letter 93-05.
This generic letter was the result of a comprehensive examination of surveillance requirements in T/Ss that require testing during power operation.
This effort was part of the NRC's T/S Improvement Program.
In performing this study, which was published as NUREG 1366, the NRC staff found that, while the majority of the testing at power is important, safety can be
- improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated by reducing the amount. of testing that the T/Ss require during power operation.
Generic Letter 93-05 provided guidance to assist licensees in preparing a
license amendment request to implement the staff recommendations as line-item improvements.'
Attachment 1 to AEP:NRC:1196 Page 4
Generic Letter 93-05 stated that licensees should not propose changes to extend any surveillance interval if the recommendations of NUREG-1366 are not compatible with plant operating experience.
We have reviewed our proposed changes against our operating experience and have found them to be compatible.
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:
l.
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 3.
involve a significant reduction in a margin of safety.
Criterion 1 Although the surveillance requirements are lessened by these proposed
- changes, the changes are consistent with those found acceptable by the NRC in Generic Letter 93-05.
The proposed changes have been determined to be compatible with our plant operating experience.
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 changes only involve the frequency of testing required to be performed.
The changes are consistent with those found to be acceptable by the NRC in Generic Letter 93-05.,
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 Although the surveillance requirements are lessened by these proposed
- changes, the changes are consistent with those found acceptable by the NRC in Generic Letter 93-05.
The proposed changes have been determined to be compatible with our plant operating experience.
Based on these considerations, it is concluded that the changes do not involve a
significant reduction in a margin of safety.