ML17334B776

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Safety Evaluation Supporting Amend 158 to License DPR-74
ML17334B776
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 12/22/1993
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML17334B775 List:
References
NUDOCS 9805210379
Download: ML17334B776 (5)


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TI UNITEDSTATES CLEAR REGULATORY COMMISSIO WASHINGTON,D. C. 20555 U

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By letter dated April 16,

1993, as supplemented September 28, and December 3, 1993, the Indiana Michigan Power Company (the licensee) requested an amendment to the Technical Specifications (TS) appended to Facility Operating License No. DPR-74 for the Donald C. Cook Nuclear Plant, Unit No. 2.

The licensee's supplemental, letters provided.clarifying information and did not change the staff's initi'al proposed no significant hazards consideration determination published in the Eedera1 ILee,stat.

(58 FR 41Ri05).

The proposed amendment would extend specific TS surveillances which have various due dates, the first of which is January 2, 1994.

The surveillances would be extended to the Unit 2 refueling outage, which is currently scheduled to begin August 6, 1994.

All of the requested surveillance extensions are associated'with surveillances normally performed during refueling outages.

The current cycle will be lengthened approximately 5 months due to a planned power reduction in order to separate the current dual unit outages.

The licensee classified the affected TS into 16 groups.

This amendment pertains only to the following four groups of TS-surveillances:

eIOR IRSAFT I

(1) 4.3.1.1.3 4.3.2.1.3 escri t o of Chan

.Delay time-response testing for reactor trip and engineered safety features instrumentation (2) 4.5.l.d 4.5.2.e 4.6.2.1.c 4.6.2.2.c 4.6.3.1.2 4.7.1.2.e 4.7.1.2.f 4.7.3.1.b 4.7.4.1.b 4.7.5.l.e.2 4.7.6.1.d.3 Delay testing for equipment response to ESF signals 98052i0379 93i222 PDR ADQCK 050003i6 P

PDR

(6)

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ec Table 4.3-1 Items 7,9,10 8 ll Table 4.3-2, Item I.d 4.3.2.1.2 (P-11) 4.4.11.1.b Table 4.3-), Item 5 4.3.1.1.2 (P-6) esc t

f I

Delay pressurizer pressure 8 level calibrations, interlock function

testing, and PORV 'calibrations Delay intermediate range calibration and interlock functional testing The due dates specified in the licensee's submittal for each TS affected are the most limiting due dates, in that for multiple TSs the data yhen the first surveillance is due is listed.

Also, the due dates given in the submittal include the 25X maximum allowable extension beyond the surveillance interval allowed by TS 4.0.2.

This amendment addresses only the above four groups of TS surveillances because their limiting due dates expire in early to mid-January 1994.

Group 2

has a limiting due date of April 15, 1994, but was also evaluated in this amendment because it is closely related to Group I surveillances.

The remaining 12 extension requests will be evaluated by the staff at a later date under a separate cover.

2.6 KW4UAT ON Generic Letter (GL) 91-04, "Changes, in Technical Specifications Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," was published April 2, 1991.

The purpose of the GL was to provide guidance to licensees wishing to take advantage of improvements in reactor fuels to increase the duration of the fuel cycle for their facilities.

Although the licensee is not requesting a

permanent change to a 24-month fuel cycle, it is requesting a one-time surveillance extension, in which some of the guidance of GL 91-04 will apply.

The staff included in its guidance in GL 91-04 the following statement:

The NRC staff has reviewed a number of requests to extend 18-month surveillances to the end of a fuel cycle and a few requests for changes in surveillance intervals to accommodate a 24-month fuel cycle.

The staff has found that the effect on safety is small because safety systems use redundant electrical and mechanical components and because licensees perform other surveillances during plant operation that confirm that these systems and'components can perform their safety functions.

Nevertheless, licensees should evaluate the effect on safety of an increase in 18-month surveillance intervals to accommodate a 24-month fuel cycle.

This evaluation should support a conclusion that the effect on safety is small.

Licensees should confirm that historical plant maintenance and surveillance data support this conclusion.'he licensee's request for surveillance extension is very similar to extensions granted previously, one for Unit I approved by the NRC on April 17,

1987, and two for Unit 2 approved by the NRC on December 28,= 1987, and February 29, 1988.

The reasons for the eytension and the equipment included

,in this request are similar.. The specific TS changes are addressed below.

Groups (1) and (2) e n

e Sa Iexiina The proposed amendment requests a 5-month (most limiting due date) extension for the time-response testing required by TSs 4.3.1.1.3 for the reactor trip and ESF instrumentation in TS Tables 3.3-1 and 3.3-3.

The amendment also requests an extension of surveillances for equipment. that actuates on an ESF signal covered by TSs 4.5.1.d. 4.5.2.e, 4.6.2.l.c, 4.6.2;2.c, 4.6.3.1.2, 4.7.1.2.e.

and f, 4.7.3.1.b, 4.7.4.1.b, 4.7.5.1.e.2 and 4.7.6.1.4.3.

.The TSs include the automatic initiation of valves,

pumps, and ventilation as detailed in the licensee's submittal.

The equipment is actuated by ESF signals:

-safety injection (SI), phase isolation, containment purge, exhaust isolation, and containment pressure high-high.

Testing of these instrument loops either requires plant shutdown or removal of an entire train of safety equipment from operation.

The licensee does not consider it prudent to perform this testing at power.

All required channel checks,and functional checks of the ESF and reactor protection system will..continue as scheduled.

The licensee has reviewed the surveillance history of these ESF systems and has determined that the equipment should be able to meet the TS requirements during the extension period.

The licensee received a similar extension for.

these components in 1987 and performed a review of all the as-found data from the extended surveillance period; No degradation was noted; all of the as-found responses were within the acceptance criteria.

Therefore, the staff finds the licensee's request for one-time surveillance extension for Groups (1) and (2) acceptable.

Group (6) ressurizer P es ure 5 evel glib ations and R

a at s

The proposed amendment requests a 6g month extension (most limiting date) for some of the pressurizer channel calibrations, interlock testing involving pressurizer pressure instrumentation, and PORV calibrations required by TS 4.3.1.1.1 Table 4.3-1 Items 7,9,10 and ll, TS 4.3.2.1.1 Table 4.3-2, Item 1.d, TS 4.3.2.1.2 (P-11) and TS 4.4.1).l.b.

Calibration of the PORVs at power is not permitted by TSs because the calibration renders all three PORVs inoperable at the same time.

Calibration of certain pressurizer level and pressure instruments at power is not considered prudent because the configuration of the instrumentation calibration could result in a reactor trip.

Two of the pressurizer pressure instruments share a common sensing line with one of the pressurizer level instruments.

Calibrations can and will be performed on two of the three pressurizer

'level channels-.and on two of the four pressurizer pressure channels per TSs.

.Also, the instrument channels on which the licensee. is requesting surveillance extensions on will be subject to channel functional testing and/or channel checks.

The testing that will be performed would be expected to provide indication of the operability of the systems.

The licensee performed a drift analysis using as-found instrument errors from previous instrument calibrations to project the amount of drift the instruments will have during the extension period.

Details of the licensee's analysis were submitted in a letter dated Decembei 3, l993.

In its submittal the licensee provided the results of the analysis and concluded that, based on these results, the drift data clearly indicated that instrument drift will be within acceptable limits while operating in the requested surveillance extension period.

ThereFore, the staff finds the licensee's request for one-time surveillance extension for Group (6) acceptable.

Group (1I) t ed a e Ran e

a nd te u

In a letter dated December 3, 1993, the licensee withdrew its request for extensions of surveillances pertaining to intermediate range ca1ibration and interlock functional testing because these surveillances were performed during a forced outage on August 10, 1993.

These extensions are no longer needed.

3.0 STAT C

N U

In accordance with the Commission's regulations, the Michigan State ofFicial'as notified of the proposed issuance of the amendments.

The State official had no comments.

4.0 NV RONHENTAL CONSID RA 0

The amendment changes surveillance requirements.

The 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 (58 FR 41505).

Accordingly, the amendment meets the eligibilitycriteria 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 connection with the issuance of the amendment.

B.B

~COIIC II The staff has concluded, based on the considerations discussed above, that:

(I) 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 Contributor:

Beth A. pretzel Date:

Decker 22, 1993

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