AEP-NRC-2019-01, Application to Revise Technical Specifications to Adopt TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program
| ML19063A498 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/26/2019 |
| From: | Lies Q American Electric Power, Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2019-01 | |
| Download: ML19063A498 (15) | |
Text
m INDIANA MICHIGAN POWER A unit of American Electric Power February 26, 2019 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 lndianaMichiganPower.com AEP-NRC-2019-01 10 CFR 50.90 Donald C. Cook Nuclear Plant, Units 1 and 2 APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-563, REVISION 0, "REVISE INSTRUMENT TESTING DEFINITIONS TO INCORPORATE THE SURVEILLANCE FREQUENCY CONTROL PROGRAM" Pursuant to 1 O CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook.
Nuclear Plant (CNP), is submitting a request for an amendment to the Technical Specifications (TS) for CNP Units 1 and 2.
l&M requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program."
TSTF-063 revises the TS definitions *of Channel Calibration, Channel Operational Test, and Trip Actuating Device Operational Test, which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. provides an affirmation statement pertaining to the information contained herein. provides a description and assessment of the proposed changes. Enclosures 3,and 4 provide Unit 1 and Unit 2 TS pages, respectively, marked to show the proposed changes. New clean Unit 1 and Unit 2 TS pages with proposed changes incorporated will be provided to the Nuclear Regulatory Commission (NRC) Licensing Project Manager when requested.
l&M would like to request NRC review and approval of the proposed changes commensurate with the NRC's normal review schedule. Once approved, the amendment shall be implemented within 60 days.
In accordance with 1 O CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan state officials.
U.S. Nuclear Regulatory Commission Page2 AEP-NRC-2019-01 There are no new regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.
Sincerely,
]~JJ.Ll 6anelies Site Vice President Indiana Michigan Power Company BMC/mil
Enclosures:
- 1.
Affirmation
- 2.
Description and Assessment of the Technical Specification Changes
- 3.
Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes
- 4.
Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Proposed Changes c:
R. J. Ancona - MPSC R. F. Kuntz-NRC, Washington, D.C.
MDEQ - RMD/RPS NRC Resident Inspector D. J. Roberts - NRC Region Ill A. J. Williamson...;. AEP Ft. Wayne, w/o enclosures to AEP-NRC-2019-01 AFFIRMATION I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U. S. Nuclear Regulatory Commission on behalf of l&M, and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company 2:::::A~
Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS &to. DAY OF rebrua.<'\\{
2019
~~~~
My Commission Expires 0\\ ]'1\\\\1D25 to AEP-NRC-2019-01 Description and Assessment of Technical Specification Changes
1.0 DESCRIPTION
Indiana Michigan Power Company (l&M}, the licensee for Donald C. Cook Nuclear Plant (CNP},
requests adoption of TSTF-563, "Revise Instrument Testing Definitions to* Incorporate the Surveillance Frequency Control Program," into the Technical Specifications (TS) for CNP Units 1 and 2. TSTF-563 revises the TS definitions of Channel Calibration, Channel Operational Test, and Trip Actuating Device Operational Test, which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or.devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.
2.0
2.1 ASSESSMENT
Applicability of Safety Evaluation l&M has reviewed the safety_ evaluation for TSTF-563 provided to the Technical Specifications Task Force in a letter dated December 4, 2018. This review included a review of the Nuclear Regulatory Commission (NRC) staffs evaluation, as well as the information provided in TSTF-563. As described herein, l&M has concluded that the justifications presented in TSTF-563 and the safety evaluation prepared by the NRC staff are applicable to CNP Units 1 and 2,. and justify this amendment for the incorporation of the changes to the CNP Units 1 and 2 TS.
A Surveillance Frequency Control Program was incorporated into the CNP Units 1 and 2 TS in a license amendment dated March 31, 2017, (NRC Agency Documents Access and Management System Accession No. ML17045A150).
2.2 Optional Changes and Variations l&M is not proposing any variations from the TS changes described in the TSTF-563 or the applicable parts of the NRC staffs safety evaluation dated December 4, 2018.
The traveler discusses the applicable regulatory requirements and guidance, including the 10 CFR 50, Appendix A, General Design Criteria (GDC). CNP Units 1 and 2 were not licensed to the 1 O CFR 50, Appendix A, GDC. The CNP equivalents of the referenced GDC are the Plant-Specific Design Criteria (PSDC}, discussed in Section 1.4 of the CNP Updated Final Safety Analysis Report. These criteria are based on the Atomic Energy Commission proposed GDC published in the Federal Register on July 11, 1967.
TSTF-563 references 1 O CFR-50, Appendix A, GDC 13, "Instrumentation and Control." GDC 13 is similar to PSDC 12, "Instrumentation and Control Systems."
to AEP-NRC-2019-01 Page 2 TSTF-563 references 1 O CFR-50, Appendix A, GDC 21, "Protection System Reliability and Testability."
GDC 21 is similar to PSDC 19, "Protection Systems Reliability," Criterion 20, "Protection Systems Redundancy and Independence," and Criterion 25, "Demonstration of Functional Operability of Protection Systems."
Following implementation of the proposed change, CNP Units 1 and 2 will remain in compliance with PSDC 12, 19, 20, and 25. Therefore, this difference does not alter the conclusion that the proposed change is applicable to CNP.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Analysis Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP),
requests adoption of TSTF-563, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," into the Technical Specifications (TS) for CNP Units 1 and 2. TSTF-563 revises the TS definitions of Channel Calibration, Channel Operational Test (COT), and Trip Actuating Device Operational Test (TADOT), which currently permit performance by means of any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.
l&M has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response:No The proposed change revises the TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. All components in the channel continue to be tested. The frequency at which a channel test is performed is not an initiator of any accident previously evaluated, so the probability of an accident is not affected by the proposed change. The channels surveilled in accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
to AEP-NRC-2019-01 Page3
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response:No The proposed change revises the TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i.e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the TS definitions of Channel Calibration, COT, and TADOT to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program. The Surveillance Frequency Control Program assures sufficient safety margins are maintained, and that design, operation, surveillance methods, and acceptance criteria specified *in applicable codes and standards ( or alternatives approved for use by the NRC) will continue to be met as described in the plants' licensing basis. The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety ~nalysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by the method of determining surveillance test intervals under an NRG-approved licensee-controlled program.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, l&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and; accordingly, a finding of "no significant hazards consideration" is justified.
3.2 Conclusion In conclusion, based on the considerations discussed above, (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, to AEP-NRC-2019-01 Page4 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.
4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22{c)(9). Therefore, pursuant to 10 CFR 51.22(b}, no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
to AEP-NRC-2019-01 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked to Show Proposed Cha".lges
1.0 USE AND APPLICATION 1.1 Definitions Definitions
- 1.1
* --- *----------------------------------------------* NOTE-----------------------------------------------------*---* -
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
ACTIONS ACTUATION LOGIC TEST.
AXIAL FLUX DIFFERENCE (AFD)
CHANNEL CALIBRATION CHANNEL CHECK Cook Nuclear Plant Unit 1 *. *.
Definition
.*. ACTIONS shall be that part of a Specification that prescribes
- Required Actions to be taken under designated Conditions within specified Compietion Times.
- An ACTUATION LOGIC TESTshall be the application of*
various simulated or actual i_nput combin_ations in conjunction with. each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic_ output.* The ACTUATION LOGIC TEST, as a minimum, shall include a GOntinuity check of output devices.
- AFD shall be the difference in normalized flux signals
- between the*top and bottom halves of a two section excore neutron detector.
A CHANNEL CALIBRATION shall be the ~djustnient, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel*OPERABILITY. Calibration of.
. instrument channels with resistance temperature detector
{RTD) or thermocouple sensors may consist of an inplace *
. qualitative assessment of sensor behavior and normal
. calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of ail series of se ueritial, overla in, or total channel steps, and each ste must be erformed within the Fre uenc in the Surveillance Fre uenc Control Pro ram or the devices included in the ste.
A CHANNEL CHECK shall 'be the qualitative assessment, by observation, of channel behavior during operation.- This determination shall inclutje, where possible, comparison of.
the channel indication and status to other indications or status derived from independent instrument channels
- measuring the same parameter.
. ~,
. ~.
- /
1.1-1 Amendment No. 287 '.
- 1.1 Definitions CHANNEL OPERATIONAL TEST (COT)
CORE ALTERATION CORE OPERATING LIMITS REPORT (COLR)
DOSE EQUIVALENT 1-131
- DOSE EQUIVALENT XE-133
- -. Cook Nuclear Plant Unit.1 Definitions.
1.1
- A COT shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to
- verify OPERABILITY of all devices in the channel required for channel.OPERABILITY. *The COT shall include adjustments,.
as necessary, of the required alarm, interlock, and trip setpoints required for channel OPERABILITY such that t_he setpoints are within the necessary range and accuracy. The COT may be performed by means of any serie~s_o_f _______
.sequential, overlapping,.or total channel steps, and each te must be erformed within the Fre uenc in the Control Pro CORE ALTERATION shall be_.the movement of any fuel, -
sources, or reactivity control components, within the reactor vessel with the vessel head removed and fuel *in the vessel..
Suspension of CORE ALTERATIONS shall not preclude. _
completion of movement of a component to a safe position.
. The COLR is the unit specific docum~nt that provides cycle specific parameter limits for the current reload cycle.
These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5.
Unit operation within these limits is addressed in individual Specifications.
DOSE EQUIVALENT 1-131 shall be that con-centration of 1-131 (microcuries per gram) that alone would produce the.
same dose when inhaled as the combined activities of iodine isotopes 1-131, 1-132, 1-133, 1-134; and 1-135 actually present The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors from Committed Dose Equivalent (COE) or Committed Effective Dose Equivalerit *(CED!=) d9se conversion factors from Table
. 2.1 of EPA Federal Guidance Report No: 1 f, "Limiting Values.
of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion."
DOSE EQUIVALENT XE-133 shall be that concentration of
- Xe-133 (microcuries per gram) that alone would produce the.
- same acute dose to the whole body as the combined
. activities.of noble gas.nuclides Kr-85m, Kr-85, Kr-87, Kr-88,.
Xe-131m, Xe-133m, Xe-133, Xe-135ni, Xe-135, and Xe:138
. actually present. If a specific noble gas nuclide is not detected, it should be. assumed to be present at the *minimum.
- detectable activity.: The determination of DOSE EQUIVALENT XE-133 shall be performed using effective
- *.:1.1-2 :
Amendment No. 287, ~
1 **
J
- ~
1.1 Definitions THERMAL POWER
. TRIP ACTUATING DEVICE
. OPERATIONAL TEST (TADOT).
Cook Nuciear Plant J.Jnit 1 Definitions
- 1.1 THERMAL POWE;R shall be the total reactor core heat transfer rate to the reactor coolant.
- ATADOT shall consist of operating the trip actuating device and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. The TADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint *
- within the necessary accuracy. The TADOT may be performed by means of an series of se uentiaf, overla
- ing, or total channel steps, and each ste must.be erforme ithin the Fre uenc in the Surveillance Fre uenc Control ra*m for the devices included in the ste
- 1.1-7 Amendment N6. 28-7 *
- Enclosure 4 to AEP-NRC-2019-01 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked to Show Proposed Changes
1.0 USE AND APPLICATION 1.1 Definitions*
Definitions 1.1
.---------------NOTE- -----------. --------. --------------------------. ----------
The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.
ACTIONS ACTUATION LOGIC Tl=ST AXIAL FLUX DIFFERENCE (AFD)
CHANNEL CALIBRATION CHANNEL CHECK Cook Nuclear Plant Unit 2.
Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions
- within specified Completion Times.
An ACTUATION LOGIC TEST shall be the application of
. various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.
AFD shall be the difference in normalized flux signals between the top and bottom halves of a two section excore neutron detector.
A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel
- required for channel OPERABILITY'. Calibration of instrument channels with resistance temperature detector _
{RTD) or thermocouple sensors may consist of an inplace
- qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of an series of se uential, overla in, or total
-channel steps, and each ste must be erformed within the Fre uenc in the Surveillance Fre uenc Control Pro ram or the devices included in the ste.
A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior*during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the sarrie parameter. -
.1.1-1
_ Amendment No. 2e9
. ~ *...
. ~. ---
1.1 Definitions CHANNEL OPERATIONAL TEST{COT)
CORE ALTERATION CORE OPERATING LIMITS REPORT (COLR)
DOSE EQUIVALENT 1.:131 DOSE EQUIVALENT XE-133.
-Cook Nuclear Plant Unit 2 -
~* ~- ' -:*
- ._.. * ~..
~ :. ;. '
,-.- -Definitions -
-:. -i- -
1.1_ -
A COT shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all devices in the channel required for -
channel OPERABILITY. The COT shall include adjustments, -
as necessary, of the required alarm, interlock, arid trip setpoints required for channel OPERABILITY such that the -
setpoints are within. the necessary range and accuracy. The-COT may be performed by means of any series of sequential, overlapping, or total channel steps, and each te must be erformed within the Fre uent in the * * -
urveillarice Fre uenc included in the ste.
-CORE: AL TERATIQN shall be the-movement of any fuel, ;- -'.
source$, or reactivity control components, within the _reactor vessel with the vessel head removed and fuel in_ the vessel.
Suspension of CORE ALTERATIONS shall not preclude '
completion of movement of 'a component to a safe position.
The COLR is the unit specific document that provides cycle specific parameter limits for the current reload cycle:
These cycle specific parameter limits shall be determined for -
each reload cycle in accordance with Specification 5.6.5..
Unit operation within these limits is adpressed in individual Specifications.
DOSE EQUIVALENT 1-131 s~all be.that concentration of --
1-131 (microcuriesper gram) that alone would produce the same dose when inhaled_as the combined activities of iodine isotopes 1-131, I~ 132, 1-133, 1-134; and 1-135 actually present.
- The determination of DOSE EQUIVALENT 1-131 shall be performed using thyroid dose conversion factors-from Committed Dose Equivalent (COE) or Committed Effective Dose Equivalent (CEDE) dose conversion factors from Table 2.1 of EPA Federal. Guidance Report No. 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose*
Conversion Factors for Inhalation, Submersion, and Ingestion._"
DOSE EQUIVALENT XE~ 133 shall be that co~ceritration of -
Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-8_7, Kr,,88, __
Xe-131m; Xe-133m, Xe-133; Xe-135m; Xe~135, and Xe-138 actually present. - If a specific noble gas nuclide is not * : --
. detected, it should be assumed to be present at the minimum detectable activity. -The* determination of DOSE - -
EQUIVALENT XE::133 shall be performed using effective * - :--
- -*;:i*-;.:;,1:1-2 /:
__,,. _ * * -*.Ar'neridme~t No,~? a+4_ :_.
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1.1 Definitions THERMAL POWER TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT)
Cook Nuclear Plant Unit 2 Definitions 1.1 THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.
A TADOT shall consist of operating -the trip actuating device.
and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. The T ADOT shall include adjustment, as necessary, of the trip actuating device so that it actuates at the required setpoint within the necessary accuracy. The TADOT may be performed by means of an series of se uential, overla
- ing, or total channel steps, and each ste must be erforme ithin the Fre uenc in the Surveillance Fre uenc Control 1.1-7 Amendment No. 269