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| | issue date = 09/22/1989 | | | issue date = 09/22/1989 |
| | title = Application for Amends to Licenses DPR-58 & DPR-74,adding Tech Spec 4.0.4 Exemptions to 18-month Measurement of Hot Leg/Cold Leg Delta T | | | title = Application for Amends to Licenses DPR-58 & DPR-74,adding Tech Spec 4.0.4 Exemptions to 18-month Measurement of Hot Leg/Cold Leg Delta T |
| | author name = ALEXICH M P | | | author name = Alexich M |
| | author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG | | | author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| | addressee name = MURLEY T E | | | addressee name = Murley T |
| | addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) | | | addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| | docket = 05000315, 05000316 | | | docket = 05000315, 05000316 |
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| | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS | | | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS |
| | page count = 9 | | | page count = 9 |
| | | project = |
| | | stage = Request |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:AC CEM RATED D1~i~BUTI ON DE M ON STRA.TION SYSTEM REGULATOAOZNFORMATZON DISTRIBUTION STEM (RIDE)ACCESSION NBR:8910040208 DOC.DATE: 89/09/22 NOTARIZED: | | {{#Wiki_filter:AC CEM RATED D1~i~BUTION DE M ON STRA. TION SYSTEM REGULATOAOZNFORMATZON DISTRIBUTION STEM (RIDE) |
| NO DOCKET FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana 6 05000316 AUTH.NAME AUTHOR AFFILIATION | | ACCESSION NBR:8910040208 DOC.DATE: 89/09/22 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana 6 05000316 AUTH. NAME AUTHOR AFFILIATION |
| .ALEXICH,M.P. | | . ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. Document Control Branch (Document Control Desk) |
| Indiana Michigan Power Co.(formerly Indiana&Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. | |
| Document Control Branch (Document Control Desk) | |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Application for amends to Licenses DPR-58 6 DPR-74,adding Tech Spec 4.0.4 exemptions to 18-month measurements. | | Application for amends to Licenses DPR-58 6 DPR-74,adding Tech Spec 4.0.4 exemptions to 18-month measurements. |
| DISTRIBUTION CODE: AOOZD COPIES RECEIVED:LTR 4 ENCL 3 SIZE: TITLE: OR Submittal: | | DISTRIBUTION CODE: AOOZD TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution 4 ENCL 3 SIZE: |
| General Distribution NOTES: INTERNAL: EXTERNAL: RECIPIENT ID CODE/NAME PD3-1 LA GIITTERFJ.
| | NOTES: |
| NRR/DEST/ADS 7E NRR/DEST/ICSB NRR/DEST/RSB 8E NUDOCS-ABSTRACT OGC/HDS1.RES/DSIR/EIB LPDR NSIC COPIES LTTR ENCL 1, 1 5 5 1 1 1 1 1 1 1 1 1 0 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DEST/ESB 8D NRR/DEST/MTB 9H NRR/DOEA/TSB 11 OC L G FILE NRC PDR COPIES LTTR ENCL~1 1 1 1 1, 1 1 1 1 0 1 1 1 1 NOZE'I0 ALL'KIDS" RECIPIEÃIS: | | RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1, 1 PD3-1 PD ~ |
| PLEASE HELP US TO REDUCE, HASTE j CXÃIACT'THE DOQ3MENI CGNZROL DESKS KXM P1-37 (EXT.20079)KO EZZK2KEE KN3R MME HKH DISTRIBUTION LISTS FOR DOC(2KNIS YOU DOHFT NEED)TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19 | | 1 1 GIITTERFJ. 5 5 INTERNAL: NRR/DEST/ADS 7E 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB NRR/DEST/RSB 8E 1 |
| | 1 1 |
| | 1 NRR/DEST/MTB 9H NRR/DOEA/TSB 11 1, |
| | 1 1 |
| | 1 NUDOCS-ABSTRACT 1 1 OC L 1 0 OGC/HDS1 1 0 G FILE 1 1 |
| | .RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOZE 'I0 ALL 'KIDS" RECIPIEÃIS: |
| | PLEASE HELP US TO REDUCE, HASTE j CXÃIACT 'THE DOQ3MENI CGNZROL DESKS KXM P1-37 (EXT. 20079) KO EZZK2KEE KN3R MME HKH DISTRIBUTION LISTS FOR DOC(2KNIS YOU DOHFT NEED) |
| | TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19 |
|
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| t~~II~]indiana Michigan Power Company P.O.Box 16631 Columbus, OH 43216 AEP: NRC: 1102 Donald C.Cook Nuclear Plant Units 1 and 2 License Nos.DPR-58 and DPR-74 Docket Nos.50-135 and 50-316 DELTA T REACTOR TRIPS TECHNICAL SPECIFICATION | | indiana Michigan t~ ~ II Power Company |
| | ~ ] |
| | P.O. Box 16631 Columbus, OH 43216 AEP: NRC: 1102 Donald C. Cook Nuclear Plant Units 1 and 2 License Nos. DPR-58 and DPR-74 Docket Nos. 50-135 and 50-316 DELTA T REACTOR TRIPS TECHNICAL SPECIFICATION 4.0.4 CHANGE U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: T. E. Murley September 22, 1989 |
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| ====4.0.4 CHANGE==== | | ==Dear Dr,== |
| U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Attn: T.E.Murley September 22, 1989
| | 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 propose to add T/S 4.0.4 exemptions to the 18-month measurement of hot leg-cold leg delta T. We intend to perform the measurement as part of the calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1 (Reactor Trip System Instrumentation Surveillance Requirements). The reasons for the proposed changes and our analyses concerning significant hazards considerations are contained in Attachment 1 to this letter. The proposed revised T/S pages are contained in Attachment 2. |
| | We believe that the proposed changes will not result in (1) a significant change in the types of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure. |
| | These changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee at their next regularly scheduled meeting. |
| | In compliance with the requirements of 10 CFR 50.92 (b)(1), copies of this letter and its attachments have been transmitted to Mr. R. C. Callen of the Michigan Public Service Commission and the Michigan Department of Public Health. |
| | 89'10040208 89'0922 PDR ADOCK 05000315 P PNU |
| | |
| | Dr. T. E. Murley AEP:NRC:1102 This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned. |
| | Sincerely, M. P. Ale ich Vice President ldp Attachments cc: D. H. Williams, Jr. |
| | W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff A. B. Davis NRC Resident Inspector - Bridgman NFEM Section Chief |
| | |
| | ~ ~ |
| | ATTACHMENT 1 TO AEP:NRC:1102 REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS to AEP:NRC:1102 Page 1 In this letter, we are proposing to modify the T/S 4.0.4 exemptions for the 18-month calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1, Functional Units 7 and 8. These functional units currently have T/S 4.0.4 exemptions for the F delta I penalties associated with the overtemperature and overpower reactor trips via Note 9 to Table 4.3-1. We are proposing to add a T/S 4.0.4 exemption for the measurement of delta T to Note 9. |
| | Submittal of this proposed T/S change fulfills a commitment made in Unit 2 licensee event report (LER) 89-10 (Attachment 3). During the last Unit 2 refueling outage, all four steam generators were replaced. Delta T measurements were taken during unit startup and eventually were incorporated into the overtemperature and overpower delta T channel calibrations. Previously, the full power delta T value had been assumed to be a fixed nominal value. The new steam generators, however, resulted in enough of a change in the delta T to place the overtemperature and overpower delta T channel calibrations, which had been performed as required prior to entry into Mode 2, outside the allowable range of T/S Table 2.2-1. |
| | Because the delta T value could change over time due, for example, to steam generator tube plugging or reactor coolant pump flow changes, we committed to measuring delta T values at the beginning of each cycle and adjusting the overtemperature and overpower delta T reactor trip calibrations as necessary. However, our T/Ss presently require the trips to be operable in Modes 1 and 2. T/S 4.0.4 prohibits entry into an operational mode or other specified applicabi11ty condition unless the surveillance requirements associated with the limiting condition for operation have been performed. The delta T measurements must be performed at full power since the overtemperature and overpower delta T functions are defined (in Table 2.2-1) as a function of the delta T at rated. |
| | thermal power. Without an exemption to the requirements of T/S 4.0.4, the plant may be in literal noncompliance with the T/Ss between the time the initial calibration is performed (prior to entry into Mode 2) and the time the delta T measurements are taken and the initial calibration revised, as necessary. |
| | Per 10 CFR 50.92, a proposed amendment will not involve a significant not: |
| | hazards consideration if the proposed amendment does (1) 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 analyzed or evaluated, or, (3) involve a significant reduction in a margin of safety. |
| | to AEP:NRC:1102 Page 2 Criterion 1 The change is necessary to allow for proper calibration of the overtemperature and overpower delta T functions without violation of T/S requirements. The change therefore corrects an inconsistency in our present T/S, and makes the T/S more accurately reflect, the system design. Since the change will allow us to measure delta T each cycle, rather than assuming a nominal value, the change should provide an enhancement to our calibration procedure. We therefore do not expect the change to involve a significant increase in the probability or consequences of a previously evaluated accident or significantly reduce the margin of safety. |
| | Criterion 2 The change involves no physical modifications to the plant nor any significant changes in plant operations. Therefore, the change should not create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated. |
| | Criterion 3 See Criterion 1 above. |
| | We note that the Commission has provided guidance concerning the determination of significant hazards by providing examples (48 FR 14870) of amendments considered not likely to involve significant hazards considerations. The first example refers to changes that are administrative in nature: for example, correction of errors. |
| | The change is similar to this example in that the present T/S does not reflect the fact that delta T measurements must be taken at full power. The sixth example refers to changes which may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are within acceptable limits. Technically, the change provides relief from current T/S requirements regarding operability of the overtemperature and overpower delta T reactor trips. However, the change will allow measurement of the delta T value each cycle, rather than assuming a nominal value for delta T. |
| | This provides an enhancement to the calibration procedure, and therefore should increase rather than decrease safety. Based on the above discussion, we believe the examples cited are relevant and that the change should not involve significant hazards considerations. |
| | We are also proposing a minor editorial change to Note 9 of T/S Table 4.3-1. The present Note 9 includes a reference to Note 1 of Table 2.2-1. This refers to the f delta I penalty of the overtemperature delta T. The inclusion of the delta T in the T/S 4.0.4 exemption provided by Note 9 would require expansion'of the to AEP:NRC:1102 - Page 3 reference to Notes 3 and 4 of Table 4.3-1, also. Rather than add the additional note numbers, we are proposing to modify the reference so that it refers generally to Table 2.2-1, rather than to the specific notes of Table 2,2-1. This will avoid cluttering Note 9 with the additional references. The change is purely administrative in nature, and therefore will not involve a significant increase in the probability or consequences of an accident previously evaluated, will not create the possibility of a new or different kind of accident from any previously analyzed or evaluated, and will not involve a significant reduction in a margin of safety. |
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| ==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 propose to add T/S 4.0.4 exemptions to the 18-month measurement of hot leg-cold leg delta T.We intend to perform the measurement as part of the calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1 (Reactor Trip System Instrumentation Surveillance Requirements).
| |
| The reasons for the proposed changes and our analyses concerning significant hazards considerations are contained in Attachment 1 to this letter.The proposed revised T/S pages are contained in Attachment 2.We believe that the proposed changes will not result in (1)a significant change in the types of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2)a significant increase in individual or cumulative occupational radiation exposure.These changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee at their next regularly scheduled meeting.In compliance with the requirements of 10 CFR 50.92 (b)(1), copies of this letter and its attachments have been transmitted to Mr.R.C.Callen of the Michigan Public Service Commission and the Michigan Department of Public Health.89'10040208 89'0922 PDR ADOCK 05000315 P PNU Dr.T.E.Murley-2-AEP:NRC:1102 This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
| |
| Sincerely, M.P.Ale ich Vice President ldp Attachments cc: D.H.Williams, Jr.W.G.Smith, Jr.-Bridgman R.C.Callen G.Charnoff A.B.Davis NRC Resident Inspector-Bridgman NFEM Section Chief
| |
| ~~ATTACHMENT 1 TO AEP:NRC:1102 REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS Attachment 1 to AEP:NRC:1102 Page 1 In this letter, we are proposing to modify the T/S 4.0.4 exemptions for the 18-month calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1, Functional Units 7 and 8.These functional units currently have T/S 4.0.4 exemptions for the F delta I penalties associated with the overtemperature and overpower reactor trips via Note 9 to Table 4.3-1.We are proposing to add a T/S 4.0.4 exemption for the measurement of delta T to Note 9.Submittal of this proposed T/S change fulfills a commitment made in Unit 2 licensee event report (LER)89-10 (Attachment 3).During the last Unit 2 refueling outage, all four steam generators were replaced.Delta T measurements were taken during unit startup and eventually were incorporated into the overtemperature and overpower delta T channel calibrations.
| |
| Previously, the full power delta T value had been assumed to be a fixed nominal value.The new steam generators, however, resulted in enough of a change in the delta T to place the overtemperature and overpower delta T channel calibrations, which had been performed as required prior to entry into Mode 2, outside the allowable range of T/S Table 2.2-1.Because the delta T value could change over time due, for example, to steam generator tube plugging or reactor coolant pump flow changes, we committed to measuring delta T values at the beginning of each cycle and adjusting the overtemperature and overpower delta T reactor trip calibrations as necessary.
| |
| However, our T/Ss presently require the trips to be operable in Modes 1 and 2.T/S 4.0.4 prohibits entry into an operational mode or other specified applicabi11ty condition unless the surveillance requirements associated with the limiting condition for operation have been performed.
| |
| The delta T measurements must be performed at full power since the overtemperature and overpower delta T functions are defined (in Table 2.2-1)as a function of the delta T at rated.thermal power.Without an exemption to the requirements of T/S 4.0.4, the plant may be in literal noncompliance with the T/Ss between the time the initial calibration is performed (prior to entry into Mode 2)and the time the delta T measurements are taken and the initial calibration revised, as necessary.
| |
| Per 10 CFR 50.92, a proposed amendment will not involve a significant hazards consideration if the proposed amendment does not: (1)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 analyzed or evaluated, or, (3)involve a significant reduction in a margin of safety.
| |
| Attachment 1 to AEP:NRC:1102 Page 2 Criterion 1 The change is necessary to allow for proper calibration of the overtemperature and overpower delta T functions without violation of T/S requirements.
| |
| The change therefore corrects an inconsistency in our present T/S, and makes the T/S more accurately reflect, the system design.Since the change will allow us to measure delta T each cycle, rather than assuming a nominal value, the change should provide an enhancement to our calibration procedure.
| |
| We therefore do not expect the change to involve a significant increase in the probability or consequences of a previously evaluated accident or significantly reduce the margin of safety.Criterion 2 The change involves no physical modifications to the plant nor any significant changes in plant operations.
| |
| Therefore, the change should not create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated.
| |
| Criterion 3 See Criterion 1 above.We note that the Commission has provided guidance concerning the determination of significant hazards by providing examples (48 FR 14870)of amendments considered not likely to involve significant hazards considerations.
| |
| The first example refers to changes that are administrative in nature: for example, correction of errors.The change is similar to this example in that the present T/S does not reflect the fact that delta T measurements must be taken at full power.The sixth example refers to changes which may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are within acceptable limits.Technically, the change provides relief from current T/S requirements regarding operability of the overtemperature and overpower delta T reactor trips.However, the change will allow measurement of the delta T value each cycle, rather than assuming a nominal value for delta T.This provides an enhancement to the calibration procedure, and therefore should increase rather than decrease safety.Based on the above discussion, we believe the examples cited are relevant and that the change should not involve significant hazards considerations.
| |
| We are also proposing a minor editorial change to Note 9 of T/S Table 4.3-1.The present Note 9 includes a reference to Note 1 of Table 2.2-1.This refers to the f delta I penalty of the overtemperature delta T.The inclusion of the delta T in the T/S 4.0.4 exemption provided by Note 9 would require expansion'of the Attachment 1 to AEP:NRC:1102
| |
| -Page 3 reference to Notes 3 and 4 of Table 4.3-1, also.Rather than add the additional note numbers, we are proposing to modify the reference so that it refers generally to Table 2.2-1, rather than to the specific notes of Table 2,2-1.This will avoid cluttering Note 9 with the additional references.
| |
| The change is purely administrative in nature, and therefore will not involve a significant increase in the probability or consequences of an accident previously evaluated, will not create the possibility of a new or different kind of accident from any previously analyzed or evaluated, and will not involve a significant reduction in a margin of safety.
| |
| ATTACHMENT 2 TO AEP:NRC:1102 PROPOSED REVISED TECHNICAL SPECIFICATION PAGES}} | | ATTACHMENT 2 TO AEP:NRC:1102 PROPOSED REVISED TECHNICAL SPECIFICATION PAGES}} |
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Proprietary Summary of Sump Inventory Calculations,Encl ML17333B0431997-09-19019 September 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Requirement for Automatic Valve Closure Feature on RHR Sys Suction from RCS ML17333A9831997-08-11011 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,allowing Filling of ECCS Accumulators W/O Declaring ECCS Equipment Inoperable ML17335A2101997-08-0101 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Wording When Secondary Steam Supply Pressure Is Greater than 310 Psig from TS ML17333A8281997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74, Modifying TS 4.7.5.1.e.2 Which Describes Control Room Ventilation Sys Autostart Functions ML17333A8311997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74,changing Grammatical Correction to Wording of Unit 2 TS 3.4.8,Action a for Modes 1,2 & 3 & Returning Frequency Requirement to TS 4.7.1.2.c & 4.7.1.2.d That Was Inadvertently Deleted ML17333A7121996-12-20020 December 1996 Application for Amends to Licenses DPR-58 & DPR-74, Requesting Rev of Reactor Coolant Pump Flywheel Insp Frequency ML17334B5941996-07-11011 July 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Support Operation of Unit 2 at Increased Core Rated Thermal Power of 3,588 Mwt.Rev 1 to WCAP-14489, ...Unit 2 3,600 Mwt Uprating Program Licensing Rept Encl ML17334B5901996-06-19019 June 1996 Application for Amend to License DPR-58,addressing Applicable Requirements of NRC GL 95-05, Voltage-Based Repair Criteria for Repair of Westinghouse SG Tubes Affected by Outside Diameter Stress Corrosion Cracking. ML17334B5891996-06-11011 June 1996 Application for Amends to Licenses DPR-58 & DPR-74,removing TSs Certain Requirements for Administrative Controls,Related to QA Requirements,Per Administrative Ltr 96-05 ML17333A4201996-04-0808 April 1996 Application for Amends to Licenses DPR-58 & DPR-74,moving TS 4.0.4 Exemption Statement for MSSVs Into Section 4.7.1.1 ML17333A3551996-03-12012 March 1996 Application for Amend to License DPR-74,removing TSs Re Shutdown & Control Rod Position Indication While in Modes 3, 4 & 5 ML17334B5751996-02-29029 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Reduce Boric Acid Concentration in Boric Acid Storage Sys from Approx 12 Percent to Approx 4 Percent by Weight. Technical Rept Presenting Justificaion for Changes Encl ML17334B5741996-02-26026 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.6.2 to Increase Current Limit on Nominal Fuel Assembly Enrichment for New,Westinghouse - Fabricated Fuel Stored in New Fuel Storage Racks ML17333A3201996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Remove Requirement That Operations Superintendent Must Hold or Have Held Sol at Plant or Similar Reactor ML17333A3151996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying Table 4.8-1,DG Test Schedule by Ref Rg 1.9,Rev 3 Rather than Rg 1.108,Rev 1 Criteria for Determination of Valid DG Test ML17333A2641996-01-12012 January 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Section 4.4.11 to Eliminate SR Demonstrating Operability of Emergency Power Supply for Pressurizer PORVs & Block Valves ML17333A2391995-12-19019 December 1995 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 ML17332B0111995-11-10010 November 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising Ts,By Modifying Surveillance Testing of EDG During Refueling & Normal Operations ML17332A9971995-10-20020 October 1995 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Add Exemption to TS 4.0.4 in Surveillance Requirements for MSIV ML17332A9111995-08-0606 August 1995 Application for Amends to Licenses DPR-58 & DPR-74,informing That Licensee Has 45 Days from Date of Issuance to Implement Amend Unless Otherwise Specified ML17334B5561995-08-0404 August 1995 Application for Exigent Amend to License DPR-58,modifying TS 4.4.5.4 & 4.4.5.5 for Repair of Hybrid Expansion Joint Sleeved SG Tubes.Proprietary W Rept WCAP-14446, Repair...Of Hybrid Expansion Joint...Tubes Encl.W Rept Withheld ML17332A8271995-06-30030 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,changing TS Section 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02, Suppl 1 ML17334B5501995-06-20020 June 1995 License Amend Request to Licenses DPR-58 & DPR-74,to Remove Requirements for Fire Protection Systems from Licenses & Guidance in GL 86-10,GL 88-12 & GL 93-07 ML17332A7991995-06-15015 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.8.1.1.2.e.7 to Reduce Duration of Surveillance Testing for EDGs During Refueling Operations from 24 H to 8 H ML17334B5481995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Support Operation of Unit 1 at SG Tube Plugging Levels Up to 30%,make One Unit 1 TS More Nearly Like Corresponding Unit 2 TS & Maintain Consistency of Unit 2 Criteria ML17334B5461995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying Tech Specs 3/4.3.1 (Reactor Trip Sys Instrumentation) & 3/4.3.2 (ESFAS Instrumentation) & Bases to Relocate Tables of Response Time Limits to Ufsar,Per GL 93-08 ML17332A7661995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty ML17332A7741995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02,Suppl 1 ML17332A7771995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Table 4.3-2 to Change Main Steam Line Isolation Valve Manual Actuation Sys Surveillance Frequency from Monthly to Quarterly 1999-09-23
[Table view] Category:TEXT-LICENSE APPLICATIONS & PERMITS
MONTHYEARML17335A5551999-10-12012 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.6.2.2.d for Spray Additive Sys to Relocate Details Associated with Acceptance Criteria & Test Parameters to Associated TS Bases ML17335A5591999-10-11011 October 1999 Supplement to Application for Amends to Licenses DPR-58 & DPR-74,replacing Correct TS Pages Inadvertently Included in 990923 Submittal.Attached Pages Also Include Appropriate Administrative Changes ML17335A5411999-10-0101 October 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Containment Recirculation Sump Water Inventory.Calculation & non-proprietary WCAP-15302 Rept Also Encl ML17326A1571999-09-23023 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,involving Movement of Loads in Excess of Design Basis Seismic Capability of Auxiliary Bldg Load Handling Equipment & Structures ML17326A1421999-09-17017 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,to Allow Credit of Rod Cluster Control Assemblies for Cold Leg Large Break LOCA Subcriticality.Ts Pages & non-proprietary Versions of WCAP-15246 Encl.Proprietary Version Withheld ML17326A1161999-09-10010 September 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Surveillance Requirement 4.4.7,TS Tables 4.4-3,3.4-1 & TS Surveillance Requirement 4.11.2.2 Re RCS & Gas Storage Tank Sampling ML17326A0921999-08-17017 August 1999 Application for Amend to License DPR-58,to Change TS 3/4.4.5 & Bases for TS 3/4.4.5,3/4.4.6.2 & 3/4.4.8 to Remove voltage-based Repair Criteria,F* Repair Criteria & Sleeving Methodologies from Unit 1 TS & Clarify Bases Sections ML17325B6041999-05-21021 May 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising Limitations of Positive Reactivity Additions in Several TS Action Statements ML17325B5511999-04-19019 April 1999 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3/4.8.1.2, Electrical Power Systems & Associated Bases to Provide one-time Extension of 18-month Surveillance Interval for Specific SRs ML17335A3661998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,adding TS for Distributed Ignition Sys ML17335A3631998-12-0303 December 1998 Application for Amend to License DPR-58,revising TS 3/4.7.7, Sealed Source Contamination & Associated Bases to Address Testing Requirements for Fission Detectors ML17335A3591998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,making Administrative Changes to Remove Obsolete Info,To Provide Consistency Between Units 1 & 2,to Provide Consistency with Std Tech Specs,To Provide Clarification & to Correct Typos ML17335A3561998-12-0303 December 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.6.5.1, Ice Condenser,Ice Bed & Associated Bases to Reflect Max Ice Condenser Flow Channel Blockage Assumed in Accident Analyses ML17335A2631998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS Containment Sys Bases 3/4.6.1.4 Re Internal Pressure & 3/4.6.1.5 Re Air Temp ML17335A2761998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,placing Tighter Restrictions on Amount of Time RWST Water Level Instrumentation Can Be Out of Svc Before Compensatory Actions Are Required ML17335A2671998-10-0808 October 1998 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 3.4.1.3, RCS - Shutdown & Associated Bases to Provide Separate Requirements for Modes 4 & 5 with Loops Filled & Mode 5 with Loops Not Filled ML17335A2311998-09-14014 September 1998 Application for Amends to Licenses DPR-58 & DPR-74,changing Runout Limits for Safety Injection Pump to 675 Gpm Unless Pump Is Specifically Tested to Higher Flow Rate Not Exceeding 700 Gpm ML17335A1901998-08-28028 August 1998 Application for Amend to License DPR-58,requesting Extension of SG Surveillance,Which TSs Require to Be Performed on or Before 990408,until End of Current Refuel Cycle Currently Scheduled for Mar 2000.W/assessment of SG Degradation & TSs ML17334A7471998-06-10010 June 1998 Application for Amends to Licenses DPR-54 & DPR-78,changing Implementation Date to Reduce Boric Acid Concentration in Boric Acid Storage Sys.Attachment 1 to Ltr Contains Description of Proposed Change & Justification for Change ML17334B7011998-03-0303 March 1998 Application for Amends to TS for Licenses DPR-58 & DPR-74, Removing Word Immediately from Unit 1 Hydrogen Recombiner Surveillance Requirement 4.6.4.2.b.4 & Revising Plants TS 3/4.6.4 Bases ML17334B6561997-10-0808 October 1997 Application for Amends to Licenses DPR-58 & DPR-78,changing TSs 3/4.6.5 & 3/4.5.5 to Increase Both Minimum Required Ice Mass Per Ice Basket & Total Minimum Required Ice Mass. Proprietary Summary of Sump Inventory Calculations,Encl ML17333B0431997-09-19019 September 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Requirement for Automatic Valve Closure Feature on RHR Sys Suction from RCS ML17333A9831997-08-11011 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,allowing Filling of ECCS Accumulators W/O Declaring ECCS Equipment Inoperable ML17335A2101997-08-0101 August 1997 Application for Amends to Licenses DPR-58 & DPR-74,deleting Wording When Secondary Steam Supply Pressure Is Greater than 310 Psig from TS ML17333A8281997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74, Modifying TS 4.7.5.1.e.2 Which Describes Control Room Ventilation Sys Autostart Functions ML17333A8311997-03-26026 March 1997 Application for Amends to Licenses DPR-58 & DPR-74,changing Grammatical Correction to Wording of Unit 2 TS 3.4.8,Action a for Modes 1,2 & 3 & Returning Frequency Requirement to TS 4.7.1.2.c & 4.7.1.2.d That Was Inadvertently Deleted ML17333A7121996-12-20020 December 1996 Application for Amends to Licenses DPR-58 & DPR-74, Requesting Rev of Reactor Coolant Pump Flywheel Insp Frequency ML17334B5941996-07-11011 July 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Support Operation of Unit 2 at Increased Core Rated Thermal Power of 3,588 Mwt.Rev 1 to WCAP-14489, ...Unit 2 3,600 Mwt Uprating Program Licensing Rept Encl ML17334B5901996-06-19019 June 1996 Application for Amend to License DPR-58,addressing Applicable Requirements of NRC GL 95-05, Voltage-Based Repair Criteria for Repair of Westinghouse SG Tubes Affected by Outside Diameter Stress Corrosion Cracking. ML17334B5891996-06-11011 June 1996 Application for Amends to Licenses DPR-58 & DPR-74,removing TSs Certain Requirements for Administrative Controls,Related to QA Requirements,Per Administrative Ltr 96-05 ML17333A4201996-04-0808 April 1996 Application for Amends to Licenses DPR-58 & DPR-74,moving TS 4.0.4 Exemption Statement for MSSVs Into Section 4.7.1.1 ML17333A3551996-03-12012 March 1996 Application for Amend to License DPR-74,removing TSs Re Shutdown & Control Rod Position Indication While in Modes 3, 4 & 5 ML17334B5751996-02-29029 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,revising TS to Reduce Boric Acid Concentration in Boric Acid Storage Sys from Approx 12 Percent to Approx 4 Percent by Weight. Technical Rept Presenting Justificaion for Changes Encl ML17334B5741996-02-26026 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.6.2 to Increase Current Limit on Nominal Fuel Assembly Enrichment for New,Westinghouse - Fabricated Fuel Stored in New Fuel Storage Racks ML17333A3201996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Remove Requirement That Operations Superintendent Must Hold or Have Held Sol at Plant or Similar Reactor ML17333A3151996-02-22022 February 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying Table 4.8-1,DG Test Schedule by Ref Rg 1.9,Rev 3 Rather than Rg 1.108,Rev 1 Criteria for Determination of Valid DG Test ML17333A2641996-01-12012 January 1996 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Section 4.4.11 to Eliminate SR Demonstrating Operability of Emergency Power Supply for Pressurizer PORVs & Block Valves ML17333A2391995-12-19019 December 1995 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 ML17332B0111995-11-10010 November 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising Ts,By Modifying Surveillance Testing of EDG During Refueling & Normal Operations ML17332A9971995-10-20020 October 1995 Application for Amends to Licenses DPR-58 & DPR-74,proposing to Add Exemption to TS 4.0.4 in Surveillance Requirements for MSIV ML17332A9111995-08-0606 August 1995 Application for Amends to Licenses DPR-58 & DPR-74,informing That Licensee Has 45 Days from Date of Issuance to Implement Amend Unless Otherwise Specified ML17334B5561995-08-0404 August 1995 Application for Exigent Amend to License DPR-58,modifying TS 4.4.5.4 & 4.4.5.5 for Repair of Hybrid Expansion Joint Sleeved SG Tubes.Proprietary W Rept WCAP-14446, Repair...Of Hybrid Expansion Joint...Tubes Encl.W Rept Withheld ML17332A8271995-06-30030 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,changing TS Section 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02, Suppl 1 ML17334B5501995-06-20020 June 1995 License Amend Request to Licenses DPR-58 & DPR-74,to Remove Requirements for Fire Protection Systems from Licenses & Guidance in GL 86-10,GL 88-12 & GL 93-07 ML17332A7991995-06-15015 June 1995 Application for Amends to Licenses DPR-58 & DPR-74,revising TS 4.8.1.1.2.e.7 to Reduce Duration of Surveillance Testing for EDGs During Refueling Operations from 24 H to 8 H ML17334B5481995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Support Operation of Unit 1 at SG Tube Plugging Levels Up to 30%,make One Unit 1 TS More Nearly Like Corresponding Unit 2 TS & Maintain Consistency of Unit 2 Criteria ML17334B5461995-05-26026 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying Tech Specs 3/4.3.1 (Reactor Trip Sys Instrumentation) & 3/4.3.2 (ESFAS Instrumentation) & Bases to Relocate Tables of Response Time Limits to Ufsar,Per GL 93-08 ML17332A7661995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty ML17332A7741995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS 5.3.1 to Allow Fuel Reconstitution,Per GL 90-02,Suppl 1 ML17332A7771995-05-25025 May 1995 Application for Amends to Licenses DPR-58 & DPR-74,modifying TS Table 4.3-2 to Change Main Steam Line Isolation Valve Manual Actuation Sys Surveillance Frequency from Monthly to Quarterly 1999-09-23
[Table view] |
Text
AC CEM RATED D1~i~BUTION DE M ON STRA. TION SYSTEM REGULATOAOZNFORMATZON DISTRIBUTION STEM (RIDE)
ACCESSION NBR:8910040208 DOC.DATE: 89/09/22 NOTARIZED: NO DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana 6 05000316 AUTH. NAME AUTHOR AFFILIATION
. ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to Licenses DPR-58 6 DPR-74,adding Tech Spec 4.0.4 exemptions to 18-month measurements.
DISTRIBUTION CODE: AOOZD TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution 4 ENCL 3 SIZE:
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1, 1 PD3-1 PD ~
1 1 GIITTERFJ. 5 5 INTERNAL: NRR/DEST/ADS 7E 1 1 NRR/DEST/ESB 8D 1 1 NRR/DEST/ICSB NRR/DEST/RSB 8E 1
1 1
1 NRR/DEST/MTB 9H NRR/DOEA/TSB 11 1,
1 1
1 NUDOCS-ABSTRACT 1 1 OC L 1 0 OGC/HDS1 1 0 G FILE 1 1
.RES/DSIR/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOZE 'I0 ALL 'KIDS" RECIPIEÃIS:
PLEASE HELP US TO REDUCE, HASTE j CXÃIACT 'THE DOQ3MENI CGNZROL DESKS KXM P1-37 (EXT. 20079) KO EZZK2KEE KN3R MME HKH DISTRIBUTION LISTS FOR DOC(2KNIS YOU DOHFT NEED)
TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19
indiana Michigan t~ ~ II Power Company
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P.O. Box 16631 Columbus, OH 43216 AEP: NRC: 1102 Donald C. Cook Nuclear Plant Units 1 and 2 License Nos. DPR-58 and DPR-74 Docket Nos. 50-135 and 50-316 DELTA T REACTOR TRIPS TECHNICAL SPECIFICATION 4.0.4 CHANGE U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: T. E. Murley September 22, 1989
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 propose to add T/S 4.0.4 exemptions to the 18-month measurement of hot leg-cold leg delta T. We intend to perform the measurement as part of the calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1 (Reactor Trip System Instrumentation Surveillance Requirements). The reasons for the proposed changes and our analyses concerning significant hazards considerations are contained in Attachment 1 to this letter. The proposed revised T/S pages are contained in Attachment 2.
We believe that the proposed changes will not result in (1) a significant change in the types of effluents or a significant increase in the amounts of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.
These changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee at their next regularly scheduled meeting.
In compliance with the requirements of 10 CFR 50.92 (b)(1), copies of this letter and its attachments have been transmitted to Mr. R. C. Callen of the Michigan Public Service Commission and the Michigan Department of Public Health.
89'10040208 89'0922 PDR ADOCK 05000315 P PNU
Dr. T. E. Murley AEP:NRC:1102 This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M. P. Ale ich Vice President ldp Attachments cc: D. H. Williams, Jr.
W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff A. B. Davis NRC Resident Inspector - Bridgman NFEM Section Chief
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ATTACHMENT 1 TO AEP:NRC:1102 REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS to AEP:NRC:1102 Page 1 In this letter, we are proposing to modify the T/S 4.0.4 exemptions for the 18-month calibration of the overtemperature and overpower delta T reactor trips required by T/S Table 4.3-1, Functional Units 7 and 8. These functional units currently have T/S 4.0.4 exemptions for the F delta I penalties associated with the overtemperature and overpower reactor trips via Note 9 to Table 4.3-1. We are proposing to add a T/S 4.0.4 exemption for the measurement of delta T to Note 9.
Submittal of this proposed T/S change fulfills a commitment made in Unit 2 licensee event report (LER) 89-10 (Attachment 3). During the last Unit 2 refueling outage, all four steam generators were replaced. Delta T measurements were taken during unit startup and eventually were incorporated into the overtemperature and overpower delta T channel calibrations. Previously, the full power delta T value had been assumed to be a fixed nominal value. The new steam generators, however, resulted in enough of a change in the delta T to place the overtemperature and overpower delta T channel calibrations, which had been performed as required prior to entry into Mode 2, outside the allowable range of T/S Table 2.2-1.
Because the delta T value could change over time due, for example, to steam generator tube plugging or reactor coolant pump flow changes, we committed to measuring delta T values at the beginning of each cycle and adjusting the overtemperature and overpower delta T reactor trip calibrations as necessary. However, our T/Ss presently require the trips to be operable in Modes 1 and 2. T/S 4.0.4 prohibits entry into an operational mode or other specified applicabi11ty condition unless the surveillance requirements associated with the limiting condition for operation have been performed. The delta T measurements must be performed at full power since the overtemperature and overpower delta T functions are defined (in Table 2.2-1) as a function of the delta T at rated.
thermal power. Without an exemption to the requirements of T/S 4.0.4, the plant may be in literal noncompliance with the T/Ss between the time the initial calibration is performed (prior to entry into Mode 2) and the time the delta T measurements are taken and the initial calibration revised, as necessary.
Per 10 CFR 50.92, a proposed amendment will not involve a significant not:
hazards consideration if the proposed amendment does (1) 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 analyzed or evaluated, or, (3) involve a significant reduction in a margin of safety.
to AEP:NRC:1102 Page 2 Criterion 1 The change is necessary to allow for proper calibration of the overtemperature and overpower delta T functions without violation of T/S requirements. The change therefore corrects an inconsistency in our present T/S, and makes the T/S more accurately reflect, the system design. Since the change will allow us to measure delta T each cycle, rather than assuming a nominal value, the change should provide an enhancement to our calibration procedure. We therefore do not expect the change to involve a significant increase in the probability or consequences of a previously evaluated accident or significantly reduce the margin of safety.
Criterion 2 The change involves no physical modifications to the plant nor any significant changes in plant operations. Therefore, the change should not create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated.
Criterion 3 See Criterion 1 above.
We note that the Commission has provided guidance concerning the determination of significant hazards by providing examples (48 FR 14870) of amendments considered not likely to involve significant hazards considerations. The first example refers to changes that are administrative in nature: for example, correction of errors.
The change is similar to this example in that the present T/S does not reflect the fact that delta T measurements must be taken at full power. The sixth example refers to changes which may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are within acceptable limits. Technically, the change provides relief from current T/S requirements regarding operability of the overtemperature and overpower delta T reactor trips. However, the change will allow measurement of the delta T value each cycle, rather than assuming a nominal value for delta T.
This provides an enhancement to the calibration procedure, and therefore should increase rather than decrease safety. Based on the above discussion, we believe the examples cited are relevant and that the change should not involve significant hazards considerations.
We are also proposing a minor editorial change to Note 9 of T/S Table 4.3-1. The present Note 9 includes a reference to Note 1 of Table 2.2-1. This refers to the f delta I penalty of the overtemperature delta T. The inclusion of the delta T in the T/S 4.0.4 exemption provided by Note 9 would require expansion'of the to AEP:NRC:1102 - Page 3 reference to Notes 3 and 4 of Table 4.3-1, also. Rather than add the additional note numbers, we are proposing to modify the reference so that it refers generally to Table 2.2-1, rather than to the specific notes of Table 2,2-1. This will avoid cluttering Note 9 with the additional references. The change is purely administrative in nature, and therefore will not involve a significant increase in the probability or consequences of an accident previously evaluated, will not create the possibility of a new or different kind of accident from any previously analyzed or evaluated, and will not involve a significant reduction in a margin of safety.
ATTACHMENT 2 TO AEP:NRC:1102 PROPOSED REVISED TECHNICAL SPECIFICATION PAGES