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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 = 12
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| stage = Request
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{{#Wiki_filter:CATEGORY 1 1 REGULAT Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)DOCKET¹05000315 05000316 ACCESSION NBR:9809220081, DOC.DATE: 98/09/14 NOTARIZED:
{{#Wiki_filter:CATEGORY 1 1
YES FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 50;316 Ponald C.Cook Nuclear Power Plant, Unit 2, Indiana M AUTH.NAME AUTHOR AFFILIATION POWERS,R.P.
REGULAT     Y INFORMATION DISTRIBUTIO         SYSTEM (RIDS)
'Induna Michigan Power Co.(formerly Indiana&Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
ACCESSION   NBR:9809220081,         DOC.DATE: 98/09/14 NOTARIZED: YES                   DOCKET    ¹ FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana                     M   05000315 50;316 Ponald C. Cook Nuclear Power Plant, Unit 2, Indiana                   M   05000316 AUTH.NAME             AUTHOR AFFILIATION POWERS,R.P.         'Induna Michigan         Power Co. (formerly Indiana & Michigan Ele RECIP.NAME             RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)


==SUBJECT:==
==SUBJECT:==
Application for amends to licenses DPR-58 8 DPR-74,revising TS page 3/4 5-6.D1STRZBUT10N CODE: A'OOZD CORTES RECEZVED:LTR
Application for     amends   to licenses     DPR-58   8 DPR-74,revising TS page 3/4 5-6.
)ENCL I SZEE: P 1 TITLE: OR Submittal:
A D1STRZBUT10N CODE: A'OOZD         CORTES RECEZVED:LTR       ) ENCL     I SZEE:   P TITLE:   OR Submittal: General Distribution 1
General Distribution NOTES: A T, E RECIPIENT ID CODE/NAME PD3-3 LA STANG,J INTERNA ILE CENTER 01 NRR/DSSA/SPLB NUDOCS-ABSTRACT EXTERNAL: NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD3-3 PD NRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS3 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 0 1 1 0 D'NOTE TO ALL"RIDS" REC1PIENTS:
T, NOTES:                                                                                               E RECIPIENT           COPIES              RECIPIENT            COPIES ID CODE/NAME           LTTR ENCL        ID  CODE/NAME        LTTR ENCL PD3-3 LA                   1      1      PD3-3 PD                  1    1                0 STANG,J                   1      1 INTERNA       ILE CENTER     01       1     1       NRR/DE/ECGB/A             1    1 1      1      NRR/DRCH/HICB             1    1 NRR/DSSA/SPLB              1     1     NRR/DSSA/SRXB              1     1 NUDOCS-ABSTRACT            1     1       OGC/HDS3                  1     0 EXTERNAL: NOAC                                      NRC PDR                    1     1 D
PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 12 I C indiana Michigan~Power Company 500 Circle Drive Buchanan, Ml 491071373 September 14, 1998 AEP:NRC:1274 10 CFR 50.92 Docket Nos.: 50-315 50-316 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-Pl-17 Washington, D.C.20555-0001 Gentlemen:
NOTE TO ALL "RIDS" REC1PIENTS:
DONALD C.COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION AMENDMENT SAFETY INJECTION PUMP RUNOUT FLOW LIMITS This letter and its attachments constitute an application for amendment to the technical specifications (T/Ss)for Cook Nuclear Plant units 1 and 2.This amendment will change the runout limits for a safety injection pump to 675 gpm unless the pump is specifically tested to a higher flow rate not exceeding 700 gpm.Background information relevant to the T/S change and our analyses concerning significant hazards considerations are contained in attachment 1 to this letter.Attachment 2 contains the current T/S pages, marked-up to reflect the proposed change.The proposed revised T/S pages are contained in attachment 3.This submittal proposes a change to T/S page 3/4 5-6 for both unit 1 and 2.The proposed change will not result in a significant change in the types of effluents or a significant increase in the amounts of any effluents that may be released offsite or a significant increase in individual or cumulative occupational radiation exposure.The proposed change has been reviewed and approved by the plant nuclear safety review committee and the nuclear safety and design review committee.
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR               13   ENCL     12
We request that the approved amendment be effective thirty days from issuance.980'7220081 9809'X4 PDR ADOCK 05000815 P'OR U.S~Nuclear Regulatory Commission Page 2 AEP:NRC:1274 In accordance 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 the Michigan Department of Public Health.R.P.Powers Vice President SWORN TO AND SUBSCRIBED BEFORE ME~l~san*i INDE Notary Publi My commission expires l 2Z 01/jmc Attachments c: J.A.Abramson, w/attachments J.L.Caldwell, w/attachments MDEQ-DW&RPD, w/attachments NRC Resident Inspector, w/attachments J.R.Sampson, w/attachments sL C
~~ATTACHMENT 1 TO AEP:NRC:1274 SUPPORTING ANALYSES FOR AMENDMENT TO THE TECHNICAL SPECIFICATIONS SAFETY INJECTION PUMP RUNOUT FLOW LIMITS Attachment 1 to AEP:NRC:1274 Page 1 Back round Amendment numbers 84 (6/24/85)and 64 (6/18/84), respectively, to the unit 1 and unit 2.technical specifications (T/Ss)incorporated a change to the allowable safety injection (SI)pump runout limits in T/S 4.5.2.h.The change raised the permissible runout flow of a single SI pump from 650 gpm to 700 gpm.The pump runout flow changes were necessitated by physical changes to the SI pump miniflow recirculation lines.These physical changes increased miniflow capacity from 30 gpm to approximately 60 gpm and it was anticipated that the increased miniflow would make it difficult to achieve all of the SI pump design flow objectives without exceeding the 650 gpm runout limit existing at that time.The justification for the change from 650 to 700 gpm was based on vendor testing (Dresser Industries) of a single Cook Nuclear Plant replacement safety injection pump and a spare element.The testing established safe pump operation up to a maximum flow of 700 gpm.We confirmed that the available net positive suction head to the SI pumps, as installed at the plant, was greater than that required to safely achieve 700 gpm during the vendor testing.Therefore, we believed this testing was also applicable to the three (untested) installed pumps.In 1991, we received correspondence from Westinghouse indicating that the generic runout limits for Pacific 2" JTCH pumps was 675 gpm unless each specific pump was tested to a higher flow.At our request, Dresser reviewed the pump runout limits for Cook Nuclear Plant.Based on their review, Dresser concluded the following:
1)for the specific replacement pump and spare element previously tested by them, the 700 gpm runout limit remained applicable (this applies to the unit 2 north pump);and 2)for other (untested)
SI pumps, Dresser's position was to abide by the general Westinghouse limit of 675 gpm (this applies to both unit 1 pumps and the unit 2 south pump).They indicated that manufacturing tolerances in sand cast impellers and material changes in the pump casing (of the tested replacement pump)could result in test variations that limit applicability of the testing between pumps.Dresser also indicated that the generic limit of 675 gpm could be increased for the three untested pumps, with appropriate in place or vendor testing.Review of SI pump flow balancing data indicated that proper balancing could be achieved without exceeding 675 gpm for the three pumps that had not been specifically tested for higher flows.Procedure 12 EHP 4030 STP~208SIg U1&U2 ECCS FLOW BALANCE SAFETY INJECTlON SYSTEM", was changed to administratively limit flow of the three untested pumps to 675 gpm.Based on procedural controls for limiting runout flow of the three untested pumps, we concluded in 1992 that the intent of T/S 4.5.2.h was being met and that a change to the T/Ss was not necessary.
However, additional recent review has concluded that a change to the T/S should have been initiated.
This submittal provides the necessary change and also clarifies the basis for setting the SI pump runout limits.The bases clarification describes why the injection lineup is more conservative than the sump recirculation lineup (when the RHR pumps are providing a suction pressure boost)for potential SI pump runout.This is due to splitting of the SI


Attachment 1 to AEP:NRC: 1274 Page 2 trains during circulation, resulting in a higher system resistance than with a-single SI pump injecting to all four reactor coolant loops.Descri tion of Amendment Re uest Technical specification 4.5.2.h (SI system single pump)is being changed to require the maximum permitted runout flow rate for a SI pump be restricted to 675 gpm unless the pump is individually qualified to a higher flow rate of up to 700 gpm.Currently, T/S 4.5.2.h recognizes a runout flow rate of 700 gpm for each of the SI pumps.The basis is being clarified to describe why the injection lineup during flow balancing is the minimum resistance configuration for runout considerations.
I C indiana Michigan Power Company
Justification for Amendment The proposed amendment is necessary to correct a technical discrepancy in the runout flow limit for safety injection pumps that, have not been specifically tested to the limit currently allowed by T/S 4.5.2.h.Basis for No Significant Hazards Determination In accordance with 10 CFR 50.92, this proposed amendment does not involve a significant hazard consideration if it does not: 1)Involve a significant increase in the probability or consequences of an accident previously evaluated.
                        ~
The proposed reduction in the SI pump runout flow does not increase the probability of occurrence of anypreviously evaluated accident because the SI pumps are not considered to be accident initiators.
500 Circle Drive Buchanan, Ml 491071373 AEP:NRC:1274 September        14, 1998                                    10 CFR 50.92 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN:      Document Control Desk Mail Stop 0-Pl-17 Washington,        D. C. 20555-0001 Gentlemen:
In addition, flow balancing performed at Cook Nuclear Plant has proven the ability to deliver the minimum T/S flow o f 300 gpm to each pair o f cold leg injection points without exceeding the 675 gpm (or 700 gpm)pump runout limits.Therefore, the emergency core cooling system performance objectives of 10 CFR 50.46 are not impacted and this change does not involve a significant increase in the consequences of an accident previously evaluated.
DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION AMENDMENT SAFETY INJECTION PUMP RUNOUT FLOW LIMITS This    letter      and its attachments constitute an application for amendment        to the technical specifications (T/Ss) for Cook Nuclear Plant units 1 and 2. This amendment will change the runout limits for a safety injection pump to 675 gpm unless the pump is specifically tested to a higher flow rate not exceeding 700 gpm.
2)Create the possibility of a new or different kind of accident from any accident previously evaluated.
Background information relevant to the T/S change and our analyses concerning significant hazards considerations are contained in attachment 1 to this letter. Attachment 2 contains the current T/S pages, marked-up to reflect the proposed change.            The proposed revised T/S pages are contained in attachment 3.
This proposed change imposes a generic limit on maximum allowable flow for untested SI pumps.No physical system changes or changes in operating modes are being made that could introduce new or different kinds of accidents from those previously evaluated.
This submittal proposes a change to T/S page 3/4 5-6 for both unit 1 and 2. The proposed            change will not result in a significant change in the types of effluents or a significant increase in the amounts of any effluents that may be released offsite or a significant increase in individual or cumulative occupational radiation exposure.
As discussed in (1)above, the SI pumps are not considered accident initiators, and this status is not affected by the change to the SI pump runout limits.
The proposed change has been reviewed and approved by the plant nuclear safety review committee and the nuclear safety and design review committee. We request that the approved amendment be effective thirty          days from issuance.
Attachment 1 to AEP:NRC:1274 Page 3 3)Involve a significant reduction in a margin of safety.This change reflects a reduced maximum single pump flow to be observed during flow balancing of the SI system.Flow balance testing at Cook Nuclear Plant has demonstrated the ability to meet SI flow requirements while maintaining an adequate margin to the revised lower runout limits being proposed by this submittal.
980'7220081        9809'X4 PDR P
Because the minimum required SI flow delivered to the core has not been reduced by this change, the change does not involve a reduction in a margin of safety.Based on the preceding, the evaluation concluded that the proposed change to the SI pump runout limits does not involve a significant hazards consideration as defined in 10 CFR 50.92.
ADOCK
ATTACHMENT 2 TO AEP:NRC:1274 CURRENT PAGES MARKED-UP TO SHOW PROPOSED CHANGES TO THE DONALD CD COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION SAFETY INJECTION PUMP RUNOUT FLOW LIMITS UNIT NO.1}}
                'OR05000815
 
U. S ~ Nuclear Regulatory Commission                  AEP:NRC:1274 Page  2 In accordance 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 the Michigan Department of Public Health.
R. P. Powers Vice President SWORN TO AND SUBSCRIBED BEFORE ME
      ~l              ~san*i      INDE Notary Publi My  commission expires  l  2Z 01
/jmc Attachments c:      J. A. Abramson, w/attachments J. L. Caldwell, w/attachments MDEQ - DW & RPD, w/attachments NRC Resident Inspector, w/attachments J. R. Sampson, w/attachments
 
sL C
 
~ ~
ATTACHMENT 1 TO AEP:NRC:1274 SUPPORTING ANALYSES FOR AMENDMENT TO THE TECHNICAL SPECIFICATIONS SAFETY INJECTION PUMP RUNOUT FLOW LIMITS to  AEP:NRC:1274                                Page  1 Back round Amendment numbers 84 (6/24/85) and 64 (6/18/84), respectively, to the unit 1 and unit 2.technical specifications (T/Ss) incorporated a change  to the allowable safety injection (SI) pump runout limits in  T/S  4.5.2.h. The change raised the permissible runout flow of a single SI pump from 650 gpm to 700 gpm.        The pump runout flow changes were necessitated by physical changes to the SI pump miniflow recirculation lines.        These physical changes increased miniflow capacity from 30 gpm to approximately 60 gpm and it      it  was difficult to anticipated that the increased miniflow would make achieve all of the SI pump design flow objectives without exceeding the 650 gpm runout limit existing at that time. The justification for the change from 650 to 700 gpm was based on vendor testing (Dresser Industries) of a single Cook Nuclear Plant replacement safety injection pump and a spare element. The testing established safe pump operation up to a maximum flow of 700 gpm.      We confirmed that the available net positive suction head to the SI pumps, as installed at the plant, was greater than that required to safely achieve 700 gpm during the vendor testing. Therefore, we believed this testing was also applicable to the three (untested) installed pumps.
In 1991, we received correspondence from Westinghouse indicating that the generic runout limits for Pacific 2" JTCH pumps was 675 gpm unless each specific pump was tested to a higher flow. At our request, Dresser reviewed the pump runout limits for Cook Nuclear Plant. Based on their review, Dresser concluded the following: 1) for the specific replacement pump and spare element previously tested by them, the 700 gpm runout limit remained applicable (this applies to the unit 2 north pump); and 2) for other (untested) SI pumps, Dresser's position was to abide by the general Westinghouse limit of 675 gpm (this applies to both unit 1 pumps and the unit 2 south pump). They indicated that manufacturing tolerances in sand cast impellers and material changes in the pump casing (of the tested replacement pump) could result in test variations that limit applicability of the testing between pumps. Dresser also indicated that the generic limit of 675 gpm could be increased for the three untested pumps, with appropriate in place or vendor testing. Review of SI pump flow balancing data indicated that proper balancing could be achieved without exceeding 675 gpm for the three pumps that had not been specifically tested for higher flows. Procedure 12 EHP 4030 STP 208SIg
                  ~        U1 & U2 ECCS FLOW BALANCE SAFETY INJECTlON SYSTEM", was changed to administratively limit flow of the three untested pumps to 675 gpm.
Based on procedural controls for limiting runout flow of the three untested pumps, we concluded in 1992 that the intent of T/S 4.5.2.h was being met and that a change to the T/Ss was not necessary.
However, additional recent review has concluded that a change to the T/S should have been initiated.        This submittal provides the necessary change and also clarifies the basis for setting the SI pump runout limits.        The bases clarification describes why the injection lineup is more conservative than the sump recirculation lineup (when the RHR pumps are providing a suction pressure boost) for potential SI pump runout. This is due to splitting of the SI
 
to  AEP:NRC: 1274                                 Page 2 trains during circulation, resulting in a higher system resistance than with a- single SI pump injecting to all four reactor coolant loops.
Descri tion of Amendment     Re uest Technical specification 4.5.2.h (SI system single pump) is being changed to require the maximum permitted runout flow rate for a SI pump be restricted to 675 gpm unless the pump is individually qualified to a higher flow rate of up to 700 gpm. Currently, T/S 4.5.2.h recognizes a runout flow rate of 700 gpm for each of the SI pumps. The basis is being clarified to describe why the injection lineup during flow balancing is the minimum resistance configuration for runout considerations.
Justification for     Amendment The   proposed   amendment     is necessary to correct   a   technical discrepancy in the runout flow limit for safety injection pumps that, have not been specifically tested to the limit currently allowed by T/S 4.5.2.h.
Basis for No Significant   Hazards Determination In accordance with 10 CFR 50.92, this proposed                   does not involve a significant hazard consideration       if itamendment does not:
: 1)     Involve   a   significant increase     in the probability or consequences   of an accident previously evaluated.
The proposed   reduction in the SI pump runout flow does not increase the probability of occurrence of any previously evaluated accident because the SI pumps are not considered to be accident initiators. In addition, flow balancing performed at Cook Nuclear Plant has proven the ability to deliver the minimum T/S flow o f 300 gpm to each pair o f cold leg injection points without exceeding the 675 gpm (or 700 gpm) pump runout limits. Therefore, the emergency core cooling system performance objectives of 10 CFR 50.46 are not impacted and this change does not involve a significant increase in the consequences of an accident previously evaluated.
: 2)     Create the possibility of a new or different kind of accident from any accident previously evaluated.
This proposed change imposes a generic limit on maximum allowable flow for untested SI pumps. No physical system changes or changes in operating modes are being made that could introduce new or different kinds of accidents from those previously evaluated. As discussed in (1) above, the SI pumps are not considered accident initiators, and this status is not affected by the change to the SI pump runout limits.
to AEP:NRC:1274                                 Page 3
: 3)     Involve a significant reduction in a margin of safety.
This change reflects a reduced maximum single pump flow to be observed during flow balancing of the SI system.         Flow balance testing at Cook Nuclear Plant has demonstrated the ability to meet SI flow requirements while maintaining an adequate margin to the revised lower runout limits being proposed by this submittal. Because the minimum required SI flow delivered to the core has not been reduced by this change, the change does not involve a reduction in a margin of safety.
Based on the preceding, the evaluation concluded that the proposed change to the SI pump runout limits does not involve a significant hazards consideration as defined in 10 CFR 50.92.
 
ATTACHMENT 2 TO AEP:NRC:1274 CURRENT PAGES MARKED-UP TO SHOW PROPOSED CHANGES TO THE DONALD CD COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION SAFETY INJECTION PUMP RUNOUT FLOW LIMITS
 
UNIT NO. 1}}

Latest revision as of 00:31, 4 February 2020

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
ML17335A231
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 09/14/1998
From: Powers R
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17335A233 List:
References
AEP:NRC:1274, NUDOCS 9809220081
Download: ML17335A231 (12)


Text

CATEGORY 1 1

REGULAT Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9809220081, DOC.DATE: 98/09/14 NOTARIZED: YES DOCKET ¹ FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50;316 Ponald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAME AUTHOR AFFILIATION POWERS,R.P. 'Induna Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses DPR-58 8 DPR-74,revising TS page 3/4 5-6.

A D1STRZBUT10N CODE: A'OOZD CORTES RECEZVED:LTR ) ENCL I SZEE: P TITLE: OR Submittal: General Distribution 1

T, NOTES: E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 LA 1 1 PD3-3 PD 1 1 0 STANG,J 1 1 INTERNA ILE CENTER 01 1 1 NRR/DE/ECGB/A 1 1 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3 1 0 EXTERNAL: NOAC NRC PDR 1 1 D

NOTE TO ALL "RIDS" REC1PIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 12

I C indiana Michigan Power Company

~

500 Circle Drive Buchanan, Ml 491071373 AEP:NRC:1274 September 14, 1998 10 CFR 50.92 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-Pl-17 Washington, D. C. 20555-0001 Gentlemen:

DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION AMENDMENT SAFETY INJECTION PUMP RUNOUT FLOW LIMITS This letter and its attachments constitute an application for amendment to the technical specifications (T/Ss) for Cook Nuclear Plant units 1 and 2. This amendment will change the runout limits for a safety injection pump to 675 gpm unless the pump is specifically tested to a higher flow rate not exceeding 700 gpm.

Background information relevant to the T/S change and our analyses concerning significant hazards considerations are contained in attachment 1 to this letter. Attachment 2 contains the current T/S pages, marked-up to reflect the proposed change. The proposed revised T/S pages are contained in attachment 3.

This submittal proposes a change to T/S page 3/4 5-6 for both unit 1 and 2. The proposed change will not result in a significant change in the types of effluents or a significant increase in the amounts of any effluents that may be released offsite or a significant increase in individual or cumulative occupational radiation exposure.

The proposed change has been reviewed and approved by the plant nuclear safety review committee and the nuclear safety and design review committee. We request that the approved amendment be effective thirty days from issuance.

980'7220081 9809'X4 PDR P

ADOCK

'OR05000815

U. S ~ Nuclear Regulatory Commission AEP:NRC:1274 Page 2 In accordance 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 the Michigan Department of Public Health.

R. P. Powers Vice President SWORN TO AND SUBSCRIBED BEFORE ME

~l ~san*i INDE Notary Publi My commission expires l 2Z 01

/jmc Attachments c: J. A. Abramson, w/attachments J. L. Caldwell, w/attachments MDEQ - DW & RPD, w/attachments NRC Resident Inspector, w/attachments J. R. Sampson, w/attachments

sL C

~ ~

ATTACHMENT 1 TO AEP:NRC:1274 SUPPORTING ANALYSES FOR AMENDMENT TO THE TECHNICAL SPECIFICATIONS SAFETY INJECTION PUMP RUNOUT FLOW LIMITS to AEP:NRC:1274 Page 1 Back round Amendment numbers 84 (6/24/85) and 64 (6/18/84), respectively, to the unit 1 and unit 2.technical specifications (T/Ss) incorporated a change to the allowable safety injection (SI) pump runout limits in T/S 4.5.2.h. The change raised the permissible runout flow of a single SI pump from 650 gpm to 700 gpm. The pump runout flow changes were necessitated by physical changes to the SI pump miniflow recirculation lines. These physical changes increased miniflow capacity from 30 gpm to approximately 60 gpm and it it was difficult to anticipated that the increased miniflow would make achieve all of the SI pump design flow objectives without exceeding the 650 gpm runout limit existing at that time. The justification for the change from 650 to 700 gpm was based on vendor testing (Dresser Industries) of a single Cook Nuclear Plant replacement safety injection pump and a spare element. The testing established safe pump operation up to a maximum flow of 700 gpm. We confirmed that the available net positive suction head to the SI pumps, as installed at the plant, was greater than that required to safely achieve 700 gpm during the vendor testing. Therefore, we believed this testing was also applicable to the three (untested) installed pumps.

In 1991, we received correspondence from Westinghouse indicating that the generic runout limits for Pacific 2" JTCH pumps was 675 gpm unless each specific pump was tested to a higher flow. At our request, Dresser reviewed the pump runout limits for Cook Nuclear Plant. Based on their review, Dresser concluded the following: 1) for the specific replacement pump and spare element previously tested by them, the 700 gpm runout limit remained applicable (this applies to the unit 2 north pump); and 2) for other (untested) SI pumps, Dresser's position was to abide by the general Westinghouse limit of 675 gpm (this applies to both unit 1 pumps and the unit 2 south pump). They indicated that manufacturing tolerances in sand cast impellers and material changes in the pump casing (of the tested replacement pump) could result in test variations that limit applicability of the testing between pumps. Dresser also indicated that the generic limit of 675 gpm could be increased for the three untested pumps, with appropriate in place or vendor testing. Review of SI pump flow balancing data indicated that proper balancing could be achieved without exceeding 675 gpm for the three pumps that had not been specifically tested for higher flows. Procedure 12 EHP 4030 STP 208SIg

~ U1 & U2 ECCS FLOW BALANCE SAFETY INJECTlON SYSTEM", was changed to administratively limit flow of the three untested pumps to 675 gpm.

Based on procedural controls for limiting runout flow of the three untested pumps, we concluded in 1992 that the intent of T/S 4.5.2.h was being met and that a change to the T/Ss was not necessary.

However, additional recent review has concluded that a change to the T/S should have been initiated. This submittal provides the necessary change and also clarifies the basis for setting the SI pump runout limits. The bases clarification describes why the injection lineup is more conservative than the sump recirculation lineup (when the RHR pumps are providing a suction pressure boost) for potential SI pump runout. This is due to splitting of the SI

to AEP:NRC: 1274 Page 2 trains during circulation, resulting in a higher system resistance than with a- single SI pump injecting to all four reactor coolant loops.

Descri tion of Amendment Re uest Technical specification 4.5.2.h (SI system single pump) is being changed to require the maximum permitted runout flow rate for a SI pump be restricted to 675 gpm unless the pump is individually qualified to a higher flow rate of up to 700 gpm. Currently, T/S 4.5.2.h recognizes a runout flow rate of 700 gpm for each of the SI pumps. The basis is being clarified to describe why the injection lineup during flow balancing is the minimum resistance configuration for runout considerations.

Justification for Amendment The proposed amendment is necessary to correct a technical discrepancy in the runout flow limit for safety injection pumps that, have not been specifically tested to the limit currently allowed by T/S 4.5.2.h.

Basis for No Significant Hazards Determination In accordance with 10 CFR 50.92, this proposed does not involve a significant hazard consideration if itamendment does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed reduction in the SI pump runout flow does not increase the probability of occurrence of any previously evaluated accident because the SI pumps are not considered to be accident initiators. In addition, flow balancing performed at Cook Nuclear Plant has proven the ability to deliver the minimum T/S flow o f 300 gpm to each pair o f cold leg injection points without exceeding the 675 gpm (or 700 gpm) pump runout limits. Therefore, the emergency core cooling system performance objectives of 10 CFR 50.46 are not impacted and this change does not involve a significant increase in the consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

This proposed change imposes a generic limit on maximum allowable flow for untested SI pumps. No physical system changes or changes in operating modes are being made that could introduce new or different kinds of accidents from those previously evaluated. As discussed in (1) above, the SI pumps are not considered accident initiators, and this status is not affected by the change to the SI pump runout limits.

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3) Involve a significant reduction in a margin of safety.

This change reflects a reduced maximum single pump flow to be observed during flow balancing of the SI system. Flow balance testing at Cook Nuclear Plant has demonstrated the ability to meet SI flow requirements while maintaining an adequate margin to the revised lower runout limits being proposed by this submittal. Because the minimum required SI flow delivered to the core has not been reduced by this change, the change does not involve a reduction in a margin of safety.

Based on the preceding, the evaluation concluded that the proposed change to the SI pump runout limits does not involve a significant hazards consideration as defined in 10 CFR 50.92.

ATTACHMENT 2 TO AEP:NRC:1274 CURRENT PAGES MARKED-UP TO SHOW PROPOSED CHANGES TO THE DONALD CD COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATION SAFETY INJECTION PUMP RUNOUT FLOW LIMITS

UNIT NO. 1