ML17332A799

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

ML17332A799
Person / Time
Site:	Cook
Issue date:	06/15/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17332A800	List: ML17332A799 ML17332A801 ML17332A802
References
AEP:NRC:0896V, AEP:NRC:896V, NUDOCS 9506200465
Download: ML17332A799 (10)

Text

RIORITY ACCELERATED RIDS PROCESSING

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9506200465 DOC.DATE: 95/06/15 NOTARIZED: YES DOCKET g FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. Indiana Michigan Power Co. (formerly Xndiana & Michigan Ele RECIPIENT AFFILIATION F'ECIP.NAME Document Control Branch (Document Control Desk) R

SUBJECT:

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.

DISTR1BUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution I ENCL g SIZE: 0 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 HICKMAN,J 1 1 INTERNAL 1E E CENTER 1 1 1 NRR/DE/EMCB 1 1 CB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE KVASTE! CONTACT THE DOCUiIENT CONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELIS!!NATE YOUR 4AML FROM DISTRIBUTION LISTS I'OR DOCUMENTS YOU DON "I'EED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11

Indiana MicIdgan Power Company ~'

P.O. Box 16631 Columbus, OH 43216 June 15, 1995 AEP:NRC:0896V Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 TECHNICAL SPECIFICATION CHANGES TO MODIFY SURVEILLANCE TESTING OF THE EMERGENCY DIESEL GENERATORS DURING REFUELING This letter and its attachments constitute an application for amendment to the technical specifications (T/Ss) for Donald C. Cook Nuclear Plant Units 1 and 2. Specifically, we are proposing to implement changes to modify surveillance testing for the emergency diesel generators (EDGs) during refueling operations.

Attachment 1 provides a detailed description of the proposed changes, the justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50.92. Attachment 2 contains the existing T/S pages marked to reflect the proposed changes. Attachment 3 contains the proposed T/S pages. Attachment 4 provides a technical evaluation report.

In addition, this is a cost beneficial licensing action (CBLA) submittal and represents a high priority item since it will, once approved, result in a significant reduction in operating cost.

The lifetime cost saving associated with this CBLA is approximately $ 600,000, as detailed in Attachment 5.

We believe that the proposed changes will not result in (1) a significant change in the types of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

9506200465 950b15 PDR ADOCK 05000315 l p PDR

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U.S. Nuclear Regulatory Commission AEP:NRC:0896V Page 2 These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and will be reviewed by the Nuclear Safety and Design Review Committee at its next regularly scheduled meeting.

In compliance with the requirements of 10 CFR 50 '1(b)(1), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.

This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached.

Sincerely, Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS ~beg DAY OF ~. . 1995 No ary Public cad Attachments

T U.S. Nuclear Regulatory Commission AEP:NRC:0896V Page 3 CC: A. A. Blind G. Charnoff J. B. Martin NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett

ATTACHMENT 1 TO AEP:NRC:0896V DESCRIPTION AND JUSTIFICATION OF CHANGES 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS to AEP:NRC:0896V Page 1 A. DESCRIPTION OF CHANGES The changes proposed by this letter involve the emergency diesel generator (EDG) 18 month 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance test. The changes are described individually as follows:

Emergency Diesel Generator Surveillance Requirements T/S: 4.8.1.1.2.e.7 (Units 1 and 2)

Page: 3/4 8-6 (Units 1 and 2)

1) Reduce the duration of the surveillance test from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

2) Modify the footnote associated with the asterisk at the end of 4.8.1.1.2.e.7 to reflect the reduction of the surveillance test from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

B. JUSTIFICATION FOR CHANGES The proposed changes involve the 18 month 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EDG surveillance which is implemented by plant procedure. The proposed changes are designed to reduce operating costs, increase outage scheduling flexibility, reduce shutdown risk, and increase diesel life.

Reducing the surveillance time from 24 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> would significantly improve outage performance without reducing EDG reliability. Based on examination of Cook Nuclear Plant test data

.from'1974 to 1994, it is clear that extensive run times beyond .the point where the EDG 'i's sta'rted, loa'ded to:3500KW, and achieves an e'quilibrium reliability.

. condition The engine provide 'ittle insight regarding EDG.

steady-state characteristics are achieved in approximately'2 ho'urs and the dominant failure modes of the EDG are expected to occur. wi'thin this period. Xn addition, r'eview of the'4 .hour,te'st data'rom 1974 'to 1994 does 'not.; indicate ~he, discovery .of any abnoraral conditions that would'have'je'opardized'the' from completing its mission during an actual emergency 'iesel demand. Therefore, as described in Attachment 4, reduction of the test duration from a 24 to an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period will maintain an equivalent level of confidence in EDG reliability and may actually improve overall EDG reliability.

Attachment 1 to AEP:NRC:0896V Page 2 C. 10 CFR 50 2 CRITERIA Per 10 CFR 50.92, a proposed change does not involve a significant hazards consideration if the change does not:

involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.

Criterion 1 The safety function of the EDGs is to supply ac electrical power to plant safety systems whenever the preferred ac power supply is unavailable.

Through surveillance requirements, the ability of the EDGs to meet their load and timing requirements is tested and the quality of the fuel and the availability of the fuel supply are monitored. Reduction of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will not reduce the surveillance factors under consideration and will sufficiently exercise the EDG and its support systems to identify potential conditions that could lead to performance degradation (See Attachment 4). Based on these considerations, concluded that the proposed changes do not involve a significant it is increase'n the probability or consequences of an accident previously evaluated.

0 Criterion 2 The proposed changes do not involve physical changes to the plant or changes. in'lant operating .configuration. The changes only involve the reduction of'18 moth 24:hour EDG.survei3.lanpe test dur'ation, Thus,',it. is'"

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concluded that the. proposed changes. do not'create'he possibility of".a new or different kind of accident from any accident previously evaluated.

Criterion 3 Although the duration of the 18 month 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EDG surveillance test would be reduce'd, the EDG components will continue to be sufficiently exercised such that the ability to detect incipient and degraded conditions will be maintained (See Attachment 4, Figure 2). The proposed changes have been determined to be compatible with our plant operating experience and commensurate with past surveillance test results. Based on these considerations, it is concluded that the proposed changes do not involve a significant reduction in a margin of safety.