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{{#Wiki_filter:CATEGORY1REGULATOROINFORMATZON DISTRIBUTION TEM(RIDE)ACCESSION NBR:9612270111 DOC.DATE:
{{#Wiki_filter:CATEGORY 1 REGULATOROINFORMATZON DISTRIBUTION TEM (RIDE)ACCESSION NBR:9612270111 DOC.DATE: 96/12/20 NOTARIZED:
96/12/20NOTARIZED:
YES FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.E American Electric Power Co., Inc.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
YESFACIL:50-315 DonaldC.CookNuclearPowerPlant,Unit1,IndianaM50-316DonaldC.CookNuclearPowerPlant,Unit2,IndianaMAUTH.NAMEAUTHORAFFILIATION FITZPATRICK,E.E AmericanElectricPowerCo.,Inc.RECIP.NAME RECIPIENT AFFILIATION DocumentControlBranch(Document ControlDesk)


==SUBJECT:==
==SUBJECT:==
Application foramendstolicensesDPR-58!'PR-74,requesting revofreactorcoolantpumpflywheelinspfrequency.
Application for amends to licenses DPR-58!'PR-74, requesting rev of reactor coolant pump flywheel insp frequency.
DISTRIBUTION CODE:AOOZDCOPIESRECEIVED:LTR 1ENCLiSIZE:4I4TITLE:ORSubmittal:
DISTRIBUTION CODE: AOOZD COPIES RECEIVED:LTR 1 ENCL i SIZE: 4I 4 TITLE: OR Submittal:
GeneralDistribution NOTES:DOCKET0500031505000316ERECIPIENT IDCODE/NAME PD3-3LAHICKMAN,J INTERNA:MLECENTE0.RDEEMCBNRR/DSSA/SPLB NUDOCS-ABSTRACT EXTERNAL:
General Distribution NOTES: DOCKET 05000315 05000316 E RECIPIENT ID CODE/NAME PD3-3 LA HICKMAN,J INTERNA:M LE CENTE 0.R DE EMCB 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/HDS2 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 0 1 1 D U N NOTE TO ALL"RIDS" RECIPIENTS:
NOACCOPIESLTTRENCL111111111111RECIPIENT IDCODE/NAME PD3-3PDNRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS2NRCPDRCOPIESLTTRENCL111111111011DUNNOTETOALL"RIDS"RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL.'12 Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 491071395 INQMNA NICNESAN PQWM December 20, 1996 Docket No: 50-315 50-316 AEP:NRC:1245 10 CFR 50.90 U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Gentlemen:
PLEASEHELPUSTOREDUCEWASTE!CONTACTTHEDOCUMENTCONTROLDESK,ROOMOWFN5D-5(EXT.
Donald C.Cook Nuclear Plant Units 1 and 2 LICENSE NOS.DPR-58 AND DPR"74 PROPOSED LICENSE AND TECHNICAL SPECIFICATION CHANGES OF REACTOR COOLANT PUMP FLYWHEEL INSPECTION FREQUENCY This letter and its attachments constitute an application for amendment of the technical specifications (T/S)for Cook Nuclear Plant units 1 and 2.Changes are proposed to reduce the frequency and scope of reactor coolant pump flywheel inspections consistent with your staff's evaluation of WCAP-14535,"Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination." A description of the proposed changes and an analysis concerning significant hazards consideration pursuant to 10 CFR 50.92 is contained in attachment 1.Attachment 2 contains the existing T/S pages marked to reflect the proposed changes.Attachment
415-2083)
.3 contains the proposed, revised T/S pages.We believe the proposed T/S changes will not result in a significant change in the types of effluents or a significant increase in the amount of effluent that might be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee~
TOELIMINATE YOURNAMEFROMDISTRIBUTION LISTSFORDOCUMENTS YOUDON'TNEED!TOTALNUMBEROFCOPIESREQUIRED:
.In compliance 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.
LTTR13ENCL.'12 IndianaMichiganPowerCompany500CircleDriveBuchanan, Ml491071395 INQMNANICNESANPQWMDecember20,1996DocketNo:50-31550-316AEP:NRC:1245 10CFR50.90U.S.NuclearRegulatory Commission DocumentControlDeskWashington, D.C.20555Gentlemen:
of Public Health.Sincerely, SWORN TO AND SUBSCRIBED BEFORE ME I THIS~O DAY OF~~Mt 1996 E.E.Fit patrick 96 O O3 Vice President Attachments Notary Public My Commission Expires: JAN WATSON NOTARY PUBUC, BERRIEN COUNTY, MI I MY COMMISSION EXPIRES FEB 10 1999'Pbi2270iii 9hi220 PDR ADQCK 050003l5 P PDR J 1';C.1W t q'a e 4~I a ,<<W*<<i~u~"" C U.S.Nuclear Regulatory Commission Page 2 AEP: NRC: 1245 cc: A.A.Blind A.B.Beach MDEQ" DW Ec RPD NRC Resident Inspector J.R.Padgett ATTACHMENT 1 TO AEP:NRC:124S 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS Attachment 1 to AEP:NRC:1245 Page 1 1.0 SECTION TO BE CHANGED 1.Unit 1 technical specification (T/S)4.4.10.1 2.Unit 2 T/S 4.4.10.1 2.0 EXTENT OF CHANGES 1.We are proposing to change unit 1 T/S 4.4.10.1 to require reactor coolant pump (RCP)flywheel inspections once every 10 years in the manner described below.We are proposing to change unit 2 T/S 4.4.10.1 to require RCP flywheel inspections once every 10 years in the manner described below.3.0 CHANGES RE UESTED We are proposing to make the following change to the unit 1 and unit 2 T/Ss.Currently T/S section 4.4.10.1 requires that each reactor coolant pump flywheel be inspected per the recommendations of regulatory position C.4.b of Regulatory Guide (RG)1.14, Revision 1, August 1975.The regulatory position of RG 1.14 concerning ISI calls for an in-place ultrasonic volumetric examination of the areas of higher stress concentration at the bore and keyway at approximately 3-year intervals and a surface examination of all exposed surfaces and complete ultrasonic volumetric examination at approximately 10-year intervals.
DonaldC.CookNuclearPlantUnits1and2LICENSENOS.DPR-58ANDDPR"74PROPOSEDLICENSEANDTECHNICAL SPECIFICATION CHANGESOFREACTORCOOLANTPUMPFLYWHEELINSPECTION FREQUENCY Thisletteranditsattachments constitute anapplication foramendment ofthetechnical specifications (T/S)forCookNuclearPlantunits1and2.Changesareproposedtoreducethefrequency andscopeofreactorcoolantpumpflywheelinspections consistent withyourstaff'sevaluation ofWCAP-14535, "TopicalReportonReactorCoolantPumpFlywheelInspection Elimination."
The proposed T/S requires that either a qualified in-place UT examination over the volume from the inner bore of the flywheel to the circle of one-half the outer radius or a surface examination (MT and/or PT)of exposed surfaces defined by the volume of the disassembled flywheels be conducted once every 10 years.4.0 DISCUSSION Technical S ecification 4.4.10.1 Bases T/S 4.4.10.1 ensures that the structural integrity of the reactor coolant pump flywheels will be maintained at an acceptable level throughout the life of the plant.Justification for Pro osed Technical S ecification Chan es The proposed T/S amendment request to reduce the frequency and scope of surveillance of the RCP flywheels is justified for several reasons.This change is consistent with Mr.Sheron's (Director Division of Engineering, Office of Nuclear Reactor Regulation) letter entitled"Acceptance for Referencing of Topical Report WCAP-14535,'Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination' and related attachments.
Adescription oftheproposedchangesandananalysisconcerning significant hazardsconsideration pursuantto10CFR50.92iscontained inattachment 1.Attachment 2containstheexistingT/Spagesmarkedtoreflecttheproposedchanges.Attachment
Per the requirement of this letter, we have confirmed that the RCP flywheels in place at Cook Nuclear Plant are composed of SA 533 B material.Though Westinghouse Electric Corporation report WCAP-14535, entitled"Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination", seeks elimination of flywheel inspections, we only Attachment 1 to AEP:NRC:1245 Page 2 seek to reduce the frequency of these inspections to once every 10 years.WCAP-14535-concludes the following.
.3containstheproposed, revisedT/Spages.WebelievetheproposedT/Schangeswillnotresultinasignificant changeinthetypesofeffluents orasignificant increaseintheamountofeffluentthatmightbereleasedoffsite,orasignificant increaseinindividual orcumulative occupational radiation exposure.
1.Flywheels are carefully designed and manufactured from excellent quality steel, which has a high fracture toughness.
TheseproposedchangeshavebeenreviewedbythePlantNuclearSafetyReviewCommittee andtheNuclearSafetyandDesignReviewCommittee~
2.Flywheel overspeed is the critical loading, but leak before break has limited the maximum speed to less than 1500 rpm.6.7.Flywheel inspections have been performed for 2C years, with no indications of service induced flaws.Flywheel integrity evaluations show very high flaw tolerance for the flywheels.
.Incompliance withtherequirements of10CFR50.91(b)(1),
Crack extension over a 60 year service life is negligible.
copiesofthisletteranditsattachments havebeentransmitted totheMichiganPublicServiceCommission andtheMichiganDepartment.
Structural reliability studies have shown that eliminating inspections after 10 years of plantlife will not significantly change the probability of failure.Most flaws which could lead to failure would be detected during preservice inspection or at worst early in plant life, and crack growth over plant life is negligible.
ofPublicHealth.Sincerely, SWORNTOANDSUBSCRIBED BEFOREMEITHIS~ODAYOF~~Mt1996E.E.Fitpatrick96OO3VicePresident Attachments NotaryPublicMyCommission Expires:JANWATSONNOTARYPUBUC,BERRIENCOUNTY,MIIMYCOMMISSION EXPIRESFEB101999'Pbi2270iii 9hi220PDRADQCK050003l5PPDR J1';C.1Wtq'ae4~Ia,<<W*<<i~u~""C U.S.NuclearRegulatory Commission Page2AEP:NRC:1245cc:A.A.BlindA.B.BeachMDEQ"DWEcRPDNRCResidentInspector J.R.Padgett ATTACHMENT 1TOAEP:NRC:124S 10CFR50.92ANALYSISFORCHANGESTOTHEDONALDC.COOKNUCLEARPLANTUNITS1AND2TECHNICAL SPECIFICATIONS Attachment 1toAEP:NRC:1245 Page11.0SECTIONTOBECHANGED1.Unit1technical specification (T/S)4.4.10.12.Unit2T/S4.4.10.12.0EXTENTOFCHANGES1.Weareproposing tochangeunit1T/S4.4.10.1torequirereactorcoolantpump(RCP)flywheelinspections onceevery10yearsinthemannerdescribed below.Weareproposing tochangeunit2T/S4.4.10.1torequireRCPflywheelinspections onceevery10yearsinthemannerdescribed below.3.0CHANGESREUESTEDWeareproposing tomakethefollowing changetotheunit1andunit2T/Ss.Currently T/Ssection4.4.10.1requiresthateachreactorcoolantpumpflywheelbeinspected pertherecommendations ofregulatory positionC.4.bofRegulatory Guide(RG)1.14,Revision1,August1975.Theregulatory positionofRG1.14concerning ISIcallsforanin-placeultrasonic volumetric examination oftheareasofhigherstressconcentration attheboreandkeywayatapproximately 3-yearintervals andasurfaceexamination ofallexposedsurfacesandcompleteultrasonic volumetric examination atapproximately 10-yearintervals.
As stated in the SER associated with WCAP-14535, assuming an initial crack of 10%of the distance from the keyway to the flywheel outer radius and a maximum fatigue crack growth, ASME margins would be maintained during the 10-year inspection period.Inspections result in man rem exposure and the potential for flywheel damage during disassembly and reassembly.
TheproposedT/Srequiresthateitheraqualified in-placeUTexamination overthevolumefromtheinnerboreoftheflywheeltothecircleofone-halftheouterradiusorasurfaceexamination (MTand/orPT)ofexposedsurfacesdefinedbythevolumeofthedisassembled flywheels beconducted onceevery10years.4.0DISCUSSION Technical Secification 4.4.10.1BasesT/S4.4.10.1ensuresthatthestructural integrity ofthereactorcoolantpumpflywheels willbemaintained atanacceptable levelthroughout thelifeoftheplant.Justification forProosedTechnical Secification ChanesTheproposedT/Samendment requesttoreducethefrequency andscopeofsurveillance oftheRCPflywheels isjustified forseveralreasons.Thischangeisconsistent withMr.Sheron's(Director DivisionofEngineering, OfficeofNuclearReactorRegulation) letterentitled"Acceptance forReferencing ofTopicalReportWCAP-14535,'TopicalReportonReactorCoolantPumpFlywheelInspection Elimination' andrelatedattachments.
Based on the above conclusions, inspections of RCP flywheels with a 10-year frequency and modified scope are justified.
Pertherequirement ofthisletter,wehaveconfirmed thattheRCPflywheels inplaceatCookNuclearPlantarecomposedofSA533Bmaterial.
5.0 NO SIGNIFICANT HAZARDS CONSIDERATION We have evaluated the proposed T/S changes and have determined they'o not represent a significant hazards consideration based on the criteria established in 10 CFR 50.92(c).Operation of Cook Nuclear Plant in accordance with the proposed amendment will not: 1.Involve a si nificant increase in the robabilit or conse ence of an accident reviousl evaluated This change will reduce tne frequency and scope of the surveillance testing on the reactor coolant pump flywheels.
ThoughWestinghouse ElectricCorporation reportWCAP-14535, entitled"TopicalReportonReactorCoolantPumpFlywheelInspection Elimination",
Operating power plants have been inspecting their flywheels for over 20 years with no flaws identified which affect flywheel integrity.
seekselimination offlywheelinspections, weonly Attachment 1toAEP:NRC:1245 Page2seektoreducethefrequency oftheseinspections toonceevery10years.WCAP-14535-concludes thefollowing.
Past examinations performed to satisfy T/S 4.4.10.1 have not revealed any cracking of flywheel plates at Cook Nuclear Plant.Crack extension over a 60 year service life is negligible.
1.Flywheels arecarefully designedandmanufactured fromexcellent qualitysteel,whichhasahighfracturetoughness.
Structural reliability studies have shown that eliminating inspections after 10 years of plant life will not significantly change'he probability of failure.Most flaws which could lead to Attachment 1 to AEP:NRC:1245 Page 3 failure would be detected during preservice inspection or, at worst, early in plant life, and crack growth over plant life is negligible.
2.Flywheeloverspeed isthecriticalloading,butleakbeforebreakhaslimitedthemaximumspeedtolessthan1500rpm.6.7.Flywheelinspections havebeenperformed for2Cyears,withnoindications ofserviceinducedflaws.Flywheelintegrity evaluations showveryhighflawtolerance fortheflywheels.
As stated in the SER associated with WCAP-14535, assuming an initial crack of 10%of the distance from the keyway to the flywheel outer radius and a maximum fatigue crack growth, ASME margins would be maintained during the 10-year inspection period.Therefore, the change in test frequency will not endanger public health or safety.For these reasons, it is our belief the proposed changes do not involve a significant increase in the probability or consequences of a previously evaluated accident.Create the ossibilit of a new or different kind of accident from an accident reviousl evaluated.
Crackextension overa60yearservicelifeisnegligible.
The changes will not introduce any new modes of plant operation, nor will any physical changes to the plant be required.Thus, the changes will not create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated.
Structural reliability studieshaveshownthateliminating inspections after10yearsofplantlife willnotsignificantly changetheprobability offailure.Mostflawswhichcouldleadtofailurewouldbedetectedduringpreservice inspection oratworstearlyinplantlife,andcrackgrowthoverplantlifeisnegligible.
3.Involve a si nificant reduction in a mar in of aafet This change will reduce the frequency and scope of the surveillance testing on the reactor coolant pump flywheels.
AsstatedintheSERassociated withWCAP-14535, assuminganinitialcrackof10%ofthedistancefromthekeywaytotheflywheelouterradiusandamaximumfatiguecrackgrowth,ASMEmarginswouldbemaintained duringthe10-yearinspection period.Inspections resultinmanremexposureandthepotential forflywheeldamageduringdisassembly andreassembly.
Operating power plants have been inspecting their flywheels for over 20 years with no flaws identified which affect flywheel integrity.
Basedontheaboveconclusions, inspections ofRCPflywheels witha10-yearfrequency andmodifiedscopearejustified.
Past examinations performed to satisfy T/S 4.4.10.1 have not revealed any cracking of flywheel plates at Cook Nuclear Plant.Crack extension over a 60 year service life is negligible.
 
Structural reliability studies have shown that eliminating inspections after 10 years of plant life will not significantly change the probability of failure.Most flaws which could lead to failure would be detected during preservice irepection or at w'orst early in plant life, and crack gr.~th over plant life is negligible.
==5.0 NOSIGNIFICANT==
As stated in the SER associated with WCAP-, 14535, assuming an initial crack of 10%of the distance f'rom the keyway to the flywheel outer radius and a maximum fatigue crack giowth, ASME margins would be maintained during the 10-year inspection period.For these reasons, it is our belief the proposed changes do not involve a significant reduction in a margin of safety.6.0 PENDING T S PROPOSALS IMPACTING THIS SUBMITTAL There are no other T/S proposals under review that impact this submittal~
HAZARDSCONSIDERATION Wehaveevaluated theproposedT/Schangesandhavedetermined they'onotrepresent asignificant hazardsconsideration basedonthecriteriaestablished in10CFR50.92(c).Operation ofCookNuclearPlantinaccordance withtheproposedamendment willnot:1.Involveasinificantincreaseintherobabilit orconseenceofanaccidentreviouslevaluated Thischangewillreducetnefrequency andscopeofthesurveillance testingonthereactorcoolantpumpflywheels.
Operating powerplantshavebeeninspecting theirflywheels forover20yearswithnoflawsidentified whichaffectflywheelintegrity.
Pastexaminations performed tosatisfyT/S4.4.10.1havenotrevealedanycrackingofflywheelplatesatCookNuclearPlant.Crackextension overa60yearservicelifeisnegligible.
Structural reliability studieshaveshownthateliminating inspections after10yearsofplantlifewillnotsignificantly change'he probability offailure.Mostflawswhichcouldleadto Attachment 1toAEP:NRC:1245 Page3failurewouldbedetectedduringpreservice inspection or,atworst,earlyinplantlife,andcrackgrowthoverplantlifeisnegligible.
AsstatedintheSERassociated withWCAP-14535, assuminganinitialcrackof10%ofthedistancefromthekeywaytotheflywheelouterradiusandamaximumfatiguecrackgrowth,ASMEmarginswouldbemaintained duringthe10-yearinspection period.Therefore, thechangeintestfrequency willnotendangerpublichealthorsafety.Forthesereasons,itisourbelieftheproposedchangesdonotinvolveasignificant increaseintheprobability orconsequences ofapreviously evaluated accident.
Createtheossibilit ofanewordifferent kindofaccidentfromanaccidentreviouslevaluated.
Thechangeswillnotintroduce anynewmodesofplantoperation, norwillanyphysicalchangestotheplantberequired.
Thus,thechangeswillnotcreatethepossibility ofanewordifferent kindofaccidentfromanyaccidentpreviously analyzedorevaluated.
3.Involveasinificantreduction inamarinofaafetThischangewillreducethefrequency andscopeofthesurveillance testingonthereactorcoolantpumpflywheels.
Operating powerplantshavebeeninspecting theirflywheels forover20yearswithnoflawsidentified whichaffectflywheelintegrity.
Pastexaminations performed tosatisfyT/S4.4.10.1havenotrevealedanycrackingofflywheelplatesatCookNuclearPlant.Crackextension overa60yearservicelifeisnegligible.
Structural reliability studieshaveshownthateliminating inspections after10yearsofplantlifewillnotsignificantly changetheprobability offailure.Mostflawswhichcouldleadtofailurewouldbedetectedduringpreservice irepection oratw'orstearlyinplantlife,andcrackgr.~thoverplantlifeisnegligible.
AsstatedintheSERassociated withWCAP-,14535,assuminganinitialcrackof10%ofthedistancef'romthekeywaytotheflywheelouterradiusandamaximumfatiguecrackgiowth,ASMEmarginswouldbemaintained duringthe10-yearinspection period.Forthesereasons,itisourbelieftheproposedchangesdonotinvolveasignificant reduction inamarginofsafety.6.0PENDINGTSPROPOSALS IMPACTING THISSUBMITTAL TherearenootherT/Sproposals underreviewthatimpactthissubmittal~
.}}
.}}

Revision as of 06:54, 6 July 2018

Application for Amends to Licenses DPR-58 & DPR-74, Requesting Rev of Reactor Coolant Pump Flywheel Insp Frequency
ML17333A712
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/20/1996
From: FITZPATRICK E
AMERICAN ELECTRIC POWER CO., INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17333A714 List:
References
AEP:NRC:1245, NUDOCS 9612270111
Download: ML17333A712 (8)


Text

CATEGORY 1 REGULATOROINFORMATZON DISTRIBUTION TEM (RIDE)ACCESSION NBR:9612270111 DOC.DATE: 96/12/20 NOTARIZED:

YES FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.E American Electric Power Co., Inc.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses DPR-58!'PR-74, requesting rev of reactor coolant pump flywheel insp frequency.

DISTRIBUTION CODE: AOOZD COPIES RECEIVED:LTR 1 ENCL i SIZE: 4I 4 TITLE: OR Submittal:

General Distribution NOTES: DOCKET 05000315 05000316 E RECIPIENT ID CODE/NAME PD3-3 LA HICKMAN,J INTERNA:M LE CENTE 0.R DE EMCB 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/HDS2 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 0 1 1 D U N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL.'12 Indiana Michigan Power Company 500 Circle Drive Buchanan, Ml 491071395 INQMNA NICNESAN PQWM December 20, 1996 Docket No: 50-315 50-316 AEP:NRC:1245 10 CFR 50.90 U.S.Nuclear Regulatory Commission Document Control Desk Washington, D.C.20555 Gentlemen:

Donald C.Cook Nuclear Plant Units 1 and 2 LICENSE NOS.DPR-58 AND DPR"74 PROPOSED LICENSE AND TECHNICAL SPECIFICATION CHANGES OF REACTOR COOLANT PUMP FLYWHEEL INSPECTION FREQUENCY This letter and its attachments constitute an application for amendment of the technical specifications (T/S)for Cook Nuclear Plant units 1 and 2.Changes are proposed to reduce the frequency and scope of reactor coolant pump flywheel inspections consistent with your staff's evaluation of WCAP-14535,"Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination." A description of the proposed changes and an analysis concerning significant hazards consideration pursuant to 10 CFR 50.92 is contained in attachment 1.Attachment 2 contains the existing T/S pages marked to reflect the proposed changes.Attachment

.3 contains the proposed, revised T/S pages.We believe the proposed T/S changes will not result in a significant change in the types of effluents or a significant increase in the amount of effluent that might be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee~

.In compliance 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.Sincerely, SWORN TO AND SUBSCRIBED BEFORE ME I THIS~O DAY OF~~Mt 1996 E.E.Fit patrick 96 O O3 Vice President Attachments Notary Public My Commission Expires: JAN WATSON NOTARY PUBUC, BERRIEN COUNTY, MI I MY COMMISSION EXPIRES FEB 10 1999'Pbi2270iii 9hi220 PDR ADQCK 050003l5 P PDR J 1';C.1W t q'a e 4~I a ,<<W*<<i~u~"" C U.S.Nuclear Regulatory Commission Page 2 AEP: NRC: 1245 cc: A.A.Blind A.B.Beach MDEQ" DW Ec RPD NRC Resident Inspector J.R.Padgett ATTACHMENT 1 TO AEP:NRC:124S 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS Attachment 1 to AEP:NRC:1245 Page 1 1.0 SECTION TO BE CHANGED 1.Unit 1 technical specification (T/S)4.4.10.1 2.Unit 2 T/S 4.4.10.1 2.0 EXTENT OF CHANGES 1.We are proposing to change unit 1 T/S 4.4.10.1 to require reactor coolant pump (RCP)flywheel inspections once every 10 years in the manner described below.We are proposing to change unit 2 T/S 4.4.10.1 to require RCP flywheel inspections once every 10 years in the manner described below.3.0 CHANGES RE UESTED We are proposing to make the following change to the unit 1 and unit 2 T/Ss.Currently T/S section 4.4.10.1 requires that each reactor coolant pump flywheel be inspected per the recommendations of regulatory position C.4.b of Regulatory Guide (RG)1.14, Revision 1, August 1975.The regulatory position of RG 1.14 concerning ISI calls for an in-place ultrasonic volumetric examination of the areas of higher stress concentration at the bore and keyway at approximately 3-year intervals and a surface examination of all exposed surfaces and complete ultrasonic volumetric examination at approximately 10-year intervals.

The proposed T/S requires that either a qualified in-place UT examination over the volume from the inner bore of the flywheel to the circle of one-half the outer radius or a surface examination (MT and/or PT)of exposed surfaces defined by the volume of the disassembled flywheels be conducted once every 10 years.4.0 DISCUSSION Technical S ecification 4.4.10.1 Bases T/S 4.4.10.1 ensures that the structural integrity of the reactor coolant pump flywheels will be maintained at an acceptable level throughout the life of the plant.Justification for Pro osed Technical S ecification Chan es The proposed T/S amendment request to reduce the frequency and scope of surveillance of the RCP flywheels is justified for several reasons.This change is consistent with Mr.Sheron's (Director Division of Engineering, Office of Nuclear Reactor Regulation) letter entitled"Acceptance for Referencing of Topical Report WCAP-14535,'Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination' and related attachments.

Per the requirement of this letter, we have confirmed that the RCP flywheels in place at Cook Nuclear Plant are composed of SA 533 B material.Though Westinghouse Electric Corporation report WCAP-14535, entitled"Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination", seeks elimination of flywheel inspections, we only Attachment 1 to AEP:NRC:1245 Page 2 seek to reduce the frequency of these inspections to once every 10 years.WCAP-14535-concludes the following.

1.Flywheels are carefully designed and manufactured from excellent quality steel, which has a high fracture toughness.

2.Flywheel overspeed is the critical loading, but leak before break has limited the maximum speed to less than 1500 rpm.6.7.Flywheel inspections have been performed for 2C years, with no indications of service induced flaws.Flywheel integrity evaluations show very high flaw tolerance for the flywheels.

Crack extension over a 60 year service life is negligible.

Structural reliability studies have shown that eliminating inspections after 10 years of plantlife will not significantly change the probability of failure.Most flaws which could lead to failure would be detected during preservice inspection or at worst early in plant life, and crack growth over plant life is negligible.

As stated in the SER associated with WCAP-14535, assuming an initial crack of 10%of the distance from the keyway to the flywheel outer radius and a maximum fatigue crack growth, ASME margins would be maintained during the 10-year inspection period.Inspections result in man rem exposure and the potential for flywheel damage during disassembly and reassembly.

Based on the above conclusions, inspections of RCP flywheels with a 10-year frequency and modified scope are justified.

5.0 NO SIGNIFICANT HAZARDS CONSIDERATION We have evaluated the proposed T/S changes and have determined they'o not represent a significant hazards consideration based on the criteria established in 10 CFR 50.92(c).Operation of Cook Nuclear Plant in accordance with the proposed amendment will not: 1.Involve a si nificant increase in the robabilit or conse ence of an accident reviousl evaluated This change will reduce tne frequency and scope of the surveillance testing on the reactor coolant pump flywheels.

Operating power plants have been inspecting their flywheels for over 20 years with no flaws identified which affect flywheel integrity.

Past examinations performed to satisfy T/S 4.4.10.1 have not revealed any cracking of flywheel plates at Cook Nuclear Plant.Crack extension over a 60 year service life is negligible.

Structural reliability studies have shown that eliminating inspections after 10 years of plant life will not significantly change'he probability of failure.Most flaws which could lead to Attachment 1 to AEP:NRC:1245 Page 3 failure would be detected during preservice inspection or, at worst, early in plant life, and crack growth over plant life is negligible.

As stated in the SER associated with WCAP-14535, assuming an initial crack of 10%of the distance from the keyway to the flywheel outer radius and a maximum fatigue crack growth, ASME margins would be maintained during the 10-year inspection period.Therefore, the change in test frequency will not endanger public health or safety.For these reasons, it is our belief the proposed changes do not involve a significant increase in the probability or consequences of a previously evaluated accident.Create the ossibilit of a new or different kind of accident from an accident reviousl evaluated.

The changes will not introduce any new modes of plant operation, nor will any physical changes to the plant be required.Thus, the changes will not create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated.

3.Involve a si nificant reduction in a mar in of aafet This change will reduce the frequency and scope of the surveillance testing on the reactor coolant pump flywheels.

Operating power plants have been inspecting their flywheels for over 20 years with no flaws identified which affect flywheel integrity.

Past examinations performed to satisfy T/S 4.4.10.1 have not revealed any cracking of flywheel plates at Cook Nuclear Plant.Crack extension over a 60 year service life is negligible.

Structural reliability studies have shown that eliminating inspections after 10 years of plant life will not significantly change the probability of failure.Most flaws which could lead to failure would be detected during preservice irepection or at w'orst early in plant life, and crack gr.~th over plant life is negligible.

As stated in the SER associated with WCAP-, 14535, assuming an initial crack of 10%of the distance f'rom the keyway to the flywheel outer radius and a maximum fatigue crack giowth, ASME margins would be maintained during the 10-year inspection period.For these reasons, it is our belief the proposed changes do not involve a significant reduction in a margin of safety.6.0 PENDING T S PROPOSALS IMPACTING THIS SUBMITTAL There are no other T/S proposals under review that impact this submittal~

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