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| Dr. T. E. Murley AEP:NRCt0980U This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached. | | Dr. T. E. Murley AEP:NRCt0980U This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached. |
| Sincerely, E. E. Fitz trick | | Sincerely, E. E. Fitz trick Vice President dr Attachments cc: A. A. Blind Bridgman G. Charnoff J. B. Martin >> Region III NFEM Section Chief NRC Resident Inspector Bridgman J. R. Padgett |
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| Vice President dr Attachments cc: A. A. Blind Bridgman G. Charnoff J. B. Martin >> Region III NFEM Section Chief NRC Resident Inspector Bridgman J. R. Padgett | |
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| STATE OF OHIO) | | STATE OF OHIO) |
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| ~ NOTARY PUBLIC. STAT OF OHIO AY COhihIISSION EXPIRE | | ~ NOTARY PUBLIC. STAT OF OHIO AY COhihIISSION EXPIRE |
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| ATTACHMENT 1 TO AEP:NRC:0980U 10 CFR 50.92 ANALYSZS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNZTS 1 AND 2 TECHNZCAL SPECZFZCATZONS | | ATTACHMENT 1 TO AEP:NRC:0980U 10 CFR 50.92 ANALYSZS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNZTS 1 AND 2 TECHNZCAL SPECZFZCATZONS to AEP:NRC:0980U Page 1 DESCRIPTION OF CHANGES We propose to delete from the technical specifications (T/S) T/S 5.9.1/Table 5.9-1 (Unit 1) and T/S 5.7.1/Table 5.7-1 (Unit 2), |
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| Attachment 1 to AEP:NRC:0980U Page 1 DESCRIPTION OF CHANGES We propose to delete from the technical specifications (T/S) T/S 5.9.1/Table 5.9-1 (Unit 1) and T/S 5.7.1/Table 5.7-1 (Unit 2),
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| entitled "Component Cyclic or Transient Limits." The limits of these T/S would be relocated to the UFSAR, and would be administratively controlled. Additionally, the Index Section is revised accordingly. | | entitled "Component Cyclic or Transient Limits." The limits of these T/S would be relocated to the UFSAR, and would be administratively controlled. Additionally, the Index Section is revised accordingly. |
| REASON FOR THE CHANGE The change achieves consistency with the new Standard T/S for Westinghouse Plants, published by the NRC as NUREG 1431 on September 28, 1992. The table contains cyclic and transient limits for the reactor coolant and secondary systems. For example, the table lists the number of heatup and cooldown cycles the reactor coolant system may undergo, as well as the number of hydrostatic pressure tests the reactor coolant system and secondary system may undergo. Although limits are provided in the table, there are no specific limiting conditions for operation or action statements provided. | | REASON FOR THE CHANGE The change achieves consistency with the new Standard T/S for Westinghouse Plants, published by the NRC as NUREG 1431 on September 28, 1992. The table contains cyclic and transient limits for the reactor coolant and secondary systems. For example, the table lists the number of heatup and cooldown cycles the reactor coolant system may undergo, as well as the number of hydrostatic pressure tests the reactor coolant system and secondary system may undergo. Although limits are provided in the table, there are no specific limiting conditions for operation or action statements provided. |
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| Criterion 2 The change only involves relocation of a table containing component cyclic and transient limits from the T/S to the UFSAR. No specific physical changes to the plant or changes in plant operation will result directly from this change. Any change in the limits contained in the current table will undergo a review against the requirements of 10 CFR 50.59 to ensure that the change does not create an unreviewed safety question. Thus, the change will not create the possibility of a new or different kind of accident from any accident previously evaluated. | | Criterion 2 The change only involves relocation of a table containing component cyclic and transient limits from the T/S to the UFSAR. No specific physical changes to the plant or changes in plant operation will result directly from this change. Any change in the limits contained in the current table will undergo a review against the requirements of 10 CFR 50.59 to ensure that the change does not create an unreviewed safety question. Thus, the change will not create the possibility of a new or different kind of accident from any accident previously evaluated. |
| Criterion 3 The proposed change is administrative in nature in that it transient simply limits relocates a table containing component cyclic and from the T/S to the UFSAR. Any change to the requirements of the table would have to be reviewed against the criteria of 10 CFR 50.59 to ensure the change does not create an unreviewed safety question. Additionally, it is noted that the change is consistent with the new Standard T/S, recently issued by the NRC as NUREG 1431. Based on these considerations, the proposed change does not involve a significant reduction in a margin of safety. | | Criterion 3 The proposed change is administrative in nature in that it transient simply limits relocates a table containing component cyclic and from the T/S to the UFSAR. Any change to the requirements of the table would have to be reviewed against the criteria of 10 CFR 50.59 to ensure the change does not create an unreviewed safety question. Additionally, it is noted that the change is consistent with the new Standard T/S, recently issued by the NRC as NUREG 1431. Based on these considerations, the proposed change does not involve a significant reduction in a margin of safety. |
| | | to AEP:NRC! 0980U Page 4 Lastly, we note that the NRC has provided guidance concerning the determination of significant hazards by providing certain examples (48 FR 14870) of amendments considered not likely to involve significant hazards consideration. The sixth of these examples refers to changes which may result in some increase to the probability or consecpences of a previously evaluated accident, but the results of which are within acceptable limits. As discussed above, the removal of the cyclic and transient limit table from the T/S is consistent with the new Standard T/S, issued by the NRC as NUREG 1431. Since the change has already been found acceptable by the NRC, we conclude that the example cited is applicable and that the change should not involve significant hazards consideration.}} |
| Attachment 1 to AEP:NRC! 0980U Page 4 Lastly, we note that the NRC has provided guidance concerning the determination of significant hazards by providing certain examples (48 FR 14870) of amendments considered not likely to involve significant hazards consideration. The sixth of these examples refers to changes which may result in some increase to the probability or consecpences of a previously evaluated accident, but the results of which are within acceptable limits. As discussed above, the removal of the cyclic and transient limit table from the T/S is consistent with the new Standard T/S, issued by the NRC as NUREG 1431. Since the change has already been found acceptable by the NRC, we conclude that the example cited is applicable and that the change should not involve significant hazards consideration.}}
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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
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Text
,'CCELERA. 0 DOCUMENT MST IUTION SYSTEM
~
. ~ REGUL. RY INFORMATION DISTRIBUT SYSTEM (RIDS)
ACCESSION NBR:9311190273 DOC!DATE: 93/11/12 NOTARIZED: YES DOCKET ¹ 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 FIYZPATRICK,E. Indiana Michigan Power Co. (formerly Indiana S Michigan Ele RECIP.NAME RECIPIENT AFFILIATION MURLEY,T.E. Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to licenses DPR-58 S DPR-74,deleting TS 5.9.1 6 Table 5.9-1,Unit 1 6 TS 5.7.1 & Table 5.7-1,Unit D 2 of TS entitled, "Component Cyclic or Transient Limits,"
per new STS published by NRC as NUREG-1431,dtd 920928.
DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution J ENCL / SIZE: 0 +
NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL D PD3-1 LA 1 1 PD3-1 PD 1 1 WETZEL,B 2 2 D INTERNAL: NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 0&/BBBGB . 1 0 OGC/HDS2 1 0 EG F LE 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE} CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-31 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 13
Indiana Michiga~~
Power Compan~
P.O. Box 16631 Columbus, OH 43216 AEP:NRC:0980U Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 TECHNICAL SPECIFICATION CHANGE REQUESTr DELETION OF COMPONENT CYCLIC OR TRANSIENT LIMIT TABLE U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Attn: T. E. Murley November 12, 1993
Dear Dr. Murley:
This letter and its attachments constitute an application for amendment to the Technical Specifications (T/S) for the Donald C.
Cook Nuclear Plant Units 1 and 2 in accordance with 10 CFR 50.90.
The proposed change deletes T/S 5.9.1 and Table 5.9-1 (Unit 1) and T/S 5.7.1 and Table 5.7-1 (Unit 2) of the T/S, entitled "Component Cyclic or Transient Limits." This change is consistent with the new Standard Technical Specifications for Westinghouse Plants, published by the NRC as NUREG 1431, dated September 28, 1992.
Attachment 1 provides a detailed description of the proposed change, the justification for the change, and our proposed 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 change. Attachment 3 contains the proposed, revised T/S pages.
We believe that the proposed change will not result in (1) a significant change in the types of effluents or a significant increase in the amount of any effluents that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.
The proposed change has been reviewed by the Plant Nuclear Safety Review Committee and by the Nuclear Safety and Design Review Committee.
In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to Mr. J. R. Padgett of the Michigan Public Service Commission and to the Michigan Department of Public Health.
93i1190273 931112 PDR 'ADOCK 05000315 P PDR
h 4
Dr. T. E. Murley AEP:NRCt0980U This letter is submitted pursuant to 10 CFR 50.30(b) and, as such, an oath statement is attached.
Sincerely, E. E. Fitz trick Vice President dr Attachments cc: A. A. Blind Bridgman G. Charnoff J. B. Martin >> Region III NFEM Section Chief NRC Resident Inspector Bridgman J. R. Padgett
STATE OF OHIO)
COUNTY OF FRANKLIN)
E. E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power Company, that he has read the foregoing Technical Specification Change Request: Deletion of Component Cyclic or Transient Limit Table and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to me before this day of NOTARY UBLIC
~ anA o. Htlt.
~ NOTARY PUBLIC. STAT OF OHIO AY COhihIISSION EXPIRE
ATTACHMENT 1 TO AEP:NRC:0980U 10 CFR 50.92 ANALYSZS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNZTS 1 AND 2 TECHNZCAL SPECZFZCATZONS to AEP:NRC:0980U Page 1 DESCRIPTION OF CHANGES We propose to delete from the technical specifications (T/S) T/S 5.9.1/Table 5.9-1 (Unit 1) and T/S 5.7.1/Table 5.7-1 (Unit 2),
entitled "Component Cyclic or Transient Limits." The limits of these T/S would be relocated to the UFSAR, and would be administratively controlled. Additionally, the Index Section is revised accordingly.
REASON FOR THE CHANGE The change achieves consistency with the new Standard T/S for Westinghouse Plants, published by the NRC as NUREG 1431 on September 28, 1992. The table contains cyclic and transient limits for the reactor coolant and secondary systems. For example, the table lists the number of heatup and cooldown cycles the reactor coolant system may undergo, as well as the number of hydrostatic pressure tests the reactor coolant system and secondary system may undergo. Although limits are provided in the table, there are no specific limiting conditions for operation or action statements provided.
NUREG 1431 was the result of a technical specification improvement program undertaken by the NRC and the nuclear industry. One of the results of the program was the streamlining of the T/S by removal of requirements that were better located elsewhere. The changes allowed the new T/S to be more clearly focused on those requirements necessary to support the safety analyses, versus requirements in vogue at the time of plant licensing. Four general criterion were used to determine if a recpirement from the former Standard T/S would remain in the new Standard T/S. These criterion involve:
1~ Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
2~ A process variable that is an initial condition of a design basis accident or transient analysis that either
'assumes the failure of or presents a challenge to the integrity of a fission product barrier.
3~ A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis 'accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
- 4. Equipment that probabilistic risk assessment or operating experience has shown to be important to public health and safety.
Attachment 1 to AEP:NRC:0980U Page 2 The T/S and table we are proposing to remove contains component cyclic and transient limits. The table is essentially a requirement for recordkeeping regarding the number of cycles or transients that have been experienced by the reactor coolant or secondary systems. Zn this sense, the requirements are administrative in nature, and clearly did not meet any of the criteria listed above. Thus, the table was not included in the new Standard T/S. Removal of the table from the T/S will streamline the document, and will help to achieve the appropriate focus of the document.
3~ JUSTIFICATION FOR THE CHANGE The change is consistent with the new Standard T/Sg as published in NUREG 1431. Zn this sense, the change has already been reviewed and found acceptable by the NRC. There are no Cook Nuclear Plant specific features that would make the change not applicable.
There is already a plant procedure that verifies that the requirements of the T/S table are implemented. The table currently in the T/S will be relocated to the UFSAR. A note will be added to the procedure to ensure that any changes to the component cyclic or transient limits undergo an unreviewed safety cpxestlon determination per the retirements of 10 CFR 50.59. Per 10 CFR 50.59, the change can only be made if the change does not:
increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report,
- 2. create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report, or 3~ reduce the margin of safety as defined in the basis for any T/S.
Any changes to the requirements of the present table would have to pass the stringent criteria of 10 CFR 50.59 in order to be implemented.
Attachment 1 to AEP:NRC:0980U Page 3 4~ 10 CFR 50.92 CRITERIA Per 10 CFR 50.92, a proposed amendment 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, 2~ create the possibility of a new or different kind of accident from any accident previously evaluated, or 3~ involve a significant reduction in a margin of safety.
Criterion 1 The proposed change is administrative in nature in that it simply relocates a table containing component cyclic and transient limits from the T/S to the UFSAR. Any change to the requirements of the table would have to be reviewed against the criteria of 10 CFR 50.59 to ensure the change does not create an unreviewed safety question. Additionally, it is noted that the change is consistent with the new Standard T/S, recently issued by the NRC as NUREG 1431. Based on these considerations, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2 The change only involves relocation of a table containing component cyclic and transient limits from the T/S to the UFSAR. No specific physical changes to the plant or changes in plant operation will result directly from this change. Any change in the limits contained in the current table will undergo a review against the requirements of 10 CFR 50.59 to ensure that the change does not create an unreviewed safety question. Thus, the change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3 The proposed change is administrative in nature in that it transient simply limits relocates a table containing component cyclic and from the T/S to the UFSAR. Any change to the requirements of the table would have to be reviewed against the criteria of 10 CFR 50.59 to ensure the change does not create an unreviewed safety question. Additionally, it is noted that the change is consistent with the new Standard T/S, recently issued by the NRC as NUREG 1431. Based on these considerations, the proposed change does not involve a significant reduction in a margin of safety.
to AEP:NRC! 0980U Page 4 Lastly, we note that the NRC has provided guidance concerning the determination of significant hazards by providing certain examples (48 FR 14870) of amendments considered not likely to involve significant hazards consideration. The sixth of these examples refers to changes which may result in some increase to the probability or consecpences of a previously evaluated accident, but the results of which are within acceptable limits. As discussed above, the removal of the cyclic and transient limit table from the T/S is consistent with the new Standard T/S, issued by the NRC as NUREG 1431. Since the change has already been found acceptable by the NRC, we conclude that the example cited is applicable and that the change should not involve significant hazards consideration.