ML17332A219

Application for Amends to Licenses DPR-58 & DPR-74, Revising TS Section 3/4.6.1.2 Re Containment Leakage Requirements

ML17332A219
Person / Time
Site:	Cook
Issue date:	07/19/1994
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17332A220	List: ML17332A219 ML17332A221
References
AEP:NRC:1215, NUDOCS 9407250158
Download: ML17332A219 (12)

Text

VR.IC3R.I ACCELERATED CV 1 RIDS PROCESSING)

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REGULATORY. INFORMATXON DXSTRXBUTXON SYSTEM (RIDS)

ACCESSION NBR:9407250158 DOC.DATE: 94/07/19 NOTARIZED: YES DOCKET 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 AFFXLIATION FITZPATRICK,E. Xndiana Michigan Power Co. (formerly Indiana 6 Michigan Ele RECXP.NAME RECIPIENT AFFXL1ATION R Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses DPR-58 & DPR-74, revising TS Section 3/4.6.1.2 re containment leakage requirements. 0 DISTRIBUTION CODE: A017D COPIES RECEIVED:LTR ( ENCL TITLE: OR Submittal: Append J Containment Leak Rate Testing g SIZE:

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 0 PD3-1 PD 1 1 HICKMAN,J 2 2 INTERNAL: OC CB 1 0 OGC/HDS2 1 1 EG F 01 1 1 RES/DE/SEB 1 1 ES/'DSTR SAXB 1 1 EXTERNAL: NRC PDR 1 1 NSIC D

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK. ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAME FROM

. DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED/

TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 9

Indiana Michigan Power Company P.O. Box 16631 Cofumbus, OH 43216 N

AEP:NRC:1215 Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos 50-315 and 50-316

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License Nos, DPR-58 and DPR-74 PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION SECTION 3/4.6.1.2 FOR CONTAINMENT LEAKAGE REQUIREMENTS U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Attn: W. T. Russell July 19, 1994

Dear Mr. Russell:

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 modify T/Ss 3/4.6.1.2 by removing the specific scheduling requirements for Types A, B, and C tests (overall integrated and local containment leakage rate) from the T/Ss and replacing these requirements with a requirement to perform Types A, B, and C testing in accordance with Appendix J to 10 CFR 50.

The proposed amendment will provide the flexibility needed in scheduling Type A tests in consideration of our 18-month fuel cycles. Further, the proposed amendment will allow us to more timely implement any performance based inspection criteria that may be added to Appendix J as an option to existing criteria. It is our understanding that such regulatory relief may be issued as a final rule change as early as 1995. The proposed changes to the scheduling requi.rements are consistent with the surveillance requirements for 10 CFR 50, Appendix J testing in NUREG-1431, "Standard Technical Specifications Westinghouse Plants."

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.

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W. T. Russell AEP:NRC:1215 The proposed amendment is a Cost Beneficial Licensing Action (CBLA). The proposed amendment can eliminate at least one Type A test per unit during each 10-year service period. Type A tests add at least two to three days to each outage. It also costs approximately $ 200,000 to perform a Type A test. The lifetime cost savings associated with this CBLA is approximately $ 800,000 based on two remaining 10-year service periods for each unit.

Another option would be to request an exemption to Appendix J requirements ever'y time this situation would occur. Such exemptions have been granted to other utilities in the past, however, approval of this proposed amendment would preclude additional staff review activities in the future for numerous exemption requests.

We believe 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.

These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Commi.ttee.

In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to t'e Michigan Department of Public Health.

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

Indiana Michigan Power requests NRC approval of the proposed amendment by August 1995, so that an additional exemption request would not have to be filed for Cook Nuclear Plant Unit 2. Based on the prescriptive T/S surveillance requirements that currently

'exist, the exemption request would have to be filed to keep from performing a Type A test in Unit 2 for each of two subsequent refueling outages, the first of which is tentatively scheduled to begin in February 1996.

Sincerely, O'E'D E. Fitz atrick Vice President

V. T. Russell AEP:NRC:1215 sah Attachments CC: A. A. Blind G. Charnoff J. B. Martin - Region III NFEM Section Chief NRC Resident Inspector 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 PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION SECTION 3/4.6.1.2 FOR CONTAINMENT LEAKAGE REQUIREMENTS and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

Subscribed and sworn to before me this ~~

day of , 19~~.

NOTARY PUBLIC RITA D. HILL NOTARY PUBLIC. STATE OF OHIO

Q /I ATTACHMENT 1 TO AEP:NRC:1215 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:1215 Page 1 DESCRIPTION OF CHANGES The proposed amendment to Technical Specifications (T/Ss) 3/4.6.1.2 makes the following specific changes to the Cook Nuclear Plant Units 1 and 2 T/Ss A. Revises Surveillance Requirement 4 '.1.2.a to remove the specific requirement that the Type A tests be performed at 40 a 10 month intervals with the third test of each set conducted during the shutdown for the 10-year plant inservice inspection and replace it with the following:

"Types A, B, and C (Overall Integrated and Local Combined Leakage Rate) testing shall be conducted in accordance with the requirements specified in Appendix J to 10 CFR 50, as modified by approved exemptions."

B. The modified statement proposed above incorporates Surveillance Requirement 4.6.1.2.d for Types B and C testing into Surveillance Requirement 4.6.1.2.a. These Types B and C testing requirements are also specified in Appendix J to 10 CFR 50. Therefore, it is not necessary to repeat these requirements in the T/Ss given the above suggested change.

C. Deletes Surveillance Requirements 4.6.1.2.b, 4.6.1.2.c, and 4.6.1.2.f. These testing requirements are also specified in Appendix J to 10 CFR 50. Therefore, it is not necessary to repeat these requirements in the T/Ss given the above suggested change.

D. The Unit 1 T/Ss adds a surveillance requirement to state that, "The provisions of Specification 4.0.2 are not applicable."

This is a requirement that exists in the Unit 2 T/Ss as Surveillance Requirement 4.6.1.2.g and is consistent with the direction provided in Appendix J to 10 CFR 50. It is being added to the Unit 1 T/Ss for consistency.

E. Renumbers the remaining surveillance requirements for continuity. Due to the amount of verbiage being deleted, Page 3/4 6-3 of both Units 1 and 2 T/Ss will be left blank. These are administrative changes.

II. JUSTIFICATION FOR CHANGES The Type A required test schedule provides only a 20-month window for scheduling Type A tests. This requirement is not appropriate for a facility like Cook Nuclear Plant which uses an 18-month fuel cycle. An 18-month fuel cycle does not provide sufficient flexibility for three tests within a ten year service period when limited by the stipulation that the tests be performed at 40 ~ 10 to AEP:NRC:1215 Page 2 month intervals. The initial schedule was based on 12-month fuel cycles; however, 18-month fuel cycles are used more widely throughout the industry and also at Cook Nuclear Plant.

Experience at other units has demonstrated that the current T/Ss test interval is too prescriptive. At the North Anna Power Station, which uses 18-month cycles, both units had to submit requests for a one time T/Ss exemption request, to deviate from the T/Ss which specified a Type A test schedule, to allow the third test to coincide with the 10-year inservice inspection period. Arizona Public Service Company also submitted a similar amendment request on December 2, 1993, to reword their T/Ss as proposed herein. This submittal was subsequently approved by the NRC on April 6, 1994, for the Palo Verde Nuclear Generating Station Units 1, 2, and 3. The need for scheduling flexibility for Type A tests was also incorporated as part of the T/Ss Improvement Program and, as a result, NUREG 1431, "Standard Technical Specifications Westinghouse Plants" only references Appendix J to 10 CFR 50 requirements for Type A tests. We are also applying this same reasoning in this request for Types B and C testing requirements to only specify reference to Appendix J of 10 CFR 50 for scheduling requirements.

The 24 month test interval is a requirement of Appendix J to 10 CFR 50.

The Cook Nuclear Plant T/Ss currently require that a set of three Type A tests be performed specifically at 40 a 10 month intervals during each 10-year service period, with the third test of each set performed during the shutdown for the 10-year plant inservice inspection. To meet these requirements, a plant operating on an 18-month fuel cycle must perform a Type A test every other outage.

The surveillance interval is no greater than 24 months for Types B and C tests, which is the same as prescribed in Appendix J to 10 CFR

50. Appendix J to 10 CFR 50 requires that a Type A test of the containment be performed periodically. These tests are required to be scheduled as a set of three tests, to be performed at approximately equal intervals, during each 10-year service period, with the third set to coincide with the shutdown for the 10-year plant inservice inspection. While the Cook Nuclear Plant T/Ss essentially duplicate the requirements of Appendix J to 10 CFR 50, the T/Ss contain the additional requirement that Type A testing be performed at 40 a 10 month intervals. This additional requirement is too restrictive for units with 18-month fuel cycles, as indicated above, and oftentimes requires submittal of an exemption request to exceed the 40 a 10 month limit for the third test. Therefore, we propose to revise the T/Ss for Cook Nuclear Plant Units 1 and 2 to delete the prescriptive testing and scheduling requirements for Types A, B, and C testing and instead reference that Types A, B, and to AEP:NRC:1215 Page 3 C testing will be performed in accordance with Appendix J to 10 CFR 50. This is accomplished by modifying the prescriptive wording in T/Ss 4.6.1.2.a and 4.6.1.2.d and combining them into T/Ss 4.6.1.2.a, and deleting T/Ss 4.6.1.2.b, 4.6.1.2.c, and 4.6.1.2.f.

Unit 1 T/Ss do not have a requirement that exempt Types A, B, and C testing from the provisions of T/S 4.0.2. T/S 4.0.2 provides provisions to allow a maximum allowable surveillance interval extension of up to 25% of the specified surveillance interval. The requirements of Appendix J to 10 CFR 50 would be violated if this extension were used for Unit l. Unit 2 T/Ss have this requirement already incorporated. The requirement is being added to Unit 1 to provide consistency between the T/Ss of both units and alleviate the possibility of violating the requirements of Appendix J.

Approval of this proposed change would also reduce the number T/S amendment requests in the future, that would be required as a result of the anticipated improvements being considered for Appendix J to 10 CFR 50, and would give us the flexibility to implement any enhancements sooner. By only referencing Appendix J in the T/Ss, any changes to Appendix J would automatically be encompassed within the T/Ss.

III. 10 CFR 50 92 CRITERI 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,

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 This amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes to the T/Ss do not affect the assumptions, parameters, or results of any UFSAR accident analysis.

The proposed changes do not modify the response of the containment during a design basis accident. The proposed amendment does not add or modi.fy any existing equipment. The proposed Types A, B, and C testing schedules will be consistent with Appendix J to 10 CFR 50.

Based on these considerations, it is concluded that the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

to AEP:NRC;1215 Page 4 Criterion 2 The proposed changes do not involve physical changes to the plant or changes in plant operating configuration. The proposed changes only remove the restrictive schedular requirements for conducting Type A testing from the T/Ss and substitute the schedule specified in Appendix J to 10 CFR 50. For Types B and C testing the schedular requirements are removed from T/Ss because they are already speci. fied in Appendix J to 10 CFR 50. Thus, it is concluded that the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3 The margin for safety presently provided is not reduced by the proposed change in the schedular requirements for Type A tests.

Types B and C schedular requirements are not changed by removing them from T/Ss. Although the changes allow more flexibility in scheduling Type A tests, the proposed amendment continues to ensure reactor containment system reliability by periodic testing in full compliance with 10 CFR 50, Appendix J. Based on these considerations, it is concluded that the changes do not involve a significant reduction in a margin of safety.