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{{#Wiki_filter:CATEGORY11REGULATYINFORMATION DISTRIBUTIO SYSTEM(RIDS)DOCKET¹0500031505000316ACCESSION NBR:9809220081, DOC.DATE:
{{#Wiki_filter:CATEGORY 1 1 REGULAT Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)DOCKET¹05000315 05000316 ACCESSION NBR:9809220081, DOC.DATE: 98/09/14 NOTARIZED:
98/09/14NOTARIZED:
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.
YESFACIL:50-315 DonaldC.CookNuclearPowerPlant,Unit1,IndianaM50;316PonaldC.CookNuclearPowerPlant,Unit2,IndianaMAUTH.NAMEAUTHORAFFILIATION POWERS,R.P.
'Induna Michigan Power Co.(formerly Indiana&Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)
'IndunaMichiganPowerCo.(formerly Indiana&MichiganEleRECIP.NAME RECIPIENT AFFILIATION RecordsManagement Branch(Document ControlDesk)


==SUBJECT:==
==SUBJECT:==
Application foramendstolicensesDPR-588DPR-74,revising TSpage3/45-6.D1STRZBUT10N CODE:A'OOZDCORTESRECEZVED:LTR
Application for amends to licenses DPR-58 8 DPR-74,revising TS page 3/4 5-6.D1STRZBUT10N CODE: A'OOZD CORTES RECEZVED:LTR
)ENCLISZEE:P1TITLE:ORSubmittal:
)ENCL I SZEE: P 1 TITLE: OR Submittal:
GeneralDistribution NOTES:AT,ERECIPIENT IDCODE/NAME PD3-3LASTANG,JINTERNAILECENTER01NRR/DSSA/SPLB NUDOCS-ABSTRACT EXTERNAL:
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:
NOACCOPIESLTTRENCL111111111111RECIPIENT IDCODE/NAME PD3-3PDNRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS3NRCPDRCOPIESLTTRENCL1111111110110D'NOTETOALL"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 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:
PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION REMOVEDFROMDISTRZBUTION LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION, CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION 415-2083TOTALNUMBEROFCOPIESREQUIRED:
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.
LTTR13ENCL12 IC indianaMichigan~PowerCompany500CircleDriveBuchanan, Ml491071373 September 14,1998AEP:NRC:1274 10CFR50.92DocketNos.:50-31550-316U.S.NuclearRegulatory Commission ATTN:DocumentControlDeskMailStop0-Pl-17Washington, D.C.20555-0001 Gentlemen:
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
DONALDC.COOKNUCLEARPLANTUNITS1AND2TECHNICAL SPECIFICATION AMENDMENT SAFETYINJECTION PUMPRUNOUTFLOWLIMITSThisletteranditsattachments constitute anapplication foramendment tothetechnical specifications (T/Ss)forCookNuclearPlantunits1and2.Thisamendment willchangetherunoutlimitsforasafetyinjection pumpto675gpmunlessthepumpisspecifically testedtoahigherflowratenotexceeding 700gpm.Background information relevanttotheT/Schangeandouranalysesconcerning significant hazardsconsiderations arecontained inattachment 1tothisletter.Attachment 2containsthecurrentT/Spages,marked-up toreflecttheproposedchange.TheproposedrevisedT/Spagesarecontained inattachment 3.Thissubmittal proposesachangetoT/Spage3/45-6forbothunit1and2.Theproposedchangewillnotresultinasignificant changeinthetypesofeffluents orasignificant increaseintheamountsofanyeffluents thatmaybereleasedoffsiteorasignificant increaseinindividual orcumulative occupational radiation exposure.
~~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:
Theproposedchangehasbeenreviewedandapprovedbytheplantnuclearsafetyreviewcommittee andthenuclearsafetyanddesignreviewcommittee.
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)
Werequestthattheapprovedamendment beeffective thirtydaysfromissuance.
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.
980'7220081 9809'X4PDRADOCK05000815P'OR U.S~NuclearRegulatory Commission Page2AEP:NRC:1274 Inaccordance withtherequirements of10CFR50.91(b)(1),
However, additional recent review has concluded that a change to the T/S should have been initiated.
copiesofthisletteranditsattachments havebeentransmitted totheMichiganPublicServiceCommission andtheMichiganDepartment ofPublicHealth.R.P.PowersVicePresident SWORNTOANDSUBSCRIBED BEFOREME~l~san*iINDENotaryPubliMycommission expiresl2Z01/jmcAttachments c:J.A.Abramson, w/attachments J.L.Caldwell, w/attachments MDEQ-DW&RPD,w/attachments NRCResidentInspector, w/attachments J.R.Sampson,w/attachments sLC
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 1TOAEP:NRC:1274 SUPPORTING ANALYSESFORAMENDMENT TOTHETECHNICAL SPECIFICATIONS SAFETYINJECTION PUMPRUNOUTFLOWLIMITS Attachment 1toAEP:NRC:1274 Page1BackroundAmendment numbers84(6/24/85) and64(6/18/84),
respectively, totheunit1andunit2.technical specifications (T/Ss)incorporated achangetotheallowable safetyinjection (SI)pumprunoutlimitsinT/S4.5.2.h.Thechangeraisedthepermissible runoutflowofasingleSIpumpfrom650gpmto700gpm.Thepumprunoutflowchangeswerenecessitated byphysicalchangestotheSIpumpminiflowrecirculation lines.Thesephysicalchangesincreased miniflowcapacityfrom30gpmtoapproximately 60gpmanditwasanticipated thattheincreased miniflowwouldmakeitdifficult toachievealloftheSIpumpdesignflowobjectives withoutexceeding the650gpmrunoutlimitexistingatthattime.Thejustification forthechangefrom650to700gpmwasbasedonvendortesting(DresserIndustries) ofasingleCookNuclearPlantreplacement safetyinjection pumpandaspareelement.Thetestingestablished safepumpoperation uptoamaximumflowof700gpm.Weconfirmed thattheavailable netpositivesuctionheadtotheSIpumps,asinstalled attheplant,wasgreaterthanthatrequiredtosafelyachieve700gpmduringthevendortesting.Therefore, webelievedthistestingwasalsoapplicable tothethree(untested) installed pumps.In1991,wereceivedcorrespondence fromWestinghouse indicating thatthegenericrunoutlimitsforPacific2"JTCHpumpswas675gpmunlesseachspecificpumpwastestedtoahigherflow.Atourrequest,DresserreviewedthepumprunoutlimitsforCookNuclearPlant.Basedontheirreview,Dresserconcluded thefollowing:
1)forthespecificreplacement pumpandspareelementpreviously testedbythem,the700gpmrunoutlimitremainedapplicable (thisappliestotheunit2northpump);and2)forother(untested)
SIpumps,Dresser's positionwastoabidebythegeneralWestinghouse limitof675gpm(thisappliestobothunit1pumpsandtheunit2southpump).Theyindicated thatmanufacturing tolerances insandcastimpellers andmaterialchangesinthepumpcasing(ofthetestedreplacement pump)couldresultintestvariations thatlimitapplicability ofthetestingbetweenpumps.Dresseralsoindicated thatthegenericlimitof675gpmcouldbeincreased forthethreeuntestedpumps,withappropriate inplaceorvendortesting.ReviewofSIpumpflowbalancing dataindicated thatproperbalancing couldbeachievedwithoutexceeding 675gpmforthethreepumpsthathadnotbeenspecifically testedforhigherflows.Procedure 12EHP4030STP~208SIgU1&U2ECCSFLOWBALANCESAFETYINJECTlON SYSTEM",waschangedtoadministratively limitflowofthethreeuntestedpumpsto675gpm.Basedonprocedural controlsforlimitingrunoutflowofthethreeuntestedpumps,weconcluded in1992thattheintentofT/S4.5.2.hwasbeingmetandthatachangetotheT/Sswasnotnecessary.
However,additional recentreviewhasconcluded thatachangetotheT/Sshouldhavebeeninitiated.
Thissubmittal providesthenecessary changeandalsoclarifies thebasisforsettingtheSIpumprunoutlimits.Thebasesclarification describes whytheinjection lineupismoreconservative thanthesumprecirculation lineup(whentheRHRpumpsareproviding asuctionpressureboost)forpotential SIpumprunout.Thisisduetosplitting oftheSI


Attachment 1toAEP:NRC:1274Page2trainsduringcirculation, resulting inahighersystemresistance thanwitha-singleSIpumpinjecting toallfourreactorcoolantloops.DescritionofAmendment ReuestTechnical specification 4.5.2.h(SIsystemsinglepump)isbeingchangedtorequirethemaximumpermitted runoutflowrateforaSIpumpberestricted to675gpmunlessthepumpisindividually qualified toahigherflowrateofupto700gpm.Currently, T/S4.5.2.hrecognizes arunoutflowrateof700gpmforeachoftheSIpumps.Thebasisisbeingclarified todescribewhytheinjection lineupduringflowbalancing istheminimumresistance configuration forrunoutconsiderations.
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.
Justification forAmendment Theproposedamendment isnecessary tocorrectatechnical discrepancy intherunoutflowlimitforsafetyinjection pumpsthat,havenotbeenspecifically testedtothelimitcurrently allowedbyT/S4.5.2.h.BasisforNoSignificant HazardsDetermination Inaccordance with10CFR50.92,thisproposedamendment doesnotinvolveasignificant hazardconsideration ifitdoesnot:1)Involveasignificant increaseintheprobability orconsequences ofanaccidentpreviously evaluated.
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.
Theproposedreduction intheSIpumprunoutflowdoesnotincreasetheprobability ofoccurrence ofanypreviously evaluated accidentbecausetheSIpumpsarenotconsidered tobeaccidentinitiators.
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.
Inaddition, flowbalancing performed atCookNuclearPlanthasproventheabilitytodelivertheminimumT/Sflowof300gpmtoeachpairofcoldleginjection pointswithoutexceeding the675gpm(or700gpm)pumprunoutlimits.Therefore, theemergency corecoolingsystemperformance objectives of10CFR50.46arenotimpactedandthischangedoesnotinvolveasignificant increaseintheconsequences ofanaccidentpreviously evaluated.
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)Createthepossibility ofanewordifferent kindofaccidentfromanyaccidentpreviously evaluated.
2)Create the possibility of a new or different kind of accident from any accident previously evaluated.
Thisproposedchangeimposesagenericlimitonmaximumallowable flowforuntestedSIpumps.Nophysicalsystemchangesorchangesinoperating modesarebeingmadethatcouldintroduce newordifferent kindsofaccidents fromthosepreviously 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.
Asdiscussed in(1)above,theSIpumpsarenotconsidered accidentinitiators, andthisstatusisnotaffectedbythechangetotheSIpumprunoutlimits.
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.
Attachment 1toAEP:NRC:1274 Page33)Involveasignificant reduction inamarginofsafety.Thischangereflectsareducedmaximumsinglepumpflowtobeobservedduringflowbalancing oftheSIsystem.FlowbalancetestingatCookNuclearPlanthasdemonstrated theabilitytomeetSIflowrequirements whilemaintaining anadequatemargintotherevisedlowerrunoutlimitsbeingproposedbythissubmittal.
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.
BecausetheminimumrequiredSIflowdelivered tothecorehasnotbeenreducedbythischange,thechangedoesnotinvolveareduction inamarginofsafety.Basedonthepreceding, theevaluation concluded thattheproposedchangetotheSIpumprunoutlimitsdoesnotinvolveasignificant hazardsconsideration asdefinedin10CFR50.92.
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 2TOAEP:NRC:1274 CURRENTPAGESMARKED-UP TOSHOWPROPOSEDCHANGESTOTHEDONALDCDCOOKNUCLEARPLANTUNITS1AND2TECHNICAL SPECIFICATION SAFETYINJECTION PUMPRUNOUTFLOWLIMITS UNITNO.1}}
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}}

Revision as of 07:07, 6 July 2018

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 P
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)DOCKET¹05000315 05000316 ACCESSION NBR:9809220081, DOC.DATE: 98/09/14 NOTARIZED:

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.

'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.D1STRZBUT10N CODE: A'OOZD CORTES RECEZVED:LTR

)ENCL I SZEE: P 1 TITLE: OR Submittal:

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:

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:

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 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.

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.

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.

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.

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