ML17325B183

Application for Amends to Licenses DPR-58 & DPR-74, Clarifying Response Time Testing Requirements for Power Range Neutron Flux Reactor Trip

ML17325B183
Person / Time
Site:	Cook
Issue date:	03/29/1989
From:	ALEXICH M P INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	MURLEY T E NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17325B184	List: ML17325B183 ML17325B185
References
AEP:NRC:1078, NUDOCS 8904040229
Download: ML17325B183 (9)

Text

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SUBJECT:

Application.

for amends to Licenses'PR-58

&DPR-74,to clarify response time testing requirements for PRNFRT.DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: TITLE: OR Submittal:

General Distribution NOTES: COPIES LTTR ENCL 1 1 RECIPIENT ID CODE/NAME PD3-1 PD COPIES LTTR ENCL 1 1 5 5 RECIPIENT ID CODE/NAME PD3-1 LA STANG,J 1 1 1 1 1 1 1 1 1 0 1 1 INTERNAL: ARM/DAF/LFMB NRR/DEST/CEB 8H NRR/DEST/ICSB NRR/DEST/RSB 8E-ABSTRACT RElFI E'1 1 0 1 1 1.1 1 1 1 1 1 1 NRR/DEST/ADS 7E NRR/DEST/ESB 8D NRR/DEST/MTB 9H NRR/DOEA/TSB 11 OGC/HDS1 RES/DSIR/EIB ACCESSION NBR:8904040229 DOC.DATE: 89/03/29 NOTARIZED:

NO FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana&50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana&AUTH.NAME.AUTHOR AFFILIATION ALEXICH,M.P.

Indiana Michigan Power Co.RECIP.NAME

'ECIPIENT AFFILIATION MURLEY,T.E.

Document Control Branch (Document Control Desk)EXTERNAL: LPDR NSIC 1 1 1 1 NRC PDR 1 1 NAZE K)ALL"RIDS" RECIPIENIS'LEASE HELP US K)REDUCE WASTE!COMI'ACZ'IHE DOCUMENT CONIBDL DESK, RDCM Pl-37 (EXT.20079)KO ELIMINATE YOUR NME FRY DISTRIBUTION LISTS FOR DOCUHENZS YOU DON'T NEED!S TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20 indiana Michigan Power Company P.O.Box 16631 Coiumbus, OH 43216 ItlAIEMANA MCHE6'AN PWE5k AEP:NRC:1078 Donald C.Cook Nuclear Plant Units 1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 CLARIFICATION OF RESPONSE TIME TESTING REQUIREMENTS FOR POWER RANGE NEUTRON FLUX REACTOR TRIP U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20555 Attn: T.E.Murley 1 March 29, 1989

Dear Dr.Murley:

This letter constitutes an application for amendment to the Technical Specifications (T/Ss)for the Donald C.Cook Nuclear Plant.Units 1 and 2.Specifically we are proposing to clarify the response time testing requirements for the power range neutron flux reactor trip.A detailed description of the change, our reasons for requesting the change, and our analyses concerning significant hazards are contained in Attachment 1.Attachment 2 includes the proposed revised T/S pages.We believe that the proposed changes will not result in (1)a significant change in the types of effluents or a significant increase in the amounts 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 will be reviewed by the Nuclear Safety and Design Review Committee at their next regularly scheduled meeting.In compliance with the requirements of 10 CFR 50.91(b)(1), copies of this letter and its attachments have been transmitted to Mr.R.C.Callen of the Michigan Public Service Commission and Mr.George Bruchmann of the Michigan Department of Public Health.S904040229 S90329 PDR ADOCK 05000315 P PDC oor Dr.T.E.Murley-2-AEP'NRC:1078 This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Sincerely, M.P.Al ich Vice President ldp Attachments cc: D.H.Williams, Jr.W.G~Smith, Jr.-Bridgman R.C.Callen G.Charnoff A.B.Davis NRC Resident Inspector-Bridgman G.Bruchmann ATTACHMENT 1 TO AEP:NRC 1078 REASONS AND 10 CFR 50.92 ANALYSES FOR CHANGES TO THE DONALD C.COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS Attachment 1 to AEP:NRC:1078 Page 1 Descri tion of Chan e This letter proposes to clarify the requirements of Table 3.3-2,"Reactor Trip System Instrumentation Response Times," by indicating that the requirements of Functional Unit 2 apply to both the high and low power range neutron flux (PRNF)reactor trip setpoints.

Back round and Reasons for Chan e During a review of our reactor trip system instrumentation time response testing procedures, it was observed that the time response test procedure for the nuclear instrumentation system PRNF reactor trip only included the high setpoint trip.Since credit was taken for the low setpoint trip in the safety analysis for both Units 1 and 2, the low setpoint should have been time response tested.It is believed that the lack of specific detail in the T/Ss regarding the separate setpoints was a contributing factor to the lack of testing, and we are therefore submitting the proposed changes of this letter to ensure that sufficient detail is included in the T/Ss for the PRNF reactor trip.Justification for Chan e These changes are considered to be administrative in nature and intended to clarify the response time testing requirements for the PRNF reactor trip.No operability or surveillance requirements will be reduced as a result of this change.Anal sis of Si nificant Hazards Per 10 CFR 50.92, a proposed amendment will not involve significant hazards consideration if the proposed amendment does not: (1)involve a significant increase in the probability or consequences of a previously evaluated accident, (2)create the possibility of a new or different kind of accident from any previously evaluated, or (3)involve a significant reduction in a margin of safety.Criterion 1 This change is intended to clarify the existing T/S requirements for the PRNF reactor trip, No operability or surveillance requirements have been reduced.We therefore believe the change does not involve a significant increase in the probability or consequences of an accident previously analyzed or a significant reduction in a margin of safety.

Attachment 1 to AEP:NRC:1078 Page 2 Criterion 2 The change does not involve physical modifications to the plant or changes in plant operation.

The change therefore should not create the possibility of a new or different kind of accident from any previously analyzed or evaluated.

Criterion 3 See Criterion 1 above.Lastly, we note that the Commission 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 first of these examples refers to changes which are purely administrative in nature: for example, changes to achieve consistency throughout the T/Ss, correction of errors, or changes in nomenclature.

The proposed change only clarifies the present T/S.We are not proposing to reduce any present requirements.

For these reasons, we believe that the example cited is applicable and that the proposed change should not involve significant hazards consideration.

TABLE 3.3-2 REACTOR TRIP SYSTEM INSTRUMENTATION RESPONSE TIMES FUNCTIONAL UNIT 1.Manual Reactor Trip RESPONSE TIME NOT APPLICABLE 2.Power Range, Neutron Flux (High and Low Setpoint)Less than or equal to 0.5 seconds 3.Power Range, Neutron Flux, High Positive Rate NOT APPLICABLE 4.Power Range, Neutron Flux, High Negative Rate Less than or equal to 0.5 seconds*5.Intermediate Range, Neutron Flux NOT APPLICABLE 6.Source Range, Neutron Flux 7.Overtemperature delta T NOT APPLICABLE Less than or equal to 6.0 seconds 8.Overpower delta T 9.Pressurizer Pressure--Low NOT APPLICABLE Less than or equal to 1.0 seconds 10.Pressurizer Pressure--High Less than or equal to 1.0 seconds 11.Pressurizer Water Level--High NOT APPLICABLE

• Neutron detectors are exempt from response time testing.Response time of the neutron flux signal portion of the channel shall be measured from detector output or input of first electronic component in channel.COOK NUCLEAR PLANT-UNIT 2 3/4 3-9 AMENDMENT NO.

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