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SUBJECT: Application for amends to Licenses PDR-58 6 DPR-74,modifyingTech Spec 3.3.2.1 Tables 3.3-3,3.3-4,3.3-5 6 4.3-2.

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ACCESSION NBR:8903220188 DOC.DATE: 89/03/14 NOTARIZED: NO . DOCKETFACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana 6 05000315

50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana & 05000316AUTH.NAME AUTHOR AFFILIATION

ALEXICH,M.P. Indiana Michigan Power Co. (formerly Indiana 6 Michigan EleRECIP.NAME RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)

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indiana MichiganPower CompanyP.O. Box 16631Columbus, OH 43216

AEP:NRC:103010 CFR 50.90

Donald C. Cook Nuclear Plant Units 1 and 2Docket Nos. 50-315 and 50-316License Nos. DPR-58 and DPR-74TECHNICAL SPECIFICATION CHANGE: SAFETY INJECTIONAND CONTAINMENT SPRAY MANUAL ACTUATION SIGNALS

U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555

Attn: T. E. Murley

March 14, 1989

Dear Dr. Murley:

This letter and its attachments constitute an application foramendment to the Technical Specifications (T/Ss) for the Donald C.Cook Nuclear Plant Units 1 and 2. Specifically, we are proposingto modify T/S 3.3.2.1 (Engineered Safety Feature Actuation SystemInstrumentation) Tables 3.3-3, 3.3-4, 3.3-5 and 4.3-2 so that theymore accurately reflect the design of the ESF manual actuationfunctions, and reference more appropriate surveillance and actionrequirements for manual actuations with respect to theWestinghouse Standard T/Ss. Attachment 1 to this letter containsthe reasons for the changes and our analyses concerningsignificant hazards consideration. Attachment 2 contains theproposed revised T/S pages.

We believe that the proposed changes will not result in (1) asignificant change in the types of effluents or a significantincrease in the amounts of any effluent that may be releasedoffsite, or (2) a significant increase in individual or cumulativeoccupational radiation exposure.

These proposed changes have been reviewed by the Plant NuclearSafety Review Committee and will be reviewed by the Nuclear Safetyand Design Review Committee at their next regularly scheduledmeeting.

In compliance with the requirements of 10 CFR 50.91(b)(1), copiesof this letter and its attachments have been transmitted toMr. R. C. Callen of the Michigan Public Service Connnission andMr. George Bruchmann of the Michigan Department of Public Health.

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Dr. T. E. Murley -2- AEP:NRC:1030

This document has been prepared following Corporate proceduresthat incorporate a reasonable set of controls to ensure itsaccuracy and completeness prior to signature by the undersigned.

Sincerely,

M. P. Ale chVice President

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Attachments

cc: D. H. Williams, Jr.W.'. Smith, Jr. - BridgmanR. C. CallenG. BruchmannG. CharnoffNRC Resident Inspector - BridgmanA. B. Davis - Region III

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ATTACHMENT 1 TO AEP:NRC:1030

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:1030 Page 1

The purpose of this submittal is to clarify and correct TechnicalSpecification (T/S) 3/4.3.2.1 (Engineered Safety FeaturesActuation System Instrumentation). Specifically, we are proposingto modify Tables 3.3-3, 3.3-4, and 4.3-2 to more accuratelyreflect the design of the ESF manual actuation channels asdelineated in T/S Table 3.3-5 and to more closely resemble thesurveillance requirements of the Standard T/Ss (STS). We are alsoproposing a modification to T/S Table 3.3-5 so that it moreaccurately reflects the design of the ESF manual actuationchannels. The specific problems and associated changes aredescribed below.

Chan e No. 1 Editorial : Misleadin Descri tion of Functions

T/S Tables 3.3-3, 3.3-4, and 4.3-2 describe the following specificmanual actuation channels:

Functional Unit

l.a Manual Safety injection (andassociated actuations)

2.a Manual

3.a.l Manual

3.b.l Manual

3.c.l Manual

Containment spray

Containment Phase "A" isolation

Containment Phase "B" isolation

Containment Purge and exhaustisolation

4.a Manual Steam line isolation

The way in which these six functional units noted above are listedin T/S Tables 3.3-3, 3.3-4, and 4.3-2 implies that there areseparate manual switches for each. However, due to one manualswitch actuating more than one function in certain cases, thereare effectively only four functional units. These four arediscernible by "!:i "ay in which they are currently listed in T/STable 3.3-5, which describes them as follows:

Initiatin Si nal . nd Function1. Manual

Descri tion

Safety injection (ECCS)Feedwater isolationReactor trip '(SI)

Attachment 1 to AEP:NRC:1030 Page 2

Ini,tiatin Si nal and Function

Containment isolation-Phase "A"Containment purge and exhaust

isolation

Auxiliary feedwater pumpsEssential service water systemContainment air recirculation

fan

Containment sprayContainment isolation-Phase "B"Containment purge and exhaust

isolation

Containment isolation-Phase "A"Containment purge and exhaust

isolation

Steam line isolation

In order to make the function descriptions consistent between T/Stables, we have created a Functional Unit 9 in Tables 3.3-3,3.3-4, and 4.3-2, which lists the manual actuation functionsconsistent with Table 3.3-5. (Note, however, that the manualstart of the containment air recirculation fans will be placedwith group b [containment spray and related functions] rather thangroup a. This is consistent with a proposed change to T/S Table3.3-5 described under "Change No. 5"). The information for thepresent functional units (l.a, 2.a, 3.a.l, 3.b.l, 3.c.l and 4.a)in Tables 3.3-3, 3.3-4, and 4.3-2 has been replaced with the words"See Functional Unit 9." This change is administrative in nature,intended only to make the T/S description of the manual functionsmore accurate.

Presently, T/S Table 3.3-3 Function 3 (Purge and Exhaust IsolationFunctions) has a footnote which states that the requirements areonly applicable during purge. The footnote is applied to'llthree parts of the function, i.e., manual, containmentradioactivity - hi~,h Train A and containment radioactivity - highTrain B. As deiini iced in Table 3.3-5, the manual circuitrypioviding purge an

1

Attachment 1 to AEP:NRC:1030 Page 3

Chan e No. 2 Editorial : Misleadin Descri tion of E ui ment inTable 3.3-3

There are inconsistencies in the T/S Table 3.3-3 descriptions ofthe number of channels which exist and the number of channelsrequired to trip for the manual initiations described above.These are described below.

a. Functional Unit l.a Safet In ection Manual Actuation

T/S Table 3.3-3 Functional Unit l.a indicates that thereare a total of two safety injection (SI) and relatedfunction manual actuation channels, with one of the twochannels required for an SI actuation. This functionalunit, which corresponds in the actual plant design toFunctional Unit l.a of T/S Table 3.3-5, does not make itclear that the above is true for each train of the

'unction. There actually are four switches for thisfunction, two redundant switches per train. Closingeither one of the two SI manual switches per train willinitiate that train of SI. To avoid confusion, we areproposing to describe these in our proposed FunctionalUnit 9.a for T/S Table 3.3-3 as follows:

Total No.of Channels

Channels ToTri

MinimumChannels 0 erable

2/train 1/train 2/train

b. Functional Unit 2.a Containment S ra Manual 3.a.lContainment Isolation Phase A Manual 3.b.lContainment Isolation Phase B Manual and 3.c.lContainment Isolation Pur e and Exhaust Manual

The above four functional units* correspond in theactual plant design to functions l.b (Containment Spray,Containment Isolation, Phase B; and Purge and ExhaustIsolation) and l.c (Containment Isolation, Phase A, andPurge .»~d Exhaust Isolation). of T/S Table 3.3-5. Eachof thea~ two function groups has one switch per train.Closin~,:he switch initiates only that train'sfunctions. However, T/S Table 3.3-3 describesfunctional unit 2.a (containment spray) and 3.b.l (Phase"B" isol.ition) as each having two channels, with bothchannels :equired to trip. To avoid confusion, we areproposin.;:o describe the manual channels in ourproposed :'nctional units 9.b and 9.c for T/S Table3.3-3 «

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Attachment 1 to AEP:NRC:1030 Page 4

Total No.of Channels

Channels~To Tri

MinimumChannels 0 erable

. 1/train 1/train 1/train

c. Functional Unit 4.a Steam Line Isolation Manual

There is one main steam stop valve in each of the fourmain steam lines at the Cook Nuclear Plant. Fastclosure of the main steam stop valves is accomplished bydump valves. There are two dump valves for each stopvalve (i.e., 8 dump valves), and one switch per dumpvalve (i.e., 8 switches). Actuation of either one ofthe two dump valves per stop valve will result inclosure of the stop valve. To be consistent with thechanges we have proposed for the other manual actuationswitches, the following description for the newFunctional Unit 9.d of T/S Table 3.3-3 is beingproposed:

Total No.of Channels

ChannelsT~oTri

MinimumChannels 0 erable

2/steam line(1 per train)

2/steam line(1 per train)

'/steam line(1 per train)

The above Item 2 changes to our manual actuation functionaldescriptions in T/S Table 3.3-3 are administrative in nature,intended only to make the T/S description more accurate and to beconsistent with T/S Table 3.3-5. No requirements with regard tooperability were lessened.

Chan e No. 3 Technical : Inconsistenc Between Surveillance

T/S Table 4.3-2 requires that both trains of manual actuationcircuitry, with the exception of the switches, be tested monthly.The switches, per Note 1 of Table 4.3-2, are required to be testedevery 18 months. 'Pith the exception of steam line isolation, themanual switches input directly into their associated trains solidstate protection s"stem (SSPS). The monthly testing that isperformed for the manual actuation circuitry (except steam lineisolation) is completely encompassed by the automatic actuationlogic testing of the SSPS, which per T/S Table 4.3-2 is to beperformed every 31 days on a staggered train basis, essentiallybimonthly . The different testing frequencies for the sameequipment appears ;o be an inconsistency in our T/Ss, which is notfound in Revision ~ of che STS. Rev. 4 of the STS does not

Attachment 1 to AEP:NRC:1030 Page 5

require monthly channel functional testing of the manualcircuitry. Rather, it requires that a "Trip Actuating DeviceOperational Test" be performed every 18 months. This is definedby the STS as follows:

A TRIP ACTUATING DEVICE OPERATIONAL TEST shall consist ofoperating the Trip Actuating Device and verifying OPERABILITYof alarm, interlock, and/or trip functions. The TRIPACTUATING DEVICE OPERATIONAL TEST shall include adjustment,as necessary, of the Trip Actuating Device such that itactuates at the required setpoint within the requiredaccuracy.

The inconsistency in our T/S required testing frequency for theportion of the circuitry not involving the manual switches isbelieved to be an error, which was corrected in later versions ofthe STS by adopting the "Trip Actuating Device Operational Test"described above. To correct the inconsistency in our T/Ss, we areproposing to adopt the STS requirement for the manual switches,and to apply the monthly testing of the balance of the circuitryonly to steam line isolation. The term "Trip Actuating DeviceOperational Test" is proposed for the Definition Section (1) ofthe T/Ss and to T/S 4.3.2.1.1.

Monthly testing of the automatic actuation logic has shown theSSPS at the Cook Nuclear Plant to be extremely reliable.Therefore, we believe that the frequency for testing the manual

'ircuitry(except for steam line isolation) can be made consistentwith the other SSPS test requirements without endangering publichealth and safety.

Chan e No. 4 Technical : Action Re uirements for Manual SteamLine Isolation

This change proposes a modification to functional unit 4.a (SteamLine Isolation-Manual) of T/S Table 3.3-3, for the purpose ofachieving greater consistency with the STS.

As currently written, the action statement for functional unit 4.a(Action 18) requires the unit to be placed in Mode 3 within 54hours if the number of operable channels is one less than thetotal. This difiers from the STS requirement, which requires thatthe steam line stop'alve associated with the inoperable manualchannel be declared inoperable if the cause of the channelinoperability is not corrected within 48 hours. The actionrequirement-of T/S 3.7.1.5 (Steam Generator Stop Valves) is thenfollowed. For op~."a'on in Mode 1, operation with one inoperablebut open stop val;~ e ~n proceed for four hours. If the cause of

Attachment 1 to AEP:NRC:1030 Page 6

the inoperability is not corrected, power must be reduced belowfive percent of rated thermal power within the next two hours.For Modes 2 and 3, operation may'continue provided the stop valveis maintained closed.

Me are proposing to change the action requirements for T/S Table3.3-3 functional unit 4.a to be consistent with the STS. Theaction requirement is changed from the current action 18 to a newaction 20, which is consistent with the STS requirement. Theproposed change provides internal consistency within the T/Ss bymaking the action requirements for the steam line manual actuationcircuitry consistent with those for the associated stop valves.The change also provides consistency with the STS.

Chan e No. 5 Editorial

This change proposes to correct an error in T/S Table 3.3-5regarding functions l.a and l.b., As previously written, themanual start of the containment air recirculation fans is groupedwith the safety injection and related functions. The start of thefans actually is associated with the switches of functional groupl.b (containment spray and related functions). Therefore, we areproposing to move the function from function l.a to function l.b.This change is also reflected in our proposed functional unit 9for T/S Tables 3.3-3, 3.3-4 and 4.3-2, which was described inChange No. 1 above.

10 CFR 50.92 Evaluation

Per 10 CFR 50.92, a proposed amendment will not involve asignificant hazards consideration if the proposed amendment doesnot:

(1) involve a significant increase in the probability orconsequences of an accident previously evaluated,

(2) create the possibility of a new or different kind ofaccident from any accident previously analyzed orevaluated, or

(3) involve .i significant reduction in a margin of safety.

Criterion 1

Change Nos. 1, 2 a:".d 5 are administrative in nature. They involverewriting the T/Ss :"yarding ESF manual actuations so that thefunctions are morc i:curately portrayed in the document, or so

Attachment 1 to AEP:NRC:1030 Page 7

that the document is internally consistent. Change No. 3,involving the ESF manual circuitry testing will reduce thefrequency of the portion involving the SSPS from once every monthto once every other month. This change corrects an inconsistencyin our T/Ss between the requirements for the manual circuitry andthe SSPS requirements which was recognized and corrected in laterversions of the STS. Our review of the surveillance test historyof the monthly SSPS tests has shown that the system is highlyreliable, and gives us confidence that the change in testfrequency will not endanger public health and safety. ChangeNo. 4, to the manual steam line isolation circuitry, providesinternal consistency in our T/Ss by making the action requirementsfor the manual actuation circuitry consistent with the associatedstop valves. The change is consistent with the STS. For thesereasons, it is our belief that the proposed changes do not involvea significant increase in the probability or consequences of apreviously evaluated accident, nor do they involve a significantreduction in a margin of safety.

Criterion 2

The changes will not introduce any new modes of plant operation,nor will any physical changes to the plant be required. Thus, thechanges should not create the possibility of 'a new or differentkind of accident from any accident previously analyzed orevaluated.

Criterion 3

See Criterion 1, above.

Lastly, we note that the Commission has provided guidanceconcerning the determination of significant hazards by providingcertain examples (48 FR 14870) of amendments considered not likelyto involve significant hazards consideration. The first of theseexamples refers to changes which are administrative in nature: forexample, changes to achieve consistency throughout the T/Ss,correction of errors, or changes in nomenclature. Change Nos. 1,2 and 5 are in this category in that they clarify the T/Ss andmake them more internally consistent. The sixth example refers tochanges which may ".esult in some increase to the probability orconsequences of a previously analyzed accident, but where theresults of the change are clearly within acceptable limits. Thisexample is relevant to change Nos. 3 and 4 since the changes areconsistent with the STS. Based on the discussion above, weconclude that the exampies cited are relevant and that the changesshould not require significant hazards consideration.