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Category:Letter type:AEP
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Cook Nuclear Plant, Emergency Plan, Revision 472022-08-0202 August 2022 Transmittal of Donald C. 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[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARAEP-NRC-2022-03, Final Supplemental Response to NRC Generic Letter 2004-022022-01-20020 January 2022 Final Supplemental Response to NRC Generic Letter 2004-02 AEP-NRC-2021-68, Response to Request for Additional Information on Requested Change Regarding Containment Water Level Instrumentation2021-12-16016 December 2021 Response to Request for Additional Information on Requested Change Regarding Containment Water Level Instrumentation AEP-NRC-2021-43, Response to Request for Additional Information Regarding Relief Request for Limited Coverage Examinations Performed in the Fourth 10-Year Inspection Interval2021-07-21021 July 2021 Response to Request for Additional Information Regarding Relief Request for Limited Coverage Examinations Performed in the Fourth 10-Year Inspection Interval AEP-NRC-2021-16, Unit 2 - Response to Request for Additional Information Regarding CFR 50.55a Request Associated with the Fifth Ten-Year Inservice Testing Interval2021-02-25025 February 2021 Unit 2 - Response to Request for Additional Information Regarding CFR 50.55a Request Associated with the Fifth Ten-Year Inservice Testing Interval AEP-NRC-2021-18, Response to Request for Additional Information Regarding License Amendment Request for One-Time Extension of the Containment Type a Leak Rate Testing Frequency2021-02-18018 February 2021 Response to Request for Additional Information Regarding License Amendment Request for One-Time Extension of the Containment Type a Leak Rate Testing Frequency AEP-NRC-2020-50, Response to Request for Additional Information Regarding License Amendment Request for One-Time Extension of the Containment Type a Leak Rate Testing Frequency2020-07-0909 July 2020 Response to Request for Additional Information Regarding License Amendment Request for One-Time Extension of the Containment Type a Leak Rate Testing Frequency AEP-NRC-2019-56, Seismic Probabilistic Risk Assessment in Response to Near Term Task Force Recommendation 2.1: Seismic2019-11-0404 November 2019 Seismic Probabilistic Risk Assessment in Response to Near Term Task Force Recommendation 2.1: Seismic AEP-NRC-2019-32, Unit 2 - Response to Request for Additional Information Regarding Unit 2 Leak-Before-Break Analysis and Deletion of Containment Humidity Monitors for Unit 1 and Unit 22019-08-22022 August 2019 Unit 2 - Response to Request for Additional Information Regarding Unit 2 Leak-Before-Break Analysis and Deletion of Containment Humidity Monitors for Unit 1 and Unit 2 AEP-NRC-2019-40, Response to Request for Additional Information Regarding License Amendment Request to Address NSAL-15-1, Rev. 02019-07-30030 July 2019 Response to Request for Additional Information Regarding License Amendment Request to Address NSAL-15-1, Rev. 0 AEP-NRC-2018-81, Supplement to Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping2018-11-27027 November 2018 Supplement to Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping AEP-NRC-2018-82, Response to Request for Additional Information Regarding the Alternative Request for Elimination of the Reactor Pressure Vessel Threads in Flange Examination2018-11-20020 November 2018 Response to Request for Additional Information Regarding the Alternative Request for Elimination of the Reactor Pressure Vessel Threads in Flange Examination AEP-NRC-2018-64, Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping2018-09-27027 September 2018 Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping ML18334A2722018-09-18018 September 2018 LTR-SDA-II-18-41-NP, Revision 1, Responses to NRC Questions on the Expanded Scope Leak-Before-Break Evaluations for D.C. Cook, Units 1 and 2. AEP-NRC-2018-45, Response to Request for Additional Information Concerning 2017 Decommissioning Funding Status Report2018-08-0909 August 2018 Response to Request for Additional Information Concerning 2017 Decommissioning Funding Status Report AEP-NRC-2018-01, Response to Request for Additional Information Regarding Generic Letter 2016-012018-05-25025 May 2018 Response to Request for Additional Information Regarding Generic Letter 2016-01 AEP-NRC-2018-23, Response to Request for Additional Information Regarding Independent Spent Fuel Storage Installation Decommissioning Funding Plan2018-04-11011 April 2018 Response to Request for Additional Information Regarding Independent Spent Fuel Storage Installation Decommissioning Funding Plan ML18092A0842018-03-28028 March 2018 Donald C. Cook Nuclear Plant Unit 2, Response to Request for Additional Information Regarding Supplemental Information Regarding the Reactor Vessel Internals Aging Management Program ML17346A7662017-12-0808 December 2017 Enclosures 2 & 3 to AEP-NRC-2017-56 - Response to Request for Additional Information Regarding the License Amendment Request to Revise Emergency Action Levels and EAL Technical Basis Manual AEP-NRC-2017-56, Response to Request for Additional Information Regarding the License Amendment Request to Revise Emergency Action Levels2017-12-0808 December 2017 Response to Request for Additional Information Regarding the License Amendment Request to Revise Emergency Action Levels AEP-NRC-2017-30, Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.9.3, Containment Penetrations2017-05-26026 May 2017 Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.9.3, Containment Penetrations AEP-NRC-2017-16, Submittal of Focused Evaluation in Response to March 12, 2012, Request for Information Regarding Near- Term Task Force Recommendation 2.1: Flooding2017-05-11011 May 2017 Submittal of Focused Evaluation in Response to March 12, 2012, Request for Information Regarding Near- Term Task Force Recommendation 2.1: Flooding AEP-NRC-2017-09, Response to Request for Additional Information Regarding the License Amendment Request for the Containment Leakage Rate Testing Program2017-02-27027 February 2017 Response to Request for Additional Information Regarding the License Amendment Request for the Containment Leakage Rate Testing Program AEP-NRC-2016-81, Unit 2 - Supplemental Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTP-425, Relocate Surveillance Frequencies Program to Licensee Control-Risk Informed ...2016-11-0303 November 2016 Unit 2 - Supplemental Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTP-425, Relocate Surveillance Frequencies Program to Licensee Control-Risk Informed ... AEP-NRC-2016-80, Response to NRC Generic Letter 2016-01: Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools2016-10-31031 October 2016 Response to NRC Generic Letter 2016-01: Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools AEP-NRC-2016-79, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from Fukushima Dai-ichi Accident2016-10-12012 October 2016 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from Fukushima Dai-ichi Accident AEP-NRC-2016-69, Follow-up Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to License Control-Risk Informed Technical Specification Task Force.2016-09-0909 September 2016 Follow-up Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to License Control-Risk Informed Technical Specification Task Force. AEP-NRC-2016-56, Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2016-07-12012 July 2016 Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2016-48, Unit 2 - Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee-Control...2016-06-16016 June 2016 Unit 2 - Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee-Control... AEP-NRC-2016-54, Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force Initiative 582016-06-16016 June 2016 Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force Initiative 58 ML16169A1152016-05-0606 May 2016 Donald C. Cook Nuclear Plant Units 1 and 2 - Response to Sixth Request for Additional Information the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2016-24, Response to Fifth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2016-02-19019 February 2016 Response to Fifth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2016-14, Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2016-01-21021 January 2016 Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation AEP-NRC-2015-11, Response (Part 2) to Fourth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2015-12-17017 December 2015 Response (Part 2) to Fourth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term ML15323A4332015-11-16016 November 2015 Supplemental Response to Request for Additional Information on the Application for Amendment to Restore Normal Reactor Coolant System Pressure and Temperature Consistent with Previously Licensed Conditions. ML15323A4342015-11-16016 November 2015 Response (Part 1) to Fourth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2015-98, Supplemental Response to Follow-Up Request for Additional Information Concerning the Reactor Vessel Internals Aging Management Program2015-10-30030 October 2015 Supplemental Response to Follow-Up Request for Additional Information Concerning the Reactor Vessel Internals Aging Management Program AEP-NRC-2015-99, Response to Request for Additional Information Re License Amendment Request to Revise Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11 and 3.8.1.152015-10-30030 October 2015 Response to Request for Additional Information Re License Amendment Request to Revise Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11 and 3.8.1.15 ML15308A0932015-10-15015 October 2015 Pressurized Water Reactor Owners Group (Pwrog), 15066-NP, Revision 1, Responses to Follow-Up NRC RAI 2 on the D.C. Cook, Units 1 and 2, Reactor Internals Aging Management Program. AEP-NRC-2015-86, Supplemental Response to Request for Additional Information on the Application for Amendment to Restore Normal Reactor Coolant System Pressure and Temperature Consistent With. Previously Licensed Conditions.2015-09-18018 September 2015 Supplemental Response to Request for Additional Information on the Application for Amendment to Restore Normal Reactor Coolant System Pressure and Temperature Consistent With. Previously Licensed Conditions. AEP-NRC-2015-80, Response to Third Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2015-08-28028 August 2015 Response to Third Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2015-88, Response to Request for Additional Information Regarding Proposed Alternative to the American Society of Mechanical Engineers Code, Section XI Repair Requirements2015-08-24024 August 2015 Response to Request for Additional Information Regarding Proposed Alternative to the American Society of Mechanical Engineers Code, Section XI Repair Requirements AEP-NRC-2015-75, Response to Second Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2015-08-24024 August 2015 Response to Second Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2015-69, Response to Follow-Up Request for Additional Information Concerning the Reactor Vessel Internals Aging Management Program2015-08-0606 August 2015 Response to Follow-Up Request for Additional Information Concerning the Reactor Vessel Internals Aging Management Program ML15223A4362015-07-28028 July 2015 PWROG-15066-NP, Revision 0, Responses to Follow-Up NRC RAI 2 on the DC Cook Units 1 and 2 Reactor Internals Aging Management Program. AEP-NRC-2015-64, Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term2015-07-17017 July 2015 Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term AEP-NRC-2015-63, Response to Request for Additional Information Regarding 2014 Unit 1 Steam Generator Tube Inspection2015-07-17017 July 2015 Response to Request for Additional Information Regarding 2014 Unit 1 Steam Generator Tube Inspection AEP-NRC-2015-60, Response to a Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.152015-07-0909 July 2015 Response to a Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15 AEP-NRC-2015-66, Response to Request for Additional Information Regarding Exigent License Amendment Request Regarding Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation2015-07-0202 July 2015 Response to Request for Additional Information Regarding Exigent License Amendment Request Regarding Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ML18219D0951978-09-29029 September 1978 D.C Cook - Acknowledges 07/12/1978 Letter Advising of Additional Information to Complete NRC Staff'S Review of D.C Cook Nuclear Plant'S Ice - Basket Stress Analysis ML18219D7991978-09-29029 September 1978 Response to Request for Additional Information on Ice Basket Stress Analysis, Prepared by Westinghouse Electric Corporation 2022-01-20
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MINDIANA Indiana Michigan Power MICHIGANCook Nuclear Plant JJV*I*'R One Cook Place A untof~nerian lectic PwerBridgmnan, Ml49106 A unt ofmenan Eectic PwerIndiana Michigan Powercomn January 21, 2016 AEP-NRC-201 6-14
- 10 CER 50.90 Docket Nos. 50-316 U. S. Nuclear Regulatory Commission ATT-IN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 2 Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation
References:
- 1. Letter from Q. S. Lies, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant Unit 2 License Amendment Request Regarding Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation," dated October 19, 2015, Agencywide Documents Access and Management System (ADAMS) Accession No. ML15293A497.
- 2. E-mail capture from A. W. Dietrich, NRC, to H. L. Kish, I&M, "D.C. Cook Nuclear Plant, Unit 2-SBPB Request for Additional Information Concerning ESFAS [AR (CAC No. MF6984),"
dated December 10, 2015, ADAMS Accession No. ML15344A350.
This letter provides Indiana Michigan Power Company's (l&M), licensee for Donald C. Cook Nuclear Plant (CNP) Unit 2, response to the Request for Additional Information (RAI) by the U. S. Nuclear Regulatory Commission (NRC) regarding a license amendment request (LAR) to revise Technical Specification (TS) 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation.
By Reference 1, I&M submitted a request to amend the TSs to CNP Unit 2 Renewed Facility Operating License DPR-74. I&M proposes to modify TS 3.3.2 requirements for the ESFAS instrumentation by adding a new Condition for inoperable required channels for main feedwater pump trips, and by adding a footnote to- the Applicable Mode column of TS Table 3.3.2-1 to reflect applicability in Mode 2. By Reference 2, the NRC transmitted an RAI from the Balance of Plant Branch regarding the [AR submitted by l&M in Reference 1.
Enclosure I to this letter provides an affirmation statement. Enclosure 2 to this letter provides I&M's response to the NRC's RAI in Reference 2. Copies of this letter are being transmitted to the Michigan Public Service Commission and Michigan Department of Environmental Quality, in accordance with the requirements of 10 CFR 50.91.
U. S. Nuclear Regulatory Commission AEP-NRC-2016-14 Page 2 There are no new regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Q. ~Shane Lies Site Vice President TLC/mll
Enclosures:
- 1. Affirmation
~Response to Request for Additional Information Regarding the License Amendment 2....
Request to Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation
- 3. Donald C. Cook Nuclear Plant Unit 2 Technical Specification (TS) Page 3.3.2-3 Marked to Show Proposed Changes TS 3.3.2, ESFAS Instrumentation c: R. J. Ancona, MPSC A. W. Dietrich, NRC, Washington, D.C.
MDEO - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC, Region Ill A. J. 'Williamson, AEP Ft. Wayne, w/o enclosures
Enclosure 1 to AEP-NRC-2016-14 AFFIRMATION of Indiana Michigan I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President with the U. S. Nuclear Power Company (I&M), that I am author-ized to sign and file this request and the matters set Regulatory Commission on behalf of I&M, and that the statements made information, and forth herein pertaining to I&M are true and correct to the best of my knowledge, belief.
Indiana Michigan Power Company Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIIS' \ DAY O F',,.¢ ,4, 2016 NotaryDANIELLE BURGOYNE Public, State of Michigan County of Berrien .
My commission Expires 04-04-2018 Acting In the County ot'*S5~X Mv Commission Expires *Z~- (>\ -~ *-,\
Enclosure 2 to AEP-NRC-2016-14 Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation By letter dated October 19, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15293A497) (Reference 1), Indiana Michigan Power Company (I&M), the licensee for the Donald C. Cook Nuclear Plant (CNP), Unit 2, submitted a license amendment request (LAR). The proposed amendment would modify Technical Specifications (TS) 3.3.2 requirements for the Engineered Safety Feature Actuation System (ESFAS) instrumentation by adding a new Condition for inoperable required channels for main feedwater (MFVW) pump trips, and by adding a footnote to the Applicable Mode column of TS Table 3.3.2-1 to reflect applicability in Mode 2.-
The U. S. Nuclear Regulatory Commission (NRC) staff in the Balance of Plant Branch (SBPB) of the Office of Nuclear Reactor Regulation is currently reviewing the submittal and has determined that additional information is needed in order to complete the review. The text of the requests for additional information (PAls) and I&M's responses are provided below.
RAI-S BPB-1 Section 3.1 of the license amendment request (LAR) states that "loss of both anticipatory trip channels does not place the plant in an unanalyzed condition and, therefore, the plant should not be required to enter TS [technical specification] Limiting Condition of Operation (LCO) 3.0.3." The LAR does not explain how starting one main feedwater pump causes a loss of both anticipatorytrip channels, nor does it provide the definition of a channel.
a) Clarify the above statement, since starting a main feedwater pump results in a loss of only one anticipatorytrip channel.
b). Explain the concern regardingbeing required to enter TS LCO 3.0.3.
c)-e fine each Engineered Safety Feature Actuation System (ESFAS) Function 6.g channel by identifying associated contacts and relays. Explain whether proposed TS Bases should be clarified regardingthe composition of each channel.
- I&M Response to RAI-SBPB-I:
There is only one anticipaitory trip channel per MEW pump. Section 3.1 of the LAR describes scenarios in which MEW pumps are started and then subsequently undergo a trip for an unknown reason. Because there is only one channel per MFW pump, starting only one MFW pump does not result in the loss of both anticipatory trip channels. It would result in the loss of only one anticipatory trip channel. Also, the discussion of trip channels is based on the premise that normal plant evolutions such as startup and shutdown should not result in entry into an LCO. The trip channels are needed only to mitigate abnormal events...
to AEP-NRC-2016-14 Pg Page 2 a) In the second RAI-SBPB-1 paragraph above, of the the phrase, Summary "loss in Section trip of both anticipatory of the [AR, 3.1 channels" refers referenced in to loss of the channels for a degraded condition, something other than starting a MEW pump. As shown in Figure 1 of Enclosure 2 to Reference 1, in order for the actuation trains for auxiliary feedwater (AFW) pumps to initiate an automatic start, both MEW pump trip channels must be activated.. To clarify the effect that trip channels have on the LCO, Condition H wording "will-be revised to delete the phrase "or more" along with the "(s)" after channel, so that the
... new Condition H will read, "One MEW Pump trip channel inoperable." A markup of the revised TS page is provided in Enclosure 3.
b) Regarding LCO 3.0.3 entry, it has been determined that entry into LCO 3.0.3 would not be required for CNP Unit 2, because there is only one trip channel per pump. With only one trip channel per MEW pump in Unit 2, entry into LCO 3.0.3 for this condition would not be required because each Unit 2 MFW pump is allowed a separate entry into Condition H. In addition, if the loss of both anticipatory trip channels is due to a degraded condition, that should not warrant entry into LCO 3.0.3 because the anticipatory MEW pump trip is not
- credited in the accident analysis.
c) A trip channel is considered to be the position indication switch, which closes when the associated MFW pump steam stop valve closes, along with the relay, as shown in Figure 1 of Enclosure 2 in Reference 1. The RE and Rw relays for the MEW pump trip channels in Unit 2 provide input to the AEW pump actuation train logic as shown in Figure 1 of Enclosure 2 in Reference 1. When the AEW actuation relay for either MFW pump (RE or RW) is energized, a signal is sent to the AFW pump actuation logic circuit. The AEW pumps will not start until signals from both MEW pump channels have been received by the AEW pump actuation logic circuit. Consideration will be given to providing additional clarification in the TS Bases regarding the composition of each channel*.
RAI-SBPB The LAR states that starting a main feedwater pump makes the associatedESFAS Function 6.g channel inoperable until it is supplying feedwater to the steam generators. The LAR proposes adding,n~ew Condition H and Note H. 1. Note H. 1 allows one ESFAS Function 6.g channel on one main feedwater pump to be inoperable for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Proposed Note H. I becomes pertinent,after entering Condition H. The value and purpose of Note H. I is questionable because the proposed Condition H already provides for the channel to be inoperable for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The purpose of Condition H is also questionable because Condition B already allows one channel to be inoperable for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
a) Explain the intended purpose of the proposed TS changes.
b) Explain how the proposed TS changes accomplish the intended purpose. Alternatively, revise .the proposed TS changes.
Enciosure 2 to AEP-NRC-2016-14 Pg Page 3 I&M Response to RAI-SBPB-2:
Proposed Note H.1 states that one MFW pump may be inoperable for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the process of removing the pump from service or placing the pump in service. This provision allows pump startup and shutdown to occur when the MFW pump is reset and not capable of feeding the steam generators, without requiring entry into the Required Action for Condition H.1.
a) This change is being proposed for two reasons. First, as discussed in Reference 1, this change is proposed to provide consistency in format and function between the Unit .1 and Unit 2 TS. Second, as discussed in Section 3.4 of Reference 1, the Note for H.1 is proposed to prevent unnecessary entry into LCO applicability for normal operational occurrences, such as startup and shutdown of a MEW pump.
b) Even though the proposed new Condition H is similar in function to the existing Condition B, the addition of the new Condition H will create consistency with the format of Unit 1 TS, for which this change has already been approved. In addition, the proposed Note to Required Action H.1 will prevent entry into Condition H while placing the MFW system into service or removing it from service, which are evolutions that typically should not require entry into an LCO Condition.
REFERENCES
- 1. Letter from Q. S. Lies, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant Unit 2 License Amendment Request Regarding Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," dated October 19, 2015, Agencywide Documents Access and Management System (ADAMS) Accession No. ML15293A497.
Enclosure 3 to AEP-NRC-2016-14, DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION (TS)
PAGE 3.3.2-3 MARKED TO SHOW PROPOSED CHANGES TS 3.3.2, ESFAS Instrumentation
ESFAS Instrumentation 3.3.2 ACTIONS (continued)___________
CONDITION REQUIRED ACTION COMPLETION TIME El lone Main Feedwatet H.1-----------NOTE-------
IPumP trip channelI One channel on one MFW
[inoperable~l,' pump may be inoperable S for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the process of removing the pump from service or placing the pump in service.
Rsoechannel to 48hoursI HI=]. Required Action and 1*fj.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition B~
not met for Function 6.g.
OR Required Action and associated Completion Time of Condition D not met for Function 6.f.
Cook'Nuclear Plant Unit 2 3323AedetN.2w 3.3.2-3 8