AEP-NRC-2019-18, License Amendment Request to Delete Technical Specification Surveillance Requirement 3.8.1.20, Regarding Diesel Generator Operation When Connected to Its Load Test Resistor Bank

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License Amendment Request to Delete Technical Specification Surveillance Requirement 3.8.1.20, Regarding Diesel Generator Operation When Connected to Its Load Test Resistor Bank
ML19184A070
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 06/27/2019
From: Lies Q
Indiana Michigan Power Co
To:
NRC/Document Processing Center, Office of Nuclear Reactor Regulation
References
AEP-NRC-2019-18
Download: ML19184A070 (32)
v • d • e


Text

m INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power lndianaMichiganPower.com June 27, 2019 AEP-NRC-2019-18 10 CFR 50.90 Docket Nos.: 50~315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 and Unit 2 License Amendment Request to Delete Technical Specification Surveillance Requirement 3.8.1.20, Regarding Diesel Generator Operation When Connected to its Load Test Resistor Bank

Dear Sir or Madam:

In accordance with 10 CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Renewed Facility Operating Licenses DPR-58 and DPR-74. l&M proposes to change TS 3.8.1, "AC Sources - Operating," by deleting CNP-specific Surveillance Requirement (SR) 3.8.1.20 which requires verification that Diesel Generator (DG) availability is not compromised as the result of connecting the DG to its load test resistor banks. The load test resistor banks are no longer operational or needed for DG testing and are to be removed. Existing SR 3.8.1.21 provides similar assurance of DG availability when connected to the bus now used for DG testing. l&M is also proposing conforming editorial changes to delete reference to SR 3.8.1.20 in SR 3.8.1.23 and SR 3.8.2.1. l&M has evaluated the proposed amendment in accordance with 10 CFR 50.92 and concluded that the change involves no significant hazards consideration.

  • Enclosure 1 to this letter provides an affirmation statement pertaining to the information contained herein. Enclosure 2 provides l&M's evaluation of the proposed TS change. Enclosures 3 and 4 provide Unit 1 and Unit 2 TS pages, respectively, marked to show the proposed changes. Clean Unit 1 and Unit 2 TS pages with proposed changes incorporated will be provided to the Nuclear Regulatory Commission (NRC) Licensing Project Manager when requested. Enclosures 5 and 6 provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. These Bases changes are provided for information only.

l&M requests approval of the proposed change in accordance with the NRC's normal review and approval schedule. The proposed change will be implemented within 90 days of NRC approval.

U. S. Nuclear Regulatory Commission AEP-NRC-2019-18 Page 2 Copies of this letter and its enclosures 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.

There are no .new regulatory commitments made in this letter._ Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.

Sincerely, 1~i~

a-Cn:n S. Lies - - -.

Site Vice President JRW/mll

Enclosures:

1. Affirmation
2. License Amendment Request to Delete Technical Specification Surveillance Requirement 3.8.1.20, Regarding Diesel Generator Operation When Connected to its Load Test Resistor Bank
3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes
4. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Proposed Changes
5. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only)
6. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only) c: R. J. Ancona - MPSC R. F. Kuntz- NRC Washington, DC EGLE - RMD/RPS NRC Resident Inspector D. J. Roberts - NRC Region Ill A J. Williamson -AEP Ft. Wayne, w/o enclosures I

I

Enclosure 1 to AEP-NRC-2019-18 AFFIRMATION I, Quinton S. Lies, being duly sworn, state that I am the Site Vice President of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U.S. Nuclear Regulatory Commission on behalf of l&M,- and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company 2~ic QuiCs. Lies Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS ,Z_] DAYOF~Jj~LL_ne.~_ _ 2019

~~~t~

My Commission Expires O \ {1\ \ 2..02.s

Enclosure 2 to AEP-NRC-2019-18 License Amendment Request to Delete Technical Specification Surveillance Requirement 3.8.1.20, Regarding Diesel Generator Operation When Connected to its Load Test Resistor Bank 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

3.0 TECHNICAL EVALUATION

3.1 DG Load Testing and Governor and Voltage Regulator Tuning Without the Load Test Resistor Banks*

3.2 Plant Modification to Remove the Load Test Resistor Banks

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 No Significant Hazards Consideration 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Enclosure 2 to AEP-NRC-2018-18 Page 2 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C.

Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. l&M proposes to change TS 3.8.1, "AC Sources - Operating," by deleting .Surveillance Requirement (SR) 3.8.1.20 regarding Diesel Generator (DG) operation when connected to its load test resistor bank. The load test resistor bank is no longer operational or needed, and is planned for removal. l&M is also proposing conforming editorial changes to delete reference to SR 3.8.1.20 in SR 3.8.1.23 and SR 3.8.2.1.

2.0 DETAILED DESCRIPTION

  • 2.1
  • System Design and Operation The components involved in the proposed change are the DGs and their associated load test resistor banks.

The CNP electrical systems include onsite, safety-related, independent, and automatically starting DGs, which are available to supply electrical power to Engineered Safety Features (ESF) if both the normal power source (the main generator via the Unit Auxiliary Transformers (UATs)) and the

  • preferred offsite power source (the grid via the Reserve Auxiliary Transformers (RATs)) are unavailable. The emergency power sources consist of four 4 kilovolt (kV), 3500 kilowatt (kW) DGs, two for each unit. The output of each DG is connected to three parallel breakers. One of those breakers feeds the load test resistor bank described below. The other two breakers are connected to 4 kV unit-specific buses T11A and T11 B, or unit specific buses T11 C and T11 D. These "T" buses supply power to 4 kV/ 600 volt transformers that power the ESF loads.

During normal plant operation, the 'T' buses are powered from the Main Generator via the UAT.

Upon a trip of the main generator, power to the "T" busses would be automatically transferred from the UAT to the RAT. Upon loss of RAT power to a 'T' bus, the associated DG will start automatically. When the DG voltage and speed approach rated values, the breaker to the associated 'T' bus will automatically close to re-energize the bus. The DG would then supply power to the appropriate 600 volt ESF components. If either DG in a unit failed to start, the remaining DG in that unit is capable of supplying the unit's required ESF loads.

Load Test Resistor Bank There are two 4 kV non-safety-related load test resistor banks located on the Auxiliary Building roof.

These resistor banks were included in the original CNP design to serve as an electrical load during DG testing. Each resistor bank is rated for 1750 kW which is approximately one half of the rating of a single DG. The resistor banks are shared between Unit 1 and Unit 2. One resistor bank serves the Train A DGs of both units, while the other resistor bank serves the Train B DGs of both units.

Safety-related resistor bank breakers connect the safety-related DG output to the non-safety-related load _test resistor bank. An .emergency signal (loss of offsite power or Safety Injection), will trip the associated resistor bank breaker. The resistor banks* were used in the past for initial DG qualification, for monthly DG load testing, and for DG governor and voltage regulator tuning. The

. J to AEP-NRC-2019-18 Page 3 resistor banks could also be used for monthly DG 50% load testing until the applicable SR was changed in 1996 to require monthly full load testing. However, the resistor banks are no longer operational and, as described in Section 3.0, "Technical Evaluation," below, the resistor banks are no longer needed or used for DG testing, or DG governor and voltage regulator tuning.

2.2 Current Technical Specifications Requirements Note that underlining has been added to some of the quoted text below to emphasize significant distinctions.

TS 3.8.1, "AC Sources - Operating" LCO 3.8.1

  • in the current Unit 1 TS and the current Unit 2 TS 'requires: *

"b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s);"

This is a standard limiting condition for operation (LCO) that was transitioned from the previous NUREG 1452 based CNP TS into the current NUREG 1431 based CNP TS during the conversion to Improved Standard TS. That conversion was approved by the Nuclear Regulatory Commission (NRC) (Reference 2). This LCO is not altered by the proposed change.

It is presented here for reference only.

LCO 3.8.1 in the current Unit 1_TS requires "d. The Unit 2 DG(s) capable of supporting the associated equipment required to be OPERABLE by LCO 3.7.8 [for Essential Service Water (ESW) System operability]."

LCO 3.8.1 in the current Unit 2 TS requires "d. The Unit 1 DG(s) capable of supporting the associated equipment required to be OPERABLE by LCO 3.7.8 [for ESW System operability]."

These are site-specific LCO's that were added during the conversion to the Improved Standard TSs. These LCOs reflect the interdependence of the Unit 1 and Unit 2 ESW systems in their normal cross-tied configuration at CNP, and the need for the opposite unit DGs to support the opposite unit ESW system in that configuration. These LCOs are not altered by the proposed change. They are presented here for reference only.

SR 3.8.1.20 in the current Unit 1 TS and the current Unit 2 TS states:

"Verify, with a DG operating in test mode and connected to its load test resistor bank, an actual or simulated ESF actuation signal overrides the test mode by:

a. Returning DG to ready-to-load operation; and to AEP-NRC-2019-18 Page4
b. Verifying the emergency loads are serviced by offsite power."

SR 3.8.1.20 includes Note 1 which states:

"This SR is only required to be metwhen the applicable DG is connected to its load test resistor bank."

This is a site-specific SR that was transitioned from the previous NUREG 1452 based CNP TS into the current NUREG 1431 based CNP TS during the conversion to the Improved Standard

  • TS. This SR recognized the presence and use of DG load test resistor banks, which few other plants have. This SR ensures that the DG availability under accident conditions will not be compromised as the result of connection to the DG load test resistor bank, and ensures that the
  • oG will automatically reset to ready-to-load condition* if *an actuation signal is "received during

- operation in the test mode. This SR would be altered by the proposed change as described in Section 2.4 of this amendment request.

  • SR 3.8.1.21 in the current Unit 1 TS and the current Unit 2 TS requires:

"Verify, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

  • a. Returning DG to ready-to-load operation; and
b. Verifying the emergency loads are serviced by offsite power."

This is a standard NUREG 1431 SR that was not included in the previous NUREG 1452 based CNP TS, but was added during the conversion to Improved Standard TSs. This SR ensures that the DG availability under accident conditions will not be compromised as the result of connection to its bus, i.e. the DGs 'T' bus, and that the DG will automatically reset to ready-to-load operation if an actuation signal is received during operation in the test mode. This SR will not be altered by the proposed change. It is presented here for reference only.

SR 3:8.1.23 in the current Unit 1 TS requires:

"For required Unit 2 AC sources, the SRs of Unit 2 Specification 3.8.1, except SR 3.8.1.9.b, SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable."

SR 3.8.1.23 in the current Unit 2 TS requires:

"For required Unit 1 AC sources, the SRs of Unit 1 Specification 3.8.1, except SR 3.8.1.9.b, SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable."

to AEP-NRC-2019-18 Page 5 These are site-specific SRs that were added during the conversion to the Improved Standard TSs. These SRs reflect the interdependence of the Unit 1 and Unit 2 ESW systems in their normal cross-tied configuration at CNP, and the need for the opposite unit DGs to support the opposite unit ESW system in that configuration. These SRs provide assurance that the

- - opposite unit's alternating current (AC) sources are available to support the opposite unit's ESW system as required by Unit 1 and Unit 2 LCOs 3.8.1.d. These SRs will be altered by the proposed change as described in Section 2.4 of this amendment request.

TS 3.8.2, "AC Sources - Shutdown" SR 3.8.2.1 in the current Unit 1 TS and the current Unit 2 TS states:

"For AC sources required to be OPERABLE, the SRs of Specification 3.8.1, "AC Sources -

Operating," except SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only),

SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable."

This is a standard SR that was transitioned from the previous NUREG 1452 based CNP TS into the current NUREG 1431 based CNP TS during the site conversion to Improved Standard TSs.

This SR is intended to assure that the unit's required AC sources are available to support required safety systems in Modes 5, and 6, and during movement of irradiated fuel. This SR will be altered by the proposed change as described in Section 2.4 of this amendment request. _

2.3 Reason for the Proposed Change l&M plans to remove the load test resistor banks. The resistor banks are no longer needed for DG testing or governor and voltage regulator tuning, and are no longer operational. Their current location on the Auxiliary Building roof can be utilized for other non-safety related equipment.

Therefore, all reference to the load test resistor banks should be removed from the TS.

2.4 Description of the Proposed Change l&M proposes the following changes to the current Unit 1 and Unit 2 TSs

  • Delete the entire SR 3.8.1.20. The removed text will be replaced with the word "DELETED."

Enclosures 3 and 4 to this letter provide the Unit 1 and Unit 2 TS pages, respectively, marked to show the proposed changes. Removed text on the pages -of Enclosures 3 arid 4 is lined through and new text on these pages is marked with a single-line outside border. New clean Unit 1 and Unit 2 TS pages with the proposed changes incorporated will be provided to the NRC Licensing Project Manager for CNP when requested. Enclosures 5 and 6 to this letter provide Unit 1 and Unit 2 TS Bases pages, respectively, marked to show planned changes to support the proposed TS changes of Enclosure 3 and Enclosure 4. The planned Bases changes are provided for information

Enclosure 2 to AEP-NRC-2019-18 Page 6 only. Changes to the TS Bases, consistent with the technical and regulatory analyses, will be implemented under the CNP TS Bases Control Program in accordance with TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of the implementation of the proposed TS changes following NRC approval.

3.0 TECHNICAL EVALUATION

3.1 DG Load Testing and Governor and Voltage Regulator Tuning Without the Load Test

  • Resistor Banks The load test resistor banks are not needed for performance of the SRs that require DG loading.

The loads required by those SRs are now applied either by paralleling the DG to a 'T' bus that is being powered by the grid (SRs 3.8.1.3; 3.8.1.10; 3.8.1.11, 3.8.1.15, 3.8.1.16), or*by connecting the*

DG to its 600 volt ESF loads via a 'T' bus (SRs 3.8.1.12, 3.8.1.13, 3.8.1.17, 3.8.1.19).

DG governor and voltage regulator tuning which previously used a load test resistor bank to apply a load to the DG is now conducted by applying selected plant ESF loads to the DG via a 'T' bus and 600 volt bus that are isolated from other power supplies and loads. Governor and voltage regulator

  • tuning with the DG in this configuration provides a constant load that allows adjustment of governor speed and load settings without perturbations from the grid. Governor and voltage regulator tuning in this configuration is used by other nuclear power plants.

Since all loads will be applied to the DG via a 'T' bus, SR 3.8.1.21 will provide assurance that DG availability under accident conditions will not be compromised as the result of connection to its

'T' bus for load testing and the DG will automatically reset to ready-to-load operation if an actuation signal is received during operation in the test mode. Although SR 3.8.1.21 assures that connection of the DG to a 'T' bus will not compromise DG availability and/or automatic reset, some testing or governor and voltage regulator tuning activities may render the DG inoperable. In such cases the associated TS Required Actions and Completion Times are followed.

3.2 Plant Modification to Remove the Load Test Resistor Banks The following description of certain aspects of the plant modification is provided as background information. The proposed amendment applies solely to the deletion of SR 3.8.1.20.

The non-safety-related load test resistor banks and associated equipment (e.g., cooling fans) will be removed from the Auxiliary Building roof. Preparation of the plant modification instructions is in progress. The safety-related components that will be affected and their currently planned disposition are as follows:

  • The 4 kV load test resistor bank breakers will be removed and the associated switchgear will be abandoned in place.
  • The 4 kV cabling between the load test resistor bank breakers and the 4 kV safety-related buses will be abandoned in place or removed to the extent possible.
  • The control components for the 4 kV load test resistor bank breakers will be removed where possible or abandoned in place.

Enclosure 2 to AEP-NRC-2019-18 Page 7

  • The 120 Volt unit transfer switches and control switches for the resistor bank breakers will be disconnected and removed from the Unit 1 and Unit 2 Control Room panels, or will be left in place and reused for other applications .

.* The 120 Volt cabling for the transfer and breaker control switches will be disconnected and either removed or abandoned in place, or will be reused if the associated switches are reused for other applications.

The NRC staff will be informed if significant changes to the affected safety-related components or their final configuration as described above occur during finalization and implementation of the plant modification instructions. During performance of portions of the modification, it may be necessary

. for DG(s) to. be inoperable in *acccirdarice with the applicable Technical Specification LCOs *and .

Action requirements. However, upon completion, the plant modification will not affect the ability of the DGs to perform their intended safety function, or the manner in which it is performed.

4.0 REGULATORY EVALUATION

. 4.1 Applicable Regulatory Requirements/Criteria The following NRC requirement documents are applicable to the proposed change.

10 CFR 50.36, "Technical Specifications,"

Section 10 CFR 50.36(c) states:

(c) Technical specifications will include items in the following categories:

Sub-Section 10 CFR 50.36(c)(3) states:

(3) Surveillance requirements. Surveillance requirements are requirements relating to test,

. calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed change will eliminate SR 3.8.1.20 because, following removal of the load test resistor banks, the SR will no longer be needed to assure that LCO 3.8.1.b and LCO 3.8.1.d regarding DG availability will be met. Loaded DG testing will continue to be performed by connecting the DG output to its associated "T" bus rather than the load test resistor bank. In this configuration SR 3.8.1.21 provides the required assurance that an actual or simulated ESF actuation signal would override the test mode by returning DG to ready-to-load operation; and verifying that the ESF loads are serviced by offsite power. Therefore, the proposed change will be consistent with the requiremen~s of 10 CFR 50.36.

10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants" The construction permits for CNP were issued and the majority of construction was completed prior to issuance of the 10 CFR 50, Appendix A, General Design Criteria, in 1971. CNP was designed to AEP-NRC-2019-18 Page 8 and constructed to comply with the Atomic Energy Commission (AEC) General Design Criteria (GDC) as proposed on July 10, 1967. The application of the AEC proposed GDC to the CNP is described in Section 1.4 of the CNP Updated Final Safety Analysis Report (UFSAR) as the Plant Specific Design Criteria (PSDC). The CNP PSDC differ both in numbering and content from the GDC of Appendix A to 10 CFR 50.

The PSDC that are applicable to the proposed deletion of SR 3.8.1.20 are as follows:

Criterion 38 "Reliability and Testability of Engineered Safety Features" "All Engineered Safety Features shall be designed to provide such functional reliability and ready testability as is necessary to avoid undue risk to the health and safety of the

  • public."*

Compliance with Criterion 38 will be maintained. The testability of the circuitry that ensures DG availability while connected to its 'T' bus will be preserved. Testing of that circuitry will continue to be required by SR 3.8.1.21. Testing of the circuitry in accordance with SR 3.8.20 will no longer be necessary because the load test resistor banks will have been removed.

Criterion 39 "Emergency Power

"An emergency power source shall be provided and designed with adequate

  • independency, redundancy, capacity, and testability to permit the functioning of the engineered safety features and protection systems required to avoid undue risk to the health and safety of the public. This power source shall provide this capacity assuming a failure of a single active component."

Compliance with Criterion 39 will be maintained. The proposed SR 3.8.1.20 deletion does not affect the DGs independency, redundancy, or capacity. As described above regarding Criterion 38, the testability of the DG will also be maintained. The UFSAR description of compliance with Criterion 39 includes a statement that "In addition, the diesel generators may be started and loaded to approximately fifty percent of rated load via the diesel generator load bank resistors for testing purposes." CNP design control processes will assure that, following NRC approval of the proposed SR 3.8.1.20 deletion, tliis statement, and other UFSAR references to load test bank resistors, will be modified in accordance with the CNP UFSAR update process to reflect removal of the load test resistor banks.

Therefore, the proposed change will be consistent with the requirements of the CNP PSDC.

Westinghouse Standard Technical Specifications SR 3.8.1.20 is a site-specific SR that was transitioned from the previous NUREG 1452 based CNP TS into the current NUREG 1431 based CNP TS during the site conversion to the Improved Standard TS. Since NUREG 1431 does not include an SR regarding DG load test resistor banks, deletion of SR 3.8.1.20 will not affect CNP conformance to NUREG 1431.

to AEP-NRC-2019-18 Page 9 Deletion of reference to SR 3.8.1.20 in the current SR 3.8.1.23 and SR 3.8.2.1 is an editorial change since SR 3.8.1.20 will be removed. Therefore conformance to NUREG 1431 will not be affected.

Existing CNP SR 3.8.1:21 conforms to SR 3.8.1.17 of NUREG 1431. Therefore, retaining CNP SR 3.8.1.21 will maintain conformance to NUREG 1431.

4.2 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, Renewed Facility Operating Licenses DPR-58 and DPR-74, proposes to amend the Unit 1 and Unit 2 Technical Specifications (TS) to delete Surveillance Requirement (SR)

  • 3.8.1.20, which requires verification *of Diesel Generator (DG) availability when connected to its load test resistor banks. l&M is proposing to delete this SR because l&M plans to remove the resistor banks, which are no longer operational and are no longer needed. The resistor banks are no longer needed because loaded DG testing is conducted by connecting them to their "T" buses rather than resistor banks. The assurance of DG availability in this configuration is provided by existing SR 3.8.1.21. l&M is also proposing conforming editorial changes_to _Unit 1 anq Unit 2 SR 3.8.1.23 and SR 3.8.2.1 to del_ete r~ference to SR 3.8.1.20.

l&M has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in Sub-Section (c) of 10 CFR 50.92, "Issuance of Amendment," as discussed below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed TS change involves deletion of an SR. The SR to be deleted verifies the availability of the DGs in a configuration that will no longer be possible. Neither the DGs nor the associated SR are accident initiators. The safety function of the DGs is to mitigate the consequences of an accident. The availability or unavailability of the DGs does not affect the likelihood that the accident they are designed to mitigate will occur. The presence or absence of the SR does not cause or prevent an accident from occurring. Therefore the probability of a previously evaluated accident will not be significantly increased.

The DGs are designed to mitigate the consequences of a previously evaluated accident.

The function of the SR to be deleted is solely to assure the availability of the DG when connected to its load test resistor bank. That configuration will no longer occur. The test conditions that will occur are addressed by another SR that is not affected by the proposed change. The unaffected SR will continue to provide assurance that the availability of the DG to mitigate the previously evaluated accident is not compromised when the DG is connected to the bus used for testing. Other systems, structures, and components required for the mitigation of an accident are unaffected by the proposed change.

Therefore, the proposed amendment

  • does not involve a significant increase in the probability or consequences of an accident previously evaluated.

to AEP-NRC-2019-18 Page 10

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No.

No new accident scenarios, failure mechanisms, or single failures will be introduced as a result of the proposed change to delete an SR. The proposed SR deletion will have no adverse effects on any safety-related systems or components and will not challenge the performance or integrity of any safety-related system. There will be no changes to the methods by which any safety-related plant system performs its safety function. The DG testing using grid and plant component loads does not involve operation of any structure, system, or component outside its established design boundaries. The proposed deletion of

  • an SR Will not involve a change in plant operational parameters: * * *
  • Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The margin of safety applicable to the proposed change is the amount by which the DGs exceed the minimum capability required for them to adequately mitigate the consequences of an accident. The capability of the DGs to adequately mitigate the consequences of an accident will be unaffected by the proposed SR deletion. Assurance of that capability will continue to be verified by SR 3.8.1.21, and the other DG related SRs.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

l&M therefore concludes that the proposed amendm~nts do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.3 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in to AEP-NRC-2019-18 Page 11 the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NRC NUREG-1431, "Standard Technical Specifications Westinghouse Plants," Revision 2, dated April 30, 2001, Agencywide Documents Access and Management System (ADAMS)

Accession No. ML011090393.

2.
  • Letter from Jack Donohew; NRC, to Mario K Nazar; l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments for the Conversion to the Improved Technical Specifications with Beyond Scope Issues," dated June 1, 2005, ADAMS Accession Number ML050620034.

Enclosure 3 to AEP-NRC-2019-18 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW PROPOSED CHANGES Pages 3.8.1-17 3.8.1-18 3.8.2-3

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.20 IDELETEDI NOTE

1. This SR is only required to be met when the applicable DG is connected to its load test resistor bank.
2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. Hmvever, portions of_ the Surveillance may be performed _

to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

In accordance Verify, with a DG operating in test mode and with the connected to its load test resistor bank, an actual or Surveillance simulated ESF actuation signal overrides the test Frequency mode by:_ Control Program

a. Returning DG to ready to load operation; and
b. Verifying the emergency loads are serviced by offsite pmr1er.

SR 3.8.1.21 ------------------------------N()TE-------------------------------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish

()PERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

a Verify, with DG operating in test mode and

  • In accordance connected to its bus, an actual or simulated ESF with the actuation signal overrides the test mode by: Surveillance Frequency
a. Returning DG to ready-to-load operation; and Control Program
b. Verifying the emergency loads are serviced by offsite power.

Cook Nuclear Plant Unit 1 3.8.1-17 Amendment No. ;;m+, ~ . 334

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.22 -.----------------------------N()TE-------------------------------

AII DG starts* may be preceded by an engine prelube period.

Verify when started simultaneously from standby In accordance condition, each DG achieves, in !:> 10 seconds, with the voltage ;:: 3910 V and frequency;:: 59.4 Hz. Surveillance Frequency Control Program SR 3.8.1.23 -----------------------------N()TES------------------------------

1. When Unit 2 is in M()DE 5 or 6, or moving irradiated fuel assemblies in the containment or auxiliary building, the following Unit 2 SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.15, SR 3.8.1.16, SR 3.8.1.17, and SR 3.8.1.18.
2. Unit 2 SR 3.8.1.9.a is only required to be met when the auxiliary source is supplying the required Unit 2 electrical power distribution subsystem.

For required Unit 2 AC sources, the SRs of Unit 2 In accordance Specification 3.8.1, except SR 3.8.1.9.b, with applicable SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal SRs portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable.

Cook Nuclear Plant Unit 1 3.8.1-18 Amendment No. 2-9-1-, W9, 334

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3:8.2.1 ------------------------------N.OTE-------------------------------

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, SR 3.8.1.15 through SR 3.8.1.17, and SR 3.8.1.18.

For AC sources required to be OPERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources -- Operating," with applicable except SR 3.8.1.9, SR 3.8,1.13, SR 3.8.1.14 (E_SF SRs actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable.

SR 3.8.2.2 One of the following SRs is applicable when the In accordance electrical distribution subsystem is being supplied by with applicable "backfeed" from an offsite source via the main SR transformer and a unit auxiliary transformer:

a. SR 3.8.1.9.a when the preferred offsite circuit is
b. SR 3.8.1.9.b when the alternate offsite circuit is required to be OPERABLE by LCO 3.8.2.a. *I I

Cook Nuclear Plant Unit 1 3.8.2-3 Amendment No. ~ . 304 Corrected by letter of 5/28/08

Enclosure 4 to AEP-NRC-2019-18 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW PROPOSED CHANGES Pages 3.8.1-17 3.8.1-18 3.8.2-3

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.20 IDELETEDI NOTE

1. This SR is only required to be met when the applicable DG is connected to its load test resistor bank.
2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. Hmvever, portions of the_ Surveillance may be_ performed _

to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

In accordance Verify, with a DG operating in test mode and with the connected to its load test resistor bank, an actual or Surveillance simulated ESF actuation signal overrides the test Frequency mode by: Control Program

a. Returning DG to ready to load operation; and
b. Verifying the emergency loads are serviced by offsite po1.Ner.

SR 3.8.1.21 ------------------------------N()TE-------------------------------

This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify, with a DG operating in test mode and In accordance connected to its bus, an actual or simulated ESF with the actuation signal overrides the test mode by: Surveillance Frequency

a. Returning DG to ready-to-load operation; and Control Program
b. Verifying the emergency loads are serviced by offsite power.

Cook Nuclear Plant Unit 2 3.8.1-17 Amendment No. 2-e-9, ~ . 316

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.1.22 ------------------------------N()TE-------------------------------

AII DG starts may be preceded by an engine prelube period.

Verify when started simultaneously from standby In accordance condition, each DG achieves, in :5 10 seconds, with the voltage ~ 3910 V and frequency~ 59.4 Hz. Surveillance Frequency.

Control Program SR 3.8.1.23 -----------------------------N()TES------------------------------

1. When Unit 1 is in M()DE 5 or 6, or moving irradiated fuel assemblies in the containment or auxiliary building, the following Unit 1 SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10, SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.15, SR 3.8.1.16, SR 3.8.1.17, and SR 3.8.1.18.
2. Unit 1 SR 3.8.1.9.a is only required to be met when the auxiliary source is supplying the required Unit 1 electrical power distribution subsystem.

For required Unit 1 AC sources, the SRs of Unit 1 In accordance Specification 3.8.1, except SR 3.8.1.9.b, with applicable SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal SRs portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable.

Cook Nuclear Plant Unit 2 3.8.1-18 Amendment No.~. 294, 316

AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ------------------------------N()TE------------------------------

The following SRs are* not required. to be performed:

SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, SR 3.8.1.15 through SR 3.8.1.17, and SR 3.8.1.18.

For AC sources required to be ()PERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources -- ()perating," with applicable except SR 3.8.1.9, S_R 3.8.1_.13, _SR 3.8.1.14 (ESF _ SRs actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, SR 3.8.1.21, and SR 3.8.1.22, are applicable.

SR 3.8.2.2 ()ne of the following SRs is applicable when the In accordance electrical distribution subsystem is being supplied by with applicable "backfeed" from an offsite source via the main SR transformer and a unit auxiliary transformer:

a. SR 3.8.1.9.a when the preferred offsite circuit is required to be ()PERABLE by LCO 3.8.2.a, or
b. SR 3.8.1.9.b when the alternate offsite circuit is required to be ()PERABLE by LCO 3.8.2.a.

Cook Nuclear Plant Unit 2 3.8.2-3 Amendment No. 200, 287 Corrected by letter of 5/28/08

Enclosure 5 to AEP-NRC-2019-18 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGES MARKED TO SHOW PROPOSED CHANGES (For Information Only)

Pages B 3.8.1-32 B 3.8.1-33 B 3.8.1-34 B 3.8.2-6

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.20 IDELETEDI Demonstration of the test mode o*ierride ensures that the DG availability under accident conditions \Nill not be compromised as the result of testing that involves connecting the DG to its test load resistor bank, and the DG will automatically reset to ready to load operation if a ESF actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

The requirement to automatically energize the emergency loads with offsite pmver is essentially identical to that of SR 3.8.1.13. The intent in the requirement associated with SR 3.8.1.20.b is to show that the emergency loading 111as not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing

. that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by tv10 Notes. Note 1 states that this Surveillance is only required to be met when the applicable DG is connected to its test load resistor bank. This is allowed since the test mode override only functions when the DG is connected to its associated test load resistor bank. When the DG is not connected to its associated test load resistor

. bank, the feature is not necessary; thus the Surveillance is not required to be met under this condition. The reason for Note 2 is that performing the Surveillance 1Nould remove a required DG from service, perturb the electrical distribution system, and challenge safety systems. This

  • restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing foilowing corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated Cook Nuclear Plant Unit 1 B 3.8.1-32 Revision No. 63

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced 1.vhen portions of the Surveillance are performed in MODE 1, 2, 3, or 4. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR SR 3.8.1.21 Dem6nstratic:in ofthe test mode override *ensures thatthe DG availability -

under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.13. The intent in the requirement associated with SR 3.8.1.21.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. I This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation Cook Nuclear Plant Unit 1 B 3.8.1-33 Revision No. 63

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as th_e operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1, 2, 3, or 4. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this.SR.

SR 3.8.1.22 This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

SR 3.8.1.23 With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.1.1 through SR 3.8.1.22) are applied to Unit 1 sources. This Surveillance is provided to direct that appropriate Surveillances for the required Unit 2 AC sources are governed by the applicable Unit 2 Technical Specifications. Performance of the applicable Unit 2 Surveillances will satisfy the Unit 2 requirements as well as satisfy this Unit 1 Surveillance Requirement. Exceptions are noted to the Unit 2 SRs of LCO 3.8.1. SR 3.8.1.9.b is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are not required to be met because the ESF actuation signal is not required to be OPERABLE. SR 3.8.1.22 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE.

The Frequency required by the applicable Unit 2 SR also governs performance of that SR for Unit 1 Cook Nuclear Plant Unit 1 B 3.8.1-34 Revision No. 63

AC Sources - Shutdown B 3.8.2 BASES SUREVEILLANCE REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4 to be applicable. SR 3.8.1.9 is not required to be met since the auxiliary source cannot power the Class 1E electrical power distribution-subsystems unless the subsystems are being powered via backfeed through the main transformer, and since only one offsite circuit is required to be OPERABLE. If the Class 1E electrical power distribution subsystems are being powered by backfeed, SR 3.8.1.9.a or SR 3.8.1.9.b is implemented by SR 3.8.2.2. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are not required to be met because the ESF actuation signal is not required to be OPERABLE*. SR 3.8.1.22* is excepted because starting independence is .

not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude de-energizing a required emergency 4.16 kV emergency bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent

  • that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

SR 3.8.2.2 SR 3.8.2.2 requires that SR 3.8.1.9.a or SR 3.8.1.9.b be met when the

. electrical distribution subsystem is being supplied by backfeed from an offsite source via the main transformer and a unit auxiliary transformer, i.e., the normal auxiliary circuit. SR 3.8.1.9.a and SR 3.8.1.9.b require, respectively, verification of the automatic transfer of each 4.16 kV emergency bus power supply from the normal auxiliary circuit to the preferred offsite circuit and verification of the manual alignment to the alternate required offsite circuit. These verifications demonstrate the OPERABILITY of the required offsite circuit to power the shutdown loads when the backfeed alignment is being used to supply the required electrical distribution subsystem.

REFERENCES None.

Cook Nuclear Plant Unit 1 B 3.8.2-6 Revision No. 45

Enclosure 6 to AEP-NRC-2019-18 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGES MARKED TO SHOW PROPOSED CHANGES (For Information Only)

Pages B 3.8.1-31 B 3.8.1-32 B 3.8.1-34 B 3.8.2-6

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (Continued)

This SR is modified by two Notes. The reasonfor Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing,

  • the DGs must be started from standby conditions, that is, with the engine
  • coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that the performance of the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope wit.h these outcomes. These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when portions of the Surveillance are performed fn MODE 1, 2, 3, or 4. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

SR 3.8.1.20 !DELETED!

Demonstration of the test mode override ensures that the DG availability under accident conditions ,Nill not be compromised as the result of testing that involves connecting the DG to its test load resistor bank, and the DG will automatically reset to ready to load operation if a ESF actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage with the DG output breaker open.

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR. 3.8.1.13. The intent in the requirement associated with SR. 3.8.1.20.b is to shm.v that the*

emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that Cook Nuclear Plant Unit 2 B 3.8.1-31 Revision No. 60

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) adequately shows the capability of the emergency loads to p~rform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by tiNo Notes: Note 1 states that this Surveillance is

  • only required to be met when the applicable DG is connected to its test load resistor bank. This is allov.*ed since the test mode override only functions when the DG is connected to its associated test load resistor bank. VVhen the DG is not connected to its associated test load resistor bank, the feature is not necessary; thus the Surveillance is not required to be met under this condition. The reason for Note 2 is that performing the Surveillance would remove a required DG from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1, 2, 3, or 4 is further amplified to allm.v portions of the -surveillance to be*
  • performed for the purpose of reestablishing OPERABILITY (e.g., post work testing follmving corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as 1Nell as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdo'lm and startup to determine that unit safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1, 2, 3, or 4. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR-,-

SR 3.8.1.21 Demonstration of the test mode override ensures that the DG availability under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA actuation signal is received during operation in the test mode. Ready to load operation is defined as the DG running at rated speed and voltage Cook Nuclear Plant Unit 2 B 3.8.1-32 Revision No. 60

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations.

SR 3.8.1.23 With the exception of this Surveillance, all other Surveillances of this Specification (SR 3.8.1.1 through SR 3.8.1.22) are applied to Unit 2 sources. This Surveillance is provided to direct that appropriate Surveillances for the required Unit 1 AC sources are governed by the applicable Unit 1 Technical Specifications. Performance of the applicable Unit 1 Surveillances will satisfy the Unit 1 requirements as well as satisfy this Unit 2 Surveillance Requirement. Exceptions are noted to the Unit 1 SRs of LCO 3.8.1. SR 3.8.1.9.b is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only}, SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are not required to be met because the ESF actuation signal is not required to be OPERABLE. SR 3.8.1.22 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE.

The Frequency required by the applicable Unit 1 SR also governs performance of that SR for Unit 2.

As noted (Note 1 to SR 3.8.1.23), if Unit 1 is in MODE 5 or 6, or moving irradiated fuel assemblies, SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, SR 3.8.1.14 through SR 3.8.1.17, *and SR 3.8.1.18 are not required to be performed. This ensures that this Unit 2 SR will not require a Unit 1 SR to be performed, when the Unit 1 Technical Specifications exempts performance of a Unit 1 SR (however, as stated in the Unit 1 SR 3.8.2.1 Note 1, while performance of an SR exempted, the SR must still be met).

As noted (Note 2 to SR 3.8.1.23), SR 3.8.1.9.a is only required to be met when the auxiliary source is supplying the Unit 1 electrical power distribution subsystem since the preferred offsite source is required to support Unit 2 operations.

2. UFSAR, Section 8.3.

Cook Nuclear Plant Unit 2 B 3.8.1-34 Revision No. 60

AC Sources - Shutdown B 3.8.2 SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4 to be applicable. SR 3.8.1.9 is not required to b-e met since the auxiliary source cannot power the Class 1E electrical power distribution subsystems unless the subsystems are being powered via backfeed through the main transformer, and since only one offsite circuit is required to be OPERABLE. If the Class 1E electrical power distribution subsystems are being powered by backfeed, SR 3.8.1.9.a or SR 3.8.1.9.b is implemented by SR 3.8.2.2. SR 3.8.1.13, SR 3.8.1.14 (ESF actuation signal portion only), SR 3.8.1.19, SR 3.8.1.20, and SR 3.8.1.21 are not required to be met because the ESF actuation sigrialis- not require-d to be OPERABLE. SR 3.8.1.22 is excepted because starting independence is not required with the DG(s) that is not required to be OPERABLE. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite power network or otherwise rendered inoperable during performance of SRs, and to preclude de-energizing a required emergency 4.16 kV emergency bus or disconnecting a required offsite circuit during performance of SRs. With limited AC sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

SR 3.8.2.2 SR 3.8.2.2 requires that SR 3.8.1.9.a or SR 3.8.1.9.b be met when the electrical distribution subsystem is being supplied by backfeed from an offsite source via the main transformer and a unit auxiliary transformer, i.e., the normal auxiliary circuit. SR 3.8.1.9.a and SR 3.8.1.9,b require, respectively, verification of the automatic transfer of each 4.16 kV emergency bus power supply from the normal auxiliary circuit to the preferred offsite circuit and verification of the manual alignment to the alternate required offsite circuit. These verifications demonstrate the OPERABILITY of the required offsite circuit tb power the shutdown loads when the backfeed alignment is being used to supply the required electrical distribution subsystem.

REFERENCES None.

Cook Nuclear Plant Unit 2 B 3.8.2-6 Revision No. 43

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