AEP-NRC-2020-61, Unit 2, Supplement to the Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable

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Unit 2, Supplement to the Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable
ML20307A102
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/27/2020
From: Lies Q
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2020-61
Download: ML20307A102 (17)
v • d • e


Text

m INDIANA lndlana Michigan Power MICHIGAN Cook Nuclear Plant JIOWEll* One Cook Placa Bndgmen, Ml 49106 A unrt ofAmencan BfJCtnc Power lnd1anaM1ch1ganPowar com October 27, 2020 AEP-NRC-2020-61 10 CFR 50.90 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant, Unit 1 and Unit 2 Supplement to the Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable."

Reference:

Indiana Michigan Power Company Letter, "Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable,"" April 2020 (ADAMS Accession No. ML20126G454).

By the above Reference, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP), submitted a request for an amendment to Technical Specifications (TS) for CNP Unit 1 and Unit 2 to implement TSTF-412, in accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR).

The Reference proposed an amendment that establishes Conditions, Required Actions, and Completion Times, in the Standard Technical Specifications (STS) for the Condition where one steam supply to the turbine driven Auxiliary Feedwater (AFW) pump is inoperable concurrent with an inoperable motor driven AFW train. This supplement to the Reference submittal discusses a variation that was not explicitly noted in the Reference and fixes formatting issues.

The CNP Unit 1 licensing basis does not include analysis of the Feedwater Line Break (FLB) accident.

This variation was not explicitly noted in the Reference but is reflected in the CNP Unit 1 Technical Specification Bases (submitted with the Reference for information only). Section 14.2.8 of the CNP Unit 1 Updated Final Safety Analysis Report also reflects that no FLB accident analysis is applicable for the CNP Unit 1 licensing basis. CNP is not proposing any change to the Unit 1 Licensing Basis for FLB.

U. S. Nuclear Regulatory Commission AEP-NRC-2020-61 Page 2 provides an affirmation statement pertaining to the information contained herein. provides existing Unit 1 Technical Specifications (TS) pages marked up to show the proposed changes with corrections made for this supplement. The indentation was changed in new REQUIRED ACTION C.1 and C.2 to match the existing formatting. The original markups from the Reference are shown underlined in red. A blue box denotes the correction made in this supplement.

Enclosures 3 and 4 provide existing Unit 1 and Unit 2 liS Bases pages, respectively, marked up to show the proposed changes with updates for this supplement. The original markups from the Reference are shown underlined in red. A blue box denotes the correction made in this supplement.

For Unit 1, a period is added to the end of the last paragraph of Actions C.1 and C.2. For Unit 2, 'the word "pumps" is added at the end of the first paragraph of Actions C.1 and C.2. TS Bases markups are included for information only. Changes to the existing TS Bases will be implemented under TS 5.5.12, "Technical Specifications Bases Control Program."

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

Sincerely, tJ~A E2 Lnelies Site Vice President DLW/mll

Enclosures:

1. Affirmation
2. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes and Supplement Correction
3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked To Show Proposed Changes and Supplement Correction (For Information Only)
4. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked To Show Proposed Changes and Supplement Correction (For Information Only)

U. S. Nuclear Regulatory Commission AEP-NRC-2020-61 Page 3 c: R. J. Ancona - MPSC EGLE - RMD/RPS J. B. Giessner - NRC Region Ill D. L. Hille - AEP Ft. Wayne, w/o enclosures NRC Resident Inspector R. M. Sistevaris - AEP Ft. Wayne, w/o enclosures S. P. Wall - NRC, Washington, D.C.

A. J. Williamson -AEP Ft. Wayne, w/o enclosures

Enclosure 1 to AEP-NRC-2020-61 Affirmation I, Q. Shane 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 Q.SZ~At:i Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS d. 7 DAY oF Oc.A::o 'be.c 2020 My Commission Expires rJ -d O -;loc2 S-

,.... '\ .....

t.. I * ...,_

"  : r

Enclosure 2 to AEP-NRC-2020-61 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked to Show Proposed Changes and Supplement Correction 3.7.5-1 3.7.5-2 3.7.5-3

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE .

N OT E--------------------------------------------

0 n ly one AFW train , which includes a motor driven pump, is required to be OPERABLE in MODE 4 .

APPLICABILITY : MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

NOTE------------------------------------------------------------

L CO 3.0.4 .b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected equipment 7 days train inoperable due to to OPERABLE status.

one inoperable steam AND fil!Q.P!y. One steam supply to turbine driven 10 days from AFVV pump inoperable. discovery of failure to meet the LCO OR

NOTE------------

0 n ly applicable if MODE 2 has not been entered following refueling.

Turbine driven AFW pump inoperable in MODE 3 following refueling.

Cook Nuclear Plant Unit 1 3.7.5-1 Amendment No. ~

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable in MODE 1, OPERABLE status .

2, or 3 for reasons other AND than Condition A.

10 days from discovery of failure to meet the LCO C. Turbine driven AFW C.1 Restore the steam su1212ly 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train ino12erable due to to the turbine driven train to one ino12erable steam OPERABLE status.

SUQQly.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW train to OPERABLE train ino12erable. status.

GQ. Required Action and GQ. 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 fGf-of Condition A , AND

§., or BS2_not met.

GQ.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

GE. Three AFW trains GE .1 --------------NOTE--------------

inoperable in MODE 1, LCO 3.0 .3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately AFW train to OPERABLE status.

Cook Nuclear Plant Unit 1 3.7 .5-2 Amendment No. ~ .~

AFW System 3.7.5 CONDITION REQUIRED ACTION COMPLETION TIME

[. Required AFW train [.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------NOTE------------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control , if it is capable of being manually realigned to the AFW mode of operation .

Verify each required AFW manual , power operated , In accordance and automatic valve in each water flow path , and in with the both steam supply flow paths to the steam turbine Surveillance driven pump , that is not locked , sealed , or otherwise Frequency secured in position , is in the correct position . Control Program SR 3.7.5.2 ------------------------------- NOTE------------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after ~ 850 psig in the steam generator.

Verify the developed head of each required AFW In accordance pump at the flow test point is greater than or equal with the to the required developed head . INSERVICE TESTING PROGRAM SR 3.7.5.3 -------------------------------NOTES----------------------------

1. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control , if it is capable of being manually realigned to the AFW mode of operation.
2. Only required to be met in MODES 1, 2, and 3.

Cook Nuclear Plant Unit 1 3.7.5-3 Amendment No. 2-&7, JJ4.

Enclosure 3 to AEP-NRC-2020-61 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked to Show Proposed Changes and Supplement Correction (For Information Only)

B3.7.5-4 B3.7.5-5 B3.7.5-6 83.7.5-7

AFW System B 3.7.5 BASES LCO (continued)

The AFW System is configured into three trains. The AFW System is cons idered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.

This requires that the two motor driven AFW pumps be OPERABLE in two independent discharge paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of two main steam lines upstream of the SGSVs, and shall be capable of supplying AFW to all of the steam generators . The piping , valves , instrumentation , and controls required to perform the safety related function also are required to be OPERABLE.

The LCO is modified by a Note indicating that only one AFW train , which includes a motor driven pump, is required to be OPERABLE in MODE 4.

This is because of the reduced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump.

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition , the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions .

In MODE 4 the AFW System may be used for heat removal via the steam generators.

In MODE 5 or 6, the steam generators are not normally used for heat removal , and the AFW System is not required .

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components , should not be applied in this circumstance .

A.1 If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply , or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling , action must be taken to restore the Cook Nuclear Plant Unit 1 B 3.7.5-4 Revision No. 0

AFW System B 3.7.5 BASES ACTIONS (continued) inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable , based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events .
b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling , the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation .
c. For both the inoperability of a steam supply line to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage , the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps , and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO .

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling . Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refuel ing and prior to the reactor being critical.

B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the Cook Nuclear Plant Unit 1 B 3.7.5-5 Revision No. 63

AFW System B 3.7.5 loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System , the time needed for repairs, and the low probability of a DBA occurring during this time period .

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO .

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Assuming no single active failures when in this condition , the accident (a MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG . In this condition , the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the analysis requiring flow from two AFW pumps .

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump , and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pum[J D.1 and D.2 When Required Action A.1 i e-F B.1, C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The allowed Completion Times are reasonable , based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Cook Nuclear Plant Unit 1 B 3.7.5-6 Revision No. 63

AFW System B 3.7. 5 BASES ACTIONS (continued)

In MODE 4 with two AFW trains inoperable , operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required ,

the unit may continue to cool down and initiate RHR.

GE .1 If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown , and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition , the unit should not be perturbed by any action , including a power change , that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status .

Required Action GE.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition .

In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation . This is addressed in LCO 3.4.6, "RCS Loops - MODE 4 ." With one required AFW train inoperable , action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6 .

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual , power operated , and automatic valves in the required AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation . Verification of the AFW System water supply flow path includes both the suction (either a flow path from the CST or the Essential Service Water (ESW) System) and discharge flow paths. This SR does not apply to valves that are locked , sealed , or otherwise secured in position , since they are verified to be in the correct position prior to locking , sealing , or securing. This SR also does not apply to valves that cannot be inadvertently misaligned , such as check valves. This Surveillance does not require any testing or valve manipulation ; rather, it involves verification that those valves capable of being mispositioned are in the correct position .

Cook Nuclear Plant Unit 1 B 3.7.5-7 Revision No. 63

Enclosure 4 to AEP-NRC-2020-61 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked to Show Proposed Changes and Supplement Correction (For Information Only) 83.7.5-5 83.7.5-6 83.7.5-7

AFW System B 3.7.5 BASES ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components , should not be applied in this circumstance.

A.1 If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply , or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling , action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable , based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply , the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events .
b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling , the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation .
c. For both the inoperability of a steam supply line to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO .

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 10 days Cook Nuclear Plant Unit 2 B 3.7.5-5 Revision No. 0

AFW System B 3.7.5 BASES ACTIONS (continued) dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling . Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable , based on the redundant capabilities afforded by the AFW System , the time needed for repairs ,

and the low probability of a OBA occurring during this time period .

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO .

The 10 day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG . In this condition , the AFW system may no Ion er be able to meet the re uired flow to the SGs assumed in the safet anal sis due to the anal sis re uirin flow from two AF Cook Nuclear Plant Unit 2 B 3.7.5-6 Revision No . 0

AFW System B 3.7.5 BASES ACTIONS (continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the rema ining OPERABLE steam supply to the turbine driven AFW pump , the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump.

D.1 and D.2 When Required Action A.1 , Gf 8 .1, C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The allowed Completion Times are reasonable , based on operating experience , to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required ,

the unit may continue to cool down and initiate RHR.

GE .1 If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown , and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition , the unit should not be perturbed by any action , including a power change , that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status .

Required Action G!;,.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status . In this case , LCO 3.0.3 is not applicable because it could force the unit into a less safe condition .

In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status . The immediate Completion Time is consistent with LCO 3.4.6.

Cook Nuclear Plant Unit 2 B 3.7.5-7 Revision No . 0

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