ML071910354

Donald C. Cook, Units 1 and 2 - License Amendment Request to Revise Technical Specifications Associated with Generic Letter 2004-02

ML071910354
Person / Time
Site:	Cook
Issue date:	06/27/2007
From:	Jensen J N Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:7036, GL-04-002
Download: ML071910354 (51)

Text

INDIANA MICHIGAN POWERO A unit of American Electric Power Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, MI 49106 AEPcom AEP:NRC:7036 10 CFR 50.90 June 27, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-Pl-17 Washington, DC 20555-0001

SUBJECT:

Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Amendment Request to Revise Technical Specifications Generic Letter .(GL) 2004-02 Associated with

Reference:

Letter from J. N. Jensen, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission Document Control Desk, "Nuclear Regulatory Commission Generic Letter 2004-02 -Information Requested by September 1, 2005," AEP:NRC:5054-11, dated August 31, 2005, ADAMS Accession No. ML052510512.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, proposes to amend Facility Operating Licenses DPR-58 and DPR-74. The proposed amendment supports resolution of Nuclear Regulatory Commission Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors." I&M proposes to revise Technical Specification (TS) 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," to include containment recirculation sump level instrumentation which will be used for indication of recirculation sump strainer blockage.

Additionally, I&M proposes to revise TS 3.5.2, "ECCS -Operating," by replacing the term "trash racks and screens" with the more descriptive term,"strainers." Finally, I&M proposes to revise TS 3.6.14, "Containment Recirculation Drains," to include Limiting Conditions for Operation, Actions, and Surveillance Requirements to ensure the operability of flow paths credited in the evaluation of potential adverse effects of post-accident debris on the containment recirculation function pursuant to GL 2004-02.I&M requests approval of the proposed amendment no later than October 1, 2007, for Unit 2 and no later than April 1, 2008, for Unit 1. I&M requests that implementation of the proposed amendment for Unit 2 and Unit 1 be required prior to entry into operational Mode 4 following completion of the Fall 2007 refueling outage and Spring 2008 refueling outage, respectively.

A,/I /(.-.. P -V U. S. Nuclear Regulatory Commission AEP:NRC:7036 Page 2 Enclosure 1 to this letter provides an affirmation statement pertaining to the proposed amendment.

Enclosure 2 provides I&M's evaluation of the proposed TS changes. Attachments IA and lB provide TS pages marked to show changes for Unit 1 and Unit 2, respectively.

Attachments 2A and 2B provide TS pages with the proposed changes incorporated.

Attachment 3 of this letter provides Unit 1 Bases pages marked to show planned changes in support of the proposed TS changes. These Bases pages are provided for information.

The planned changes to the Unit 2 Bases are similar to the planned Unit 1 Bases changes. The Bases changes will be implemented in accordance with the CNP Bases control program.This letter contains no new regulatory commitments.

Copies of this letter and its attachments 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.Should you have any questions, please contact Ms. Susan D. Simpson, Regulatory Affairs Manager, at (269) 466-2428.Sincerely,.Jensen Site Vice President

Enclosures:

1. Affirmation

2. Proposed Technical Specification Changes and Evaluation Attachments:

1A. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Changes lB. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Changes 2A. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages With the Proposed Changes Incorporated 2B. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages With the Proposed Changes Incorporated

3. Information Copy of the Unit 1 Technical Specification Bases Changes in Support of the Proposed TS Changes U. S. Nuclear Regulatory Commission AEP:NRC:7036 Page 3 c: J. L. Caldwell, NRC Region III K. D. Curry, AEP Ft. Wayne, w/o enclosures/attachments J. T. King, MPSC MDEQ -WHMD/RPMWS NRC Resident Inspector P. S. Tam, NRC Washington, DC Enclosure 1 to AEP:NRC:7036 AFFIRMATION I, Joseph N. Jensen, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.Indiana Michigan Power Company Joseph N. Jensen Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS )T--DAY OF ,iTn6 ,2007 My Commission Expires 4'Enclosure 2 to AEP:NRC:7036 Proposed Technical Specification Changes and Evaluation Documents referenced in this attachment are identified in Section 7.0.

1.0 DESCRIPTION

Pursuant to 10 CFR 50.90, Indiana Michigan Power Company, (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, proposes to amend Facility Operating Licenses DPR-58 and DPR-74. The proposed amendment supports resolution of Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors." I&M proposes to revise Technical Specification (TS) 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," to include containment recirculation sump' level instrumentation which will be used for indication of recirculation sump strainer blockage.Additionally, I&M proposes to revise TS 3.5.2, "ECCS -Operating," by replacing!

the term"trash racks and screens" with the more descriptive term, "strainers." Finally, I&M proposes to revise TS 3.6.14, "Containment Recirculation Drains," to include Limiting Conditions for Operation (LCOs), Actions, and Surveillance Requirements to ensure the operability;'of flow paths credited in the evaluation of potential adverse effects of post-accident debris on the containment recirculation function pursuant to GL 2004-02.2.0 PROPOSED TS CHANGES I&M proposes to revise Unit 1 and Unit 2 TS Table 3.3.3-1, "Post Accident Monitoring (PAM)Instrumentation," to add a new Function 25, "Containment Recirculation Sump Water Level." This Function will have two Required Channels, and will reference Condition "G" from Required Action F. 1.I&M proposes to revise Unit 1 and Unit 2 TS 3.5.2, "ECCS -Operating," Surveillance Requirement 3.5.2.7 to replace the term "trash racks and screens" with the term "strainers." I&M proposes to revise Unit 1 and Unit 2 TS LCO 3.6.14, "Containment Recirculation Drains," to include additional flow paths that must be operable in Modes 1, 2, 3, and 4. The additional flow paths are those associated with the floor drains in the Containment Air Recirculation/Hydrogen Skimmer System (CEQ) fan rooms, and those associated with holes in the flood-up overflow wall separating the reactor coolant loop compartment and the containment annulus (pipe tunnel). I&M also proposes to revise the Actions to include two additional Conditions and associated Required Actions and Completion Times. The two additional Conditions are one required CEQ fan room drain inoperable, and one flood-up overflow wall flow path inoperable.

The Required Actions for both these new Conditions is to restore Enclosure 2 to AEP:NRC:7036 Page 2 operability of the respective flow path. The associated Completion Times for both Actions is one hour.I&M proposes to revise Unit 1 and Unit 2 TS 3.6.14 to include four additional Surveillance Requirements.

The four additional Surveillance Requirements are to: Verify, by visual inspection, that no debris is present in the CEQ fan rooms that could obstruct the required CEQ fan room drains and that the required drain line debris interceptors are not obstructed by debris. The proposed Frequency is prior to entering Mode 4 from Mode 5, and after personnel entry into a CEQ fan room in Modes 1 through 4.Verify for each CEQ fan room drain line that the: " Drain line debris interceptor is installed.

o Drain line debris interceptor shows no evidence of structural distress.* Pipe tunnel (annulus) sump flow opening is not obstructed (Unit 1).-o Containment sump flow opening is not obstructed (Unit 2).The proposed Frequency is 24 months.Verify, by visual inspection, that no debris is present in the lower containment that could obstruct the flood-up overflow wall flow paths and that the flow paths are not obstructed by debris. The proposed Frequency is prior to entering Mode 4 from Mode 5, and after personnel entry into lower containment in Modes 1 through 4.Verify, by visual inspection, that the flood-up overflow wall debris interceptor is installed and is free of structural distress.

The proposed Frequency is 24 months.Attachments IA through 2B of this letter provide the Unit 1 and Unit 2 TS pages marked to show the proposed changes and the TS pages with the proposed changes incorporated.

Attachment 3 of this letter provides the Unit 1 Bases pages marked to show the planned changes in support of the proposed TS changes. The planned changes to the Unit 2 Bases are similar to the planned Unit 1 Bases changes. These Bases pages are provided for information.

Bases changes associated with this proposed amendment will be implemented in accordance with the CNP Bases control program.

Enclosure 2 to AEP:NRC:7036 Page 3

3.0 BACKGROUND

In GL 2004-02 (Reference 1), the NRC requested that addressees perform a mechanistic evaluation, using an NRC-approved methodology, of the potential for the adverse effects of post-accident debris blockage and operation with debris-laden fluids to impede or prevent the recirculation functions of the emergency core cooling systems (ECCS) and the containment spray system (CTS) in a pressurized water reactor. The NRC requested that addressees provide information regarding the mechanistic evaluation and the plant modifications needed for compliance with the applicable regulatory requirements.

I&M's updated response (Reference 2)to GL 2004-02 stated that the existing recirculation sump strainer (grating, mesh screen, auxiliary steel) inside the crane wall will be replaced with a strainer (main strainer), and a new remote strainer will be installed in the annulus area between the crane wall and containment wall. The new remote strainer will be connected to the existing recirculation sump via a rectangular stainless steel duct waterway.

These plant modifications are shown in the sketch onPage 14 of this enclosure.

Reference 2 also described other modifications including the addition of two level instruments in the containment recirculation sump and the installation of debris interceptors in various locations in the containment including on top of the three CEQ fan room drains and in front of the flood-up overflow wall flow paths.System Descriptions and Current TS Requirements The systems involved in the proposed amendment are the PAM system, the ECCS and CTS systems, and the Containment Recirculation Drains. These systems and their current TS requirements are described below.3.1 PAM Instrumentation The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations.

This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for the safety systems to accomplish their safety functions for Design Basis Accidents (DBAs). The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined.

As defined in TS Table 3.3.3-1, the current PAM instrumentation requirements include twenty-four variables required by the operators during accident situations.

Containment water level is a monitored variable.

However, the current PAM instrumentation does not include a variable that has been found necessary to address the GL 2004-02 concerns at CNP. The variable is containment recirculation sump water level. If the water level drops to an undesirable level during the recirculation phase of an accident, it would indicate excessive fouling or blockage of the sump strainers.

Enclosure 2 to AEP:NRC:7036 Page 4 3.2 ECCS System The function of the ECCS system is to provide core cooling and negative reactivity to ensure that the reactor core is protected after any of a series of postulated accidents.

There are three phases of ECCS operation:

injection, cold leg recirculation, and hot leg recirculation.

In the injection phase, water is taken from the refueling water storage tank (RWST) and injected into the Reactor Coolant System through the cold legs. When sufficient water is removed from the RWST to ensure that enough boron has been added to maintain the reactor subcritical and the containment sumps have enough water to supply the required net positive suction head to the ECCS pumps, suction is switched to the containment recirculation sump for cold leg recirculation.

ECCS flow is later shifted to hot leg recirculation phase to provide a backflush in order to minimize the potential for boron precipitation.

The original design of the CNP containment recirculation sump.included grating, mesh screen, and auxiliary steel at the face of the recirculation sump. This was designed to prevent debris from entering the sump and adversely impacting downstream systems.TS 3.5, Surveillance Requirement 3.5.2.7, requires verification, by visual inspection, that each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet trash racks and screens show no evidence of structural distress or abnormal corrosion.

The terminology "trash racks and screens" reflects standard terminology used in NUREG 0452, upon which the original CNP TS were based. However, the trash rack and screen assembly is being replaced with a new pocket strainer design, and a remote strainer.

Although the new design for both the main and remote strainers maintain both the trash rack and screen functions, the term"strainer" has been applied to this design in the TS of other nuclear plants.3.3 Containment Recirculation Drains The Containment Recirculation Drains are a subsystem of the Containment System and currently include the ice condenser drains and the refueling canal drains. Twenty-one ice condenser drains function to drain melted ice from the ice condenser to the lower compartment following a DBA.The three refueling canal drains are at the low point in the refueling canal and function as the main return path to the lower compartment for CTS water sprayed into the upper compartment during a DBA. The ice condenser drains and the refueling canal drains function with the ice bed, the CTS, and the ECCS to limit the pressure and temperature in containment that could be expected following a DBA.TS LCO 3.6.14 currently requires that the ice condenser floor drains and two refueling canal drains shall be operable.

However, the TSs do not recognize the function of the CEQ fan room drains or the flood-up overflow wall flow paths in returning CTS flow from the CEQ fan rooms to the lower compartment or in providing a communication path between the loop compartment inside the crane wall and the annulus outside the crane wall.

Enclosure 2 to AEP:NRC:7036 Page 5 4.0 TECHNICAL ANALYSIS A technical analysis for each of the changes to the TS is provided in the following sections.4.1 PAM Instrumentation The proposed license amendment revises Unit 1 and Unit 2 TS Table 3.3.3-1, "Post Accident Monitoring (PAM) Instrumentation," to add a new Function 25, "Containment Recirculation Sump Water Level." The new Function 25 is needed because I&M is installing new containment recirculation sump level instruments.

As described in Reference 2, these instruments will provide indication and alarm function if the water level in the sump drops to an undesirable level.The selected level setting will provide advanced warning of potential air entrainment due to vortexing, which is more limiting for the CNP ECCS and CTS pumps than the loss of net positive suction head. System redundancy is provided by having two required channels (NLI-300 and NLI-301).

The requirement for two operable channels provides protection from a single failure causing a complete loss of function.Regulatory Guide 1.97 (Reference

3) describes a method acceptable to the NRC staff for complying with the NRC's regulations to provide instrumentation to monitor plant variables and systems during and following an accident in a light-water-cooled nuclear power plant. As stated in Regulatory Guide 1.97, Type A variables are those that provide primary information needed to permit the control room operating personnel to take the specified manually controlled actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accidents.

The new Containment Recirculation Sump Water Level function will be a Type A variable monitored by a Category 1 instrument, provided for diagnosis of excessive fouling or blockage of the sump strainers.

The two new redundant, safety-related level switches, to be installed in the containment recirculation sump, will provide indication and alarm in the main control room as advance warning of potential air entrainment prior to indication of degraded pump flow or motor amp oscillation.

The level switches each have a white light to indicate recirculation sump level is adequate and a red light to indicate that recirculation sump level is low. Red and white indicating lights will be installed on the containment water level sub-panel of the Residual Heat Removal System panel in the main control room. The system is armed when level in the sump rises and the white light is actuated.

After arming, level dropping below the low level setpoint will result in the associated red light on and a common annunciator alarming on the control room panel.The safety-related level switches were installed in Unit 1 during the Fall 2006 refueling outage and will be installed in Unit 2 during the Fall 2007 refueling outage.The level switches and conduit seal assemblies are environmentally qualified for a post-DBA harsh environment in containment in accordance with IEEE-323-1974 (Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations).

Components associated with the Enclosure 2 to AEP:NRC:7036 Page 6 level switches are seismically qualified in accordance with IEEE-344-1975 (Recommended Practice for Seismic Qualification of Class lE Equipment for Nuclear Power Generating Stations).

The two level channels are fed from separate Class IE power 120 volt alternating current power supplies.The existing TS 3.3.3 LCO, Applicability, Actions, and Surveillance Requirements will apply to the new Containment Recirculation Sump Water Level function.

Existing Action A.1 will require that an inoperable Containment Recirculation Sump Water Level channel be restored to operable status within 30 days. In the unlikely event that an inoperable channel cannot be restored to operable status within 30 days, TS 5.6.6 would require submittal of a report within 14 days outlining the pre-planned alternative method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the function to operable status. If both Containment Recirculation Sump Water Level channels are inoperable, existing Action D.1 will require that one channel be restored to operable status within 7 days. If one channel is. not restored to operable status within 7 days, existing Actions F. 1 and G. 1 will require that the unit be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.4.2 ECCS System The proposed license amendment revises Unit 1 and Unit 2 TS 3.5.2 (ECCS -Operating)

Surveillance Requirement 3.5.2.7 to replace the term "trash racks and screens" with the more descriptive term "strainers." The original sump screen design consists of two sections of 1 inch by 4 inch grating that"sandwiches" a 1/4 inch by 1/4 inch mesh stainless steel screen. The grating functions as a trash rack to prevent large debris from damaging the screen mesh and provides structural support. The screen mesh provides the fine debris removal function.

The existing screen area is approximately 85 square feet (Rt 2).As described in Reference 2, I&M is replacing the existing recirculation sump grating and mesh screen with a new main strainer assembly.

The new main strainer assembly was installed in Unit 1 during the Fall 2006 refueling outage. The new main strainer assembly will be installed in Unit 2 during the Fall 2007 refueling outage. A remote strainer is also being installed in the annulus region between the crane wall and containment wall. The new remote strainer assembly will be installed in Unit 1 during the Spring 2008 refueling outage. The new remote strainer assembly will be installed in Unit 2 during the Fall 2007 refueling outage. The new main and remote strainers are designed and fabricated by Control Components Incorporated (CCI). The pocket type strainers provided by CCI integrally combine the screen and trash rack functions for the recirculation sump. The reinforced front of the new CCI strainers functions as the trash rack.Recessed pockets provide the screen function.

The nominal size of the openings in the new main and remote strainers is approximately 1/12 inch to approximately 3/32 inch. The total surface area of the new main strainers is approximately 900 ft 2.The total surface area of the new remote strainers is expected to be between 1000 ft 2 and 1100 ft 2.

Enclosure 2 to AEP:NRC:7036 Page 7 The proposed TS change is editorial in that the new strainer performs the trash rack function and the screen function.

Inspection of the sump components for debris accumulation and structural integrity will continue to be performed.

The more general TS wording is being implemented as a clarification and for consistency with terminology used at other plants. The proposed TS wording has no effect on the underlying intent of the TS Surveillance Requirement, which is to ensure that the containment sump and its components are capable of performing their design function.4.3 Containment Recirculation Drains The proposed amendment revises Unit 1 and Unit 2 TS 3.6.14, "Containment Recirculation Drains," to assure the availability of two flow paths needed to provide an adequate water level in the ECCS recirculation sump following a loss of coolant accident (LOCA). The two flow paths provide water to the sump via the CEQ fan room drains and the flood-up overflow wall holes. As described below, these flow paths are needed in addition to the ice condenser floor drains and refueling canal drains that are the subject of existing TS 3.6.14.As requested by the NRC in GL 2004-02, I&M is performing a mechanistic evaluation,using an NRC-approved methodology, of the potential for the adverse effects of post-accident debris blockage and operation with debris-laden fluids to impede or prevent the recirculation functions of the ECCS and the CTS. As described in I&M's August 31, 2005, response (Reference

4) to GL 2004-02 and I&M's June 27, 2006, update (Reference

2) to that response, the requested evaluation, termed the "refined analysis," is being performed in accordance with the Nuclear Energy Institute Guidance Report (GR) and associated NRC Safety Evaluation Report (SER)published jointly as Volume 1 and Volume 2 of Reference

5. The refined analysis will address the technical issues involved in resolution of thel GL 2004-02 concerns at CNP, including debris generation and distribution, debris transport, and head loss across the new strainers during the recirculation phase of a LOCA. As documented in Reference 6, I&M will submit the results of the refined analysis to the NRC no later than December 31, 2007.The refined analysis will credit the CEQ fan room drains and the flood-up overflow wall hole flow paths, in addition to crediting the ice condenser floor drain and refueling canal drain flow paths that already have an associated TS LCO (LCO 3.6.14). In accordance with 10 CFR 50.36(c)(2)(ii)(C), Criterion 3, a TS LCO is required for the additional flow paths because they will be part of the primary success path and function to mitigate a LOCA.Accordingly, I&M is proposing to add the CEQ fan room drains and flood-up overflow wall flow paths to the components that are required to be operable by TS LCO 3.6.14.I&M also proposes to add new Action Conditions C and D, with associated Required Actions and Completion Times for LCO 3.6.14. The new Conditions C and D are, respectively, one required CEQ fan room drain inoperable and one flood-up overflow wall flow path inoperable.

These new Conditions, Required Actions, and Completion Times are similar to existing Conditions A

Enclosure 2 to AEP:NRC:7036 Page 8 and B and their associated Required Actions and Completion Times. Like existing Conditions A and B, operation in new Conditions C and D will be outside the bounds of the applicable containment analysis.

For new Conditions C and D, the applicable containment analysis will be the refined analysis conducted in accordance with the GR and SER. The one hour Completion Time is consistent with that of existing Conditions A and B, and consistent with the Completion Time for LCO 3.6.1, Condition A which requires that the containment be restored to operable status within one hour. Existing Condition C will be re-lettered as Condition E to provide proper sequencing.

In accordance with 10 CFR 50.36(c)(3), I&M is proposing four new TS Surveillance Requirements for the CEQ fan room drains and flood-up overflow wall flow paths to assure that the necessary quality of the associated systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. The four proposed Surveillance Requirements are as follows: " The inspection required by proposed new Surveillance Requirement.

3.6.14.4 will assure that no debris is present in the CEQ fan rooms that could obstruct the CEQ fan room drains and that the drain line debris interceptors are not obstructed.

This proposed Surveillance Requirement will provide a function for the CEQ fan room drains similar to the function that existing Surveillance Requirement 3.6.14.1 provides for the refueling canal drains, i.e., provide assurance that the drains will not be blocked by debris that could be moved to the drains by water flowing from elsewhere in the area. The proposed Frequency will assure that the Surveillance Requirement is performed prior to the unit entering Mode 4. With the unit in Modes 1 through 4, the likelihood that debris producing activity will be conducted in the CEQ fan rooms is significantly reduced. Therefore, the proposed Surveillance Requirement will require that the inspection be performed only if personnel enter a CEQ fan room. The Surveillance Requirement is modified by a note stating that only the CEQ fan room that has been entered need be inspected if the Surveillance Requirement is being performed due to personnel entry in Modes 1 through 4. The note precludes unnecessarily requiring inspection of both CEQ fan rooms if only one has been entered." The inspection required by proposed new Surveillance Requirement 3.6.14.5 will assure that the required CEQ fan room drain lines are operable.

This proposed Surveillance Requirement will assure CEQ fan room drain line operability by inspecting critical features, similar to existing Surveillance Requirement 3.6.14.2 which requires inspection of refueling canal drain critical features.

The proposed Frequency of 24 months is consistent with the Frequency of other critical features in TS Section 3.6, "Containment Systems."" The inspection required by proposed new Surveillance Requirement 3.6.14.6 will assure that no debris is present in the lower containment that could obstruct the flood-up overflow wall flow paths. This proposed Surveillance Requirement will provide a function for the flood-up overflow wall flow paths similar to the function that existing Surveillance Requirement 3.6.14.1 provides for the refueling canal drains, i.e., provide assurance that the drains will not Enclosure 2 to AEP:NRC:7036 Page 9 be blocked by debris that could be moved to the drains by water flowing from elsewhere in the area. The proposed Frequency will assure that the Surveillance Requirement is performed prior to the unit entering Mode 4. With the unit in Modes 1 through 4, the likelihood that debris producing activity will be conducted in the lower containment is significantly reduced.Therefore, the proposed Surveillance Requirement will require that the inspection be performed only if personnel enter the lower containment.

The Surveillance Requirement is modified by a note stating that only the lower containment area that has been entered need be inspected if the Surveillance Requirement is being performed due to personnel entry in Modes 1 through 4. The note precludes unnecessarily requiring inspection of the entire lower containment if only a portion has been accessed.The inspection required by proposed new Surveillance Requirement 3.6.14.7 will assure that the flood-up overflow wall flow paths are operable.

This proposed Surveillance Requirement will assure flood-up overflow wall flow path operability by inspecting critical features, similar to existing Surveillance Requirement 3.6.14.2 which requires inspection of refueling canal drain critical features.

The proposed Frequency of 24 months is consistent with the Frequency of other critical features in TS Section 3.6, "Containment Systems." 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Indiana Michigan Power Company (I&M) has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated?

Response:

No The proposed change consists of a revision to the Technical Specifications (TS) for post accident monitoring (PAM) instrumentation to include new containment recirculation sump level instrumentation, a revision to the TS for Emergency Core Cooling Systems (ECCS) to replace the term "trash rack and screen" with the term "strainer," and a revision to the TS for containment recirculation drains to add two flow paths credited in the evaluation of the effects of post-accident debris on the containment recirculation functions pursuant to Nuclear Regulatory Commission Generic Letter 2004-02.The proposed TS revisions will not increase the probability of an accident because the associated components, i.e., the new sump level instruments, the new strainers, and the two flow paths, are not, and will not become, accident initiators.

The activities involving these components pursuant to the proposed TS revisions consist of implementing Surveillance Enclosure 2 to AEP:NRC:7036 Page 10 Requirements for the new sump level instruments and the flow paths and actions to be taken if these components are inoperable.

These activities will not increase the likelihood of an accident.

The TS change associated with the sump strainers is editorial in that it reflects the terminology that has been applied to new pocket strainers that continue to perform the trash rack and screen functions.

The change in terminology will not result in any new activities.

The proposed TS revisions will not increase the consequences of an accident because the associated components all provide mitigative functions for an accident, and their ability to perform their mitigative functions is not reduced by the associated TS changes. The TS changes associated with the new sump level instrumentation and the recirculation flowpaths will provide increased assurance that these components will be available to perform their mitigative function if needed. The TS change associated with the sump strainers is editorial and does not affect the mitigative capability of the screens.Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

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

Response:

No The proposed TS revisions will not create the possibility of a new or different kind of accident from any accident previously evaluated because the associated components, i.e., the new sump level instruments, the new strainers, and the two flow paths, are components that will not initiate any accident.

The proposed TS changes associated with these components will not cause them to be operated in any manner not previously evaluated for the specific components or for similar components, or cause them to become other than passive components.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No The margin of safety associated with the proposed TS revisions involves the ability of the associated components, i.e., the new sump level instruments, the new strainers, and the two flow paths, to assure the ECCS and containment spray recirculation function can be adequately accomplished.

The TS changes associated with the new sump level instrumentation and the recirculation flowpaths will provide increased assurance that this Enclosure 2 to AEP:NRC:7036 Page 11 function can be fulfilled.

The TS change associated with the sump strainers is editorial and does not affect this function.Therefore, the proposed change will not create a significant reduction in a margin of safety.In summary, based upon the above evaluation, I&M has concluded that the proposed amendment involves no 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.

5.2 Applicable

Regulatory Requirements Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident" Regulatory Guide 1.97 describes a method acceptable to the Nuclear Regulatory Commission (NRC) staff for complying with the NRC's regulations to provide instrumentation to monitor plant variables and systems during and following an accident in a light-water-cooled nuclear power plant. The new containment recirculation sump level instruments will comply with Regulatory Guide 1.97 as described in the preceding Section 4.1, titled "PAM Instrumentation." 10 CFR 50,36, "Technical Specifications" Regulation 10 CFR 50.36(c) identifies the categories of items that a utilization facility's TS must include. Paragraph 10 CFR 50.36(c)(2)(ii)(C) indicates that an Limiting Condition for Operation (LCO) must be established for items meeting the following criterion:

Criterion

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.As described in the preceding Section 4.3, titled "Containment Recirculation Drains," the Containment Air Recirculation/Hydrogen Skimmer System (CEQ) fan room drains and flood-up overflow wall flow paths meet this criterion.

Accordingly, I&M is proposing to add these items to an existing TS LCO and to add appropriate TS Actions to be taken if the items are inoperable.

Paragraph 10 CFR 50.36(c)(3) describes the TS Surveillance Requirements as follows: 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.Accordingly, I&M is proposing to add appropriate TS Surveillance Requirements for the CEQ fan room drains and flood-up overflow wall flow paths.

Enclosure 2 to AEP:NRC:7036 Page 12 In 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 NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health or safety of the public.6.0 ENVIRONMENTAL CONSIDERATIONS A review has determined that 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, or would change an inspection or Surveillance Requirement.

The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent 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(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. NRC GL 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurizer-Water Reactors," dated September 13, 2004 (ML042360586).

2. Letter from J. N. Jensen, I&M, to NRC Document Control Desk, "Update Response to NRC GL 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," AEP:NRC:6054-05, dated June 27, 2006 (ML061860257).

3. NRC Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 3, May 1983 (ML003740282).

4. Letter from J. N. Jensen, I&M, to NRC Document Control Desk, "Nuclear Regulatory Commission Generic Letter 2004-02 -Information Requested by September 1, 2005," AEP:NRC:5054-11, dated August 31, 2005 (ML052510512).

5. Nuclear Energy Institute report NEI 04-07, "Pressurized Water Reactor Sump Performance Methodology," dated December 2004 (ML041550332).

6. Memo from P. S. Tam, NRC, "Summary of May 8, 2007, Meeting with I&M, on Status and Issues Related to DCCNP Implementation of Generic Letter 2004-02.(TAC Nos. MC4679 and MC4680)," dated May 25, 2007, (ML071220258).

Enclosure 2 to AEP:NRC:7036 Page 13 Sketch Location of New CNP Containment Sump Flowpaths, Debris Interceptors, and Strainers Debris Interceptor CEQ Fan Room Drains and Debris Interceptors

-7 New Remote Strainer Flood-up Overflow Wall Flow Holes (5 total, 3 shown)Upgraded Existing Strainer Attachment 1A to AEP:NRC:7036 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW CHANGES 3.3.3-5 3.5.2-3 3.6.14-1 3.6.14-2 3.6.14-3 PAM Instrumentation

3.3.3 Table

3.3.3-1 (page 2 of 2)Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION F.1 20. Emergency Core Cooling System Flow (per train) 2(e) G 21. Containment Pressure (Wide Range) 2 G 22. Refueling Water Storage Tank Level 2 G 23. RCS Subcooling Margin Monitor 1 (f) G 24. Component Cooling Water Pump Circuit Breaker 2 H Status (e) Any combination of two instruments per train, including Centrifugal Charging Pump Flow, Safety Injection Pump Flow, Centrifugal Charging Pump Circuit Breaker Status, and Safety Injection Pump Circuit Breaker Status,-can be used to satisfy Function 20 OPERABILITY requirements.(f) An OPERABLE plant process computer (PPC) subcooling margin readout can be used as a substitute for an inoperable Function 23, RCS Subcooling Margin Monitor.Cook Nuclear Plant Unit 1 3.3.3-5 Amendment No. 287 ECCS -Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.24 months Valve Number 1-SI-121 N 1-SI-121 S 1-SI-141 Li 1-SI-141 L2 1-SI-141 L3 1-SI-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train 24 months containment sump suction inlet is not restricted by debris and the suction inlet trash rFacks and screens trainers show no evidence of structural distress or abnormal corrosion.

Cook Nuclear Plant Unit 1 3.5.2-3 Amendment No. 287 Containment Recirculation Drains 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Containment Recirculation Drains LCO 3.6.14 The ice condenser floor drainsq and two refueling canal drains-*ne drair in each Co rimen r ulatn Hydrogenkimmer System (C EQ)fan room, and the overflow wall flow b shall be OPERABLE.APPLICABILITY:

MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser floor A.1 Restore ice condenser floor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drain inoperable, drain to OPERABLE status.B. One required refueling B.1 Restore required refueling 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> canal drain inoperable, canal drain to OPERABLE status.roorn idrain inoperable.

room dran to OPERAB~LE associated Completion Time not met. AND GE.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Cook Nuclear Plant Unit 1 3.6.14-1 Amendment No. 287 Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify, by visual inspection, that no debris is present in the upper containment or refueling canal that could obstruct the required refueling canal drains.92 days AND Prior to entering MODE 4 from MODE 5 after each partial or complete fill of the canal SR 3.6.14.2 Verify, by visual inspection, that: Prior to entering MODE 4 from a. Each required refueling canal drain blind flange MODE 5 after is removed; and each partial or complete fill of the b. Each required refueling canal drain is not canal obstructed by debris.SR 3.6.14.3 Verify for each ice condenser floor drain that the: 18 months a. Valve opening is not impaired by ice, frost, or debris;b. Valve seat shows no evidence of damage;c. Valve opening force is _100 Ib; and d. Drain line from the ice condenser floor to the lower compartment is unrestricted.

........... ... P r I ... .S 3..4.4 ----- nOTE---m-Pier to entering Rqie: nl 1;f&.@EEU-fanjý roomthat 'is entered O~ ror whenerformied after personnel entry in MdD!ES 1 O1DE 5~Verify, by visual inspection, thatno dbris is present A~fter personnel, in the CEQ fa~n roormsthat could obstruct the entry into a OE Irequired CEO ~fan roomndrains and the required fan room in drain line~ debris interceptors are not-obstructed lby MODES 1 throu4j d~ebris., Cook Nuclear Plant Unit 1 3.6.14-2 Amendment No. 287 Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 5 Verify by visual inspection, for each :required CEQ fan room drain line that _.D-a-i n lie debris intece n pto r i_.s installed; b Drai n lIne debri inteceptor shows no evidence ,of structural distress,'

K4:i:onthsR9 Pipe tunnel (annulus) sump flow opening is not 1osrutd i-R 3.6.146-------------

prior to erteiii MODE 4 from MODE5 A ft er -pe r-son nelI entry into low6~~j conta~inment in'MOiDES I thr ugj, S-R -3.6.14.77 Verif, by visua Ninspecti ontatef-dw~nii Cook Nuclear Plant Unit 1 3.6.14-3 Amendment No.

Attachment 1B to AEP:NRC:7036 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW CHANGES 3.3.3-5 3.5.2-3 3.6.14-1 3.6.14-2 3.6.14-3 PAM Instrumentation

3.3.3 Table

3.3.3-1 (page 2 of 2)Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION F.1 20. Emergency Core Cooling System Flow (per train) 2(e) G 21. Containment Pressure (Wide Range) 2 G 22. Refueling Water Storage Tank Level 2 G 23. RCS Subcooling Margin Monitor 1 W G 24. Component Cooling Water Pump Circuit Breaker 2 H Status ,25-. -C-ta5m-fFec~-linSRe 2, (e) Any combination of two instruments per train, inc:uding Centrifugal Charging Pump Flow, Safety Injection Pump Flow, Centrifugal Charging Pump Circuit Breaker Status, and Safety Injection Pump Circuit Breaker Status, can be used to satisfy Function 20 OPERABILITY requirements.(f) An OPERABLE plant process computer (PPC) subcooling margin readout can be used as a substitute for an inoperable Function 23, RCS Subcooling Margin Monitor.Cook Nuclear Plant Unit 2 3.3.3-5 Amendment No. 269 ECCS -Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY I SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.24 months Valve Number 2-SI-121 N 2-SI-121 S 2-SI-141 Li 2-SI-141 L2 2-SI-141 L3 2-SI-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train 24 months containment sump suction inlet is not restricted by debris and the suction inlet trash rFacks a-nd Gc-eeR trtaifner show no evidence of structural distress or abnormal corrosion.

Cook Nuclear Plant Unit 2 3.5.2-3 Amendment No. 269 Containment Recirculation Drains 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Containment Recirculation Drains LCO 3.6.14 APPLICABILITY:

The ice condenser floor drains, and two refueling canal drains.o`e driaiR in each Containment Air RecircutionIHydogn Skimmer I qjrom,_andthe flood-up overflow wall pth shall be OPERABLE.MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser floor A. 1 Restore ice condenser floor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drain inoperable, drain to OPERABLE status.B. One required refueling B.1 Restore required refueling 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> canal drain inoperable, canal drain to OPERABLE status.G0.Required Action and GC.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 not met. ANDBe in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Cook Nuclear Plant Unit 2 3.6.14-1 Amendment No. 269 Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify, by visual inspection, that no debris is present 92 days in the upper containment or refueling canal that could obstruct the required refueling canal drains. AND Prior to entering MODE 4 from MODE 5 after each partial or complete fill of the canal SR 3.6.14.2 Verify, by visual inspection, that: Prior to entering MODE 4 from a. Each required refueling canal drain blind flange MODE 5 after is removed; and each partial or complete fill of the b. Each required refueling canal drain is not canal obstructed by debris.SR 3.6:14.3 Verify for each ice condenser floor drain that the: 18 months a. Valve opening is not impaired by ice, frost, or debris;b. Valve seat shows no evidence of damage;c. Valve opening force is _100 Ib; and d. Drain line from the ice condenser floor to the lower compartment is unrestricted.

SR 4 N E---------

yr ite tering Rqied oWnly for 1W@5- fan room f thIat is enterd@E4ro wen-perf brmedaftr pelrsonnel entry in MODES 1 MOID 5.Verify, by visual nspection, thapt noi debris is present After ersonnel in the CEQ fan rooms that could obstruct the e~ntry into a CEQ ,requ~ire'd CEQ fan room drains arnd the required fan room in'drain line debris interceptosae~o MOSE ~Jj~e r is., Cook Nuclear Plant Unit 2 3.6.14-2 Amendment No. 269 Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY_______Verify, by visual fnpetono-r each required CEQ fan~~ room drain I ne that thie.a'- Drin-' lin-e_ d e b-r is -i n te rc -ept'o- r i _is ain 'iid, months rin lie 6-d-e-br~is frfterc-e-p-tr -shows no~ evdie n6 Lofsrcua dites cYC o -nt a'i6m e- sum J1-w-ofi '_i~nigYno

' _obstructed.Piroeig i MODE 4 from'After personnel§R 3.6.14.7 Verfy by viul'sein httef~d efle wal deb5r.Is interfe .ter is, istalle I n re of struotural distress.Cook Nuclear Plant Unit 2 3.6.14-3 Amendment No.

Attachment 2A to AEP:NRC:7036 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGES WITH THE PROPOSED CHANGES INCORPORATED 3.3.3-5 3.5.2-3 3.6.14-1 3.6.14-2 3.6.14-3 PAM Instrumentation

3.3.3 Table

3.3.3-1 (page 2 of 2)Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION F.1 20. Emergency Core Cooling System Flow (per train) 2(e) G 21. Containment Pressure (Wide Range) 2 G 22. Refueling Water Storage Tank Level 2 G 23. RCS Subcooling Margin Monitor 1 (f) G 24. Component Cooling Water Pump Circuit Breaker 2 H Status 25. Containment Recirculation Sump Water Level 2 G (e) Any combination of two instruments per train, including Centrifugal Charging Pump Flow, Safety Injection Pump Flow, Centrifugal Charging Pump Circuit Breaker Status, and Safety Injection Pump Circuit Breaker Status, can be used to satisfy Function 20 OPERABILITY requirements.(f) An OPERABLE plant process computer (PPC) subcooling margin readout can be used as a substitute for an inoperable Function 23, RCS Subcooling Margin Monitor.Cook Nuclear Plant Unit 1 3.3.3-5 Amendment No. 297, ECCS -Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.24 months Valve Number 1-SI-121 N 1-SI-121 S 1-SI-141 Li 1-SI-141 L2 1-SI-141 L3 1-SI-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train 24 months containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.

Cook Nuclear Plant Unit 1 3.5.2-3 Amendment No. 2&7, Containment Recirculation Drains 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Containment Recirculation Drains LCO 3.6.14 APPLICABILITY:

The ice condenser floor drains, two refueling canal drains, one drain in each Containment Air Recirculation/Hydrogen Skimmer System (CEQ)fan room, and the flood-up overflow wall flow paths shall be OPERABLE.MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser floor A. 1 Restore ice condenser floor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drain inoperable, drain to OPERABLE status.B. One required refueling B.1 Restore required refueling 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> canal drain inoperable, canal drain to OPERABLE status.C. One required CEQ fan C.1 Restore required CEQ fan 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> room drain inoperable, room drain to OPERABLE status.D. One flood-up overflow D.1 Restore flood-up overflow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> wall flow path wall flow path to inoperable.

OPERABLE status.E. Required Action and E.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 not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Cook Nuclear Plant Unit 1 3.6.14-1 Amendment No. 297, Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify, by visual inspection, that no debris is present 92 days in the upper containment or refueling canal that could obstruct the required refueling canal drains. AND Prior to entering MODE 4 from MODE 5 after each partial or complete fill of the canal SR 3.6.14.2 Verify, by visual inspection, that: Prior to entering MODE 4 from a. Each required refueling canal drain blind flange MODE 5 after is removed; and each partial or complete fill of the b. Each required refueling canal drain is not canal obstructed by debris.SR 3.6:14.3 Verify for each ice condenser floor drain that the: 18 months a. Valve opening is not impaired by ice, frost, or debris;b. Valve seat shows no evidence of damage;c. Valve opening force is _100 Ib; and d. Drain line from the ice condenser floor to the lower compartment is unrestricted.

SR 3.6.14.4 ---------------------

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

Prior to entering Required only for CEQ fan room that is entered MODE 4 from when performed after personnel entry in MODES 1 MODE 5 through 4.AND Verify, by visual inspection, that no debris is present After personnel in the CEQ fan rooms that could obstruct the entry into a CEQ required CEQ fan room drains and the required fan room in drain line debris interceptors are not obstructed by MODES 1 through debris. 4.Cook Nuclear Plant Unit 1 3.6.14-2 Amendment No. 297, Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.5 Verify by visual inspection, for each required CEQ fan room drain line that the: a. Drain line debris interceptor is installed;

b. Drain line debris interceptor shows no evidence of structural distress;c. Pipe tunnel (annulus) sump flow opening is not obstructed.

24 months i SR 3.6.14.6----------------------

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

Required only for area of lower containment that is entered when performed after personnel entry in MODES 1 through 4.Verify, by visual inspection, that no debris is present in the lower containment that could obstruct the flood-up overflow wall flow paths and that the flow paths are not obstructed by debris.Prior to entering MODE 4 from MODE 5 AND After personnel entry into lower containment in MODES 1 through 4.SR 3.6.14.7 Verify, by visual inspection, that the flood-up 24 months overflow wall debris interceptor is installed and is free of structural distress.Cook Nuclear Plant Unit 1 3.6.14-3 Amendment No.

Attachment 2B to AEP:NRC:7036 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGES WITH THE PROPOSED CHANGES INCORPORATED 3.3.3-5 3.5.2-3 3.6.14-1 3.6.14-2 3.6.14-3 PAM Instrumentation

3.3.3 Table

3.3.3-1 (page 2 of 2)Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED FUNCTION REQUIRED CHANNELS ACTION F.1 20. Emergency Core Cooling System Flow (per train) 2(e) G 21. Containment Pressure (Wide Range) 2 G 22. Refueling Water Storage Tank Level 2 G 23. RCS Subcooling Margin Monitor 1 M G 24. Component Cooling Water Pump Circuit Breaker 2 H Status 25. Containment Recirculation Sump Water Level 2 G (e) Any combination of two instruments per train, including Centrifugal Charging Pump Flow, Safety Injection Pump Flow, Centrifugal Charging Pump Circuit Breaker Status, and Safety Injection Pump Circuit Breaker Status, can be used to satisfy Function 20 OPERABILITY requirements.(f) An OPERABLE plant process computer (PPC) subcooling margin readout can be used as a substitute for an inoperable Function 23, RCS Subcooling Margin Monitor.Cook Nuclear Plant Unit 2 3.3.3-5 Amendment No. 269, ECCS -Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.24 months Valve Number 2-SI-121 N 2-SI-121 S 2-SI-141 Li 2-SI-141 L2 2-SI-141 L3 2-SI-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train 24 months containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.

Cook Nuclear Plant Unit 2 3.5.2-3 Amendment No. 26-9, Containment Recirculation Drains 3.6.14 3.6 CONTAINMENT SYSTEMS 3.6.14 Containment Recirculation Drains LCO 3.6.14 APPLICABILITY:

The ice condenser floor drains, two refueling canal drains, one drain in each Containment Air Recirculation/Hydrogen Skimmer System (CEQ)fan room, and the flood-up overflow wall flow paths shall be OPERABLE.MODES 1, 2, 3, and 4.ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ice condenser floor A.1 Restore ice condenser floor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> drain inoperable, drain to OPERABLE status.B. One required refueling B.1 Restore required refueling 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> canal drain inoperable, canal drain to OPERABLE status.C. One required CEQ fan C.1 Restore required CEQ fan 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> room drain inperable.

room drain to OPERABLE status.D. One flood-up overflow D.1 Restore flood-up overflow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> wall flow path wall flow path to inoperable.

OPERABLE status.E. Required Action and E.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 not met. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Cook Nuclear Plant Unit 2 3.6.14-1 Amendment No. 2-6-9, Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.14.1 Verify, by visual inspection, that no debris is present in the upper containment or refueling canal that could obstruct the required refueling canal drains.92 days AND Prior to entering MODE 4 from MODE 5 after each partial or complete fill of the canal SR 3.6.14.2 Verify, by visual inspection, that: Prior to entering MODE 4 from a. Each required refueling canal drain blind flange MODE 5 after is removed; and each partial or complete fill of the b. Each required refueling canal drain is not canal obstructed by debris.SR 3.6.14.3 -Verify for each ice condenser floor drain that the: 18 months a. Valve opening is not impaired by ice, frost, or debris;b. Valve seat shows no evidence of damage;c. Valve opening force is _100 Ib; and d. Drain line from the ice condenser floor to the lower compartment is unrestricted.

SR 3.6.14.4 ---------------------

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

Prior to entering Required only for CEQ fan room that is entered MODE 4 from when performed after personnel entry in MODES 1 MODE 5.through 4.AND Verify, by visual inspection, that no debris is present After personnel in the CEQ fan rooms that could obstruct the entry into a CEQ required CEQ fan room drains and the required fan room in drain line debris interceptors are not obstructed by MODES 1 through debris. 4.Cook Nuclear Plant Unit 2 3.6.14-2 Amendment No. 2-W Containment Recirculation Drains 3.6.14 SURVEILLANCE REQUIREMENTS (continued)

~1~SURVEILLANCE FREQUENCY~1-Verify, by visual inspection, for each required CEQ SR 3.6.14.5 Verify, by visual inspection, for each required CEQ fan room drain line that the: a. Drain line debris interceptor is installed;

b. Drain line debris interceptor shows no evidence of structural distress;c. Containment sump flow opening is not obstructed.

24 months SR 3.6.14.6---------------------

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

Required only for area of lower containment that is entered when performed after personnel entry in MODES 1 through 4.Prior to entering MODE 4 from MODE 5 AND After personnel entry into lower containment in MODES 1 through 4.Verify, by visual inspection, that no debris is present in the lower containment that could obstruct the flood-up overflow wall flow paths and that the flow paths are not obstructed by debris.SR 3.6.14.7 Verify, by visual inspection, that the flood-up 24 months overflow wall debris interceptor is installed and is free of structural distress.Cook Nuclear Plant Unit 2 3.6.14-3 Amendment No.

Attachment 3 to AEP:NRC:7036 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGES MARKED TO SHOW CHANGES B 3.3.3-1 B 3.3.3-10 B 3.3.3-14 B 3.5.2-8 B 3.6.14-1 B 3.6.14-2 B 3.6.14-3 B 3.6.14-4 B 3.6.14-5 B 3.6.14-6 PAM Instrumentation B 3.3.3 B 3.3 INSTRUMENTATION B 3.3.3 Post Accident Monitoring (PAM) Instrumentation BASES BACKGROUND The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations.

This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for Design Basis Accidents (DBAs).The OPERABILITY of the accident monitoring instrumentation ensures that there is sufficient information available on selected unit parameters to monitor and to assess unit status and behavior following an accident.The availability of accident monitoring instrumentation is important so that responses to corrective actions can be observed and the need for, and magnitude of, further actions can be determined.

These essential instruments are identified in References 1n and 2n addressing the recommendations of Regulatory Guide 1.97 (Ref. 3) as required by Supplement 1 to NUREG-0737 (Ref. 4).The instrument channels required to be OPERABLE by this LCO include two classes of parameters identified during unit specific implementation of Regulatory Guide 1.97 as Type A and Category 1 variables.

These key variables are identified by the unit specific Regulatory Guide 1.97 analyses (Ref. 2and 5). These analyses identify the unit specific Type A and Category 1 variables and provide justification for deviating from the NRC guidance in Reference 3.The specific instrument Functions listed in Table 3.3.3-1 are discussed in the LCO section.APPLICABLE SAFETY ANALYSES The PAM instrumentation LCO ensures the OPERABILITY of Regulatory Guide 1.97 Type A variables so that the control room operating staff can: Perform the diagnosis specified in the emergency operating procedures (these variables are restricted to preplanned actions for the primary success path of DBAs), e.g., loss of coolant accident (LOCA); and Take the specified, pre-planned, manually controlled actions, for which no automatic control is provided, and that are required for safety systems to accomplish their safety function.Cook Nuclear Plant Unit 1 B 3.3.3-1 Revision No. 0 PAM Instrumentation B 3.3.3 BASES LCO (continued)

24. Component Cooling Water Pump Circuit Breaker Status Component Cooling Water Pump Circuit Breaker Status is a Type A, Category 1 variable provided for verification of component cooling water flow to Engineered Safety Feature Systems. Two component cooling water pump circuit breaker status channels (one channel per component cooling water pump) are provided.

Each channel is capable of indicating circuit breaker position (open or closed).05. _Co0ntaijn m ent Rec6r'cu la~tion Sum Wn6V ate r Lev4el APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1, 2, and 3.These variables are related to the diagnosis and pre-planned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1, 2, and 3. In MODES 4, 5, and 6, unit conditions are such that the likelihood of an event that would require PAM instrumentation is low;therefore, the PAM instrumentation is not required to be OPERABLE in these MODES.ACTIONS A Note has been added in the ACTIONS to clarify the application of Completion Time rules. The Condition of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.A.1 Condition A applies when one or more Functions (except Functions 14 and 23) have one required channel that is inoperable.

Required Action A.1 requires restoring the inoperable channel to OPERABLE status within 30 days. The 30 day Completion Time is based on operating experience and takes into account the remaining OPERABLE channel or remaining isolation barrier in the case of containment penetrations with only one CIV, the passive nature of the instrument (no critical automatic action is assumed to occur from these instruments), and Cook Nuclear Plant Unit 1 B 3.3.3-10 Revision No. 0 ECCS -Operating B 3.5.2 BASES SURVEILLANCE REQUIREMENTS (continued) based on consideration of the design reliability (and confirming operating experience) of the equipment.

SR 3.5.2.6 Proper throttle valve position is necessary for proper ECCS performance.

These valves have stops to allow proper positioning for restricted flow to a ruptured cold leg, ensuring that the other cold legs receive at least the required minimum flow. This Surveillance verifies the mechanical stop of each listed ECCS throttle valve is in the correct position.

The 24 month Frequency is based on the same reasons as those stated in SR 3.5.2.4 and SR 3.5.2.5.SR 3.5.2.7 Periodic inspections of the containment sump suction inlets ensure that it isthey are'unrestricted and stays in proper operating condition.

Thisýýurveillance verifies that the sump suiction irlets are noti restricted b yj debris and t he suctlion1 inlei strain~ers shbev noevidenceofK structural

'dist1ress, suc h as'ex eis;si~v oper ir g ~or g-ap§ ý,>hich would a llo~n gncceptale debris t bypassthe sr ine .The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage, on the need to have access to the location.This Frequency has been found to be sufficient to detect abnormal degradation and is confirmed by operating experience.

REFERENCES

1. UFSAR, Section 1.4.7.2. 10 CFR 50.46.3. UFSAR, Section 14.3.1.4. UFSAR, Section 14.3.2.5. UFSAR, Section 14.2.4.6. UFSAR, Section 14.2.5.7. UFSAR, Section 14.3.4.8. NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.9. IE Information Notice No. 87-01.10. ASME, Operations and Maintenance Standards and Guides (OM Codes).Cook Nuclear Plant Unit 1 B 3.5.2-8 Revision No. 0 Containment Recirculation Drains B 3.6.14 B 3.6 CONTAINMENT SYSTEMS B 3.6.14 Containment Recirculation Drains BASES BACKGROUND The containment recirculation drains consist of the ice condenser drainsq a.A the refueling canal drainsi the6Con'tainment-A ii 7ndh Simmer System Im fan ,,and the floaod -up oefoww. The ice condenser is partitioned into 24 bays, each having a pair of inlet doors that open from the bottom plenum to allow the hot steam-air mixture from a Design Basis Accident (DBA) to enter the ice condenser.

Twenty-one of the 24 bays have an ice condenser floor drain at the bottom to drain the melted ice into the lower compartment (in the 3 bays that do not have drains, the water drains through the floor drains in the adjacent bays). Each drain leads to a drain pipe that drops down several feet, then makes one or more 900 bends and exits into the lower compartment.

A check (flapper) valve at the end of each pipe keeps warm air from entering during normal operation, but when the water exerts pressure, it opens to allow the water to spill into the lower compartment.

This prevents water from backing up and interfering with the ice condenser inlet doors. The water delivered to the lower containment serves to cool the atmosphere as it falls through to the floor and provides a source of borated water at the containment sump for long term use by the Emergency Core Cooling System (ECCS) and the Containment Spray System during the recirculation mode of operation.

Cook Nuclear Plant Unit 1 B 3.6.14-1 Revision No. 0 Cook Nuclear Plant Unit 1 B 3.6.14-1 Revision No. 0 Containment Recirculation Drains B 3.6.14 BASES BACKGROUND (continued)

The three refueling canal drains are at low points in the refueling canal.During a refueling, blind flanges are installed in the drains and the canal is flooded to facilitate the refueling process. The water acts to shield and cool the spent fuel as it is transferred from the reactor vessel to storage.After refueling, the canal is drained and the blind flanges removed. In the event of a DBA, the refueling canal drains are the main return path to the lower compartment for Containment Spray System water sprayed into the upper compartment.

The ice condenser aPA the refuelinq canal drains!,_theEQfan room drains,i and the flood-up overflow wall flow p function with the ice bed, the Containment Spray System, and the ECCS to limit the pressure and temperature that could be expected following a DBA.APPLICABLE SAFETY ANALYSES The limiting DBAs considered relative to-containment temperature and pressure are the loss of coolant accident (LOCA) and the steam line break (SLB). The LOCA and SLB are analyzed using computer codes designed to predict the resultant containment pressure and temperature transients.

DBAs are assumed not to occur simultaneously or consecutively.

Although the ice condenser is a passive system that requires no electrical power to perform its function, the Containment Spray System and the Containment Air RecirculatilcnHydrogen Skimmer (CEQ) System also function to assist the ice bed in limiting pressures and temperatures.

Therefore, the analysis of the postulated DBAs, with respect to Engineered Safety Feature (ESF) systems, assumes the loss of one ESF bus, which is the worst case single active failure and results in one train of the Containment Spray System and one train of the CEQ System being rendered inoperable.

The limiting DBA analyses (Ref. 1) show that the maximum peak containment pressure results from the LOCA analysis and is calculated to be less than the containment design pressure.

The maximum peak containment atmosphere temperature results from the SLB analysis and is discussed in the Bases for LCO 3.6.5, "Containment Air Temperature." In addition to calculating the overall peak containment pressures, the DBA analyses include calculation of the transient differential pressures that occur across subcompartment walls during the initial blowdown phase of the accident transient.

The internal containment walls and structures are designed to withstand these local transient pressure differentials for the limiting DBAs.The Containment Recirculation Drains satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Cook Nuclear Plant Unit 1 B 3.6.14-2 Revision No. 0 Cook Nuclear Plant Unit 1 B 3.6.14-2 Revision No. 0 Containment Recirculation Drains B 3.6.14 BASES LCO This LCO establishes the minimum requirements to ensure that the containment recirculation drains perform their safety functions.

The ice condenser floor drain valve disks must be closed to minimize air leakage into and out of the ice condenser during normal operation and must open in the event of a DBA when water begins to drain out. Two of the three refueling canal drains must have their blind flanges removed and remain clear to ensure the return of Containment Spray System water to the lower containment in the event of a DBA. Oiedrain in each CEQ fad room also remain clear to ensmre the returof Containment Spray System water to the lower containment in the 'event of a DBA. The flood]i up overflow wall flow paths must iremain clear to ensurie wNatercn flow readily between the loop compa rnnt and the annulust The containment recirculation drains function with the ice condenser, ECCS, and Containment Spray System to limit the pressure and temperature that could be expected following a DBA.APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause an increase in containment pressure and temperature, which would require the operation of the containment recirculation drains. Therefore, the LCO is applicable in MODES 1, 2, 3, and 4.The probability and consequences of these events in MODES 5 and 6 are low due to the pressure and temperature limitations of these MODES. As such, the containment recirculation drains are not required to be OPERABLE in these MODES.BASES ACTIONS A. 1 If one ice condenser floor drain is inoperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to restore the drain to OPERABLE status. The Required Action is necessary to return operation to within the bounds of the containment analysis.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTIONS of LCO 3.6.1,"Containment," which requires that containment be restored to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.B.1 If one required refueling canal drain is inoperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to restore the required drain to OPERABLE status. The Required Action is necessary to return operation to within the bounds of the containment analysis.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is consistent with the ACTIONS of LCO 3.6.1, which requires that containment be restored to OPERABLE status in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.Cook Nuclear Plant Unit 1 B 3.6.14-3 Revision No. 0 Containment Recirculation Drains B 3.6.14 BASES ACTIONS (continued)

S-one requiredCEQ roo drain is ioperable, hour is alowedto I restore the drain.to OPERABLE status. The Required Action is necessary to return operatioR to withinMthebounds oftheecotainment-

'analysis.

The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (ýorpletion Time ýis c~onsi~stent withth WiACINSý of LI: 0 6.1, "Contai rnent, whichrequires thateth containment bees d', te t ra satrestored to OPERABLE status within 1 hour:If one flow path in m the fod soverfloW wall is iroperable, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> i theowd to restore the drain To OaPERABLE status. The Required Acm b ouh is anecesst y to return operation to within 3the6 b ofthe containment nalysiso The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> C ompletion Ti mesi aconsistent with the ACTIONS o LeOpi6.1, "Contaionment," which requires thationtainment befrestor c iRABLE -status within 1anoera CE. 1 and GE.62 If the affected drain(s) cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to 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 to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 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.SURVEILLANCE SR 3.6.14.1 and SR 3.6.14.2 REQUIREMENTS Verifying the OPERABILITY of the required refueling canal drains ensures that they will be able to perform their functions in the event of a DBA. SR 3.6.14.2 confirms that the required refueling canal drain blind flanges have been removed and that the required drains are clear of any obstructions that could impair their functioning.

In addition to debris near the drains, attention must be given to any debris that is located where it could be moved to the drains in the event that the Containment Spray System is in operation and water is flowing to the drains. This verification is performed by SR 3.6.14.1, which requires verification that there is no debris present in the upper containment or refueling canal that could obstruct the required refueling canal drains. SR 3.6.14.1 and SR 3.6.14.2 must be performed before entering MODE 4 from MODE 5 after every filling of the canal to ensure that the blind flanges have been removed and that no debris that could impair the drains was deposited during the time the canal was filled. In addition, SR 3.6.14.1 must be performed Cook Nuclear Plant Unit 1 B 3.6.14-4 Revision No. 0 Containment Recirculation Drains B 3.6.14 BASES SURVEILLANCE REQUIREMENTS (continued) every 92 days. The 92 day Frequency was developed considering such factors as the inaccessibility of the drains, the absence of traffic in the vicinity of the drains, and the redundancy of the drains.SR 3.6.14.3 Verifying the OPERABILITY of the ice condenser floor drains ensures that they will be able to perform their functions in the event of a DBA.Inspecting the drain valve disk ensures that the valve is performing its function of sealing the drain line from warm air leakage into the ice condenser during normal operation, yet will open if melted ice fills the line following a DBA. Verifying that the drain lines are not obstructed ensures their readiness to drain water from the ice condenser.

The 18 month Frequency was developed considering such factors as the inaccessibility of the drains during power operation; the design of the ice condenser, which precludes melting and refreezing of the ice; and operating experience that has confirmed that the drains are found to be acceptable when the Surveillance is performed at an 18 month Frequency.

Because of high radiation in the vicinity of the drains during power operation, this Surveillance is normally done during a shutdown.S.R 30i~ and S, 3.6.14.5 Cook Nuclear Plant Unit 1 B 3.6.14-5 Revision No.

Containment Recirculation Drains B 3.6.14 BASES SURVEILLANCE REQUIREMENTS (continued)

SR361. and SR 3.6.14.71 REFERENCES

1. UFSAR, Section 14.3.4.Cook Nuclear Plant Unit 1 B 3.6.14-6 Revision No.