Text

License Amendment Request Regarding Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15
	ML14356A022
Person / Time
Site:	Cook
Issue date:	12/17/2014
From:	Lies Q; American Electric Power, Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2014-70
	Download: ML14356A022 (37)
	v • d • e

z INDIANA MICHIGAN Indiana Michigan Power Cook Nuclear Plant PIPM R One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power IndianaMichiganPower.com December 17, 2014 AEP-NRC-2014-70 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Docket Nos. 50-315 and 50-316 License Amendment Request Regarding Technical Specification Section 3.8.1, "AC Sources - Operating," Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook Nuclear Plant Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify the notes to TS 3.8.1, "AC Sources - Operating," to allow surveillance testing of the onsite standby emergency diesel generators (DG) during modes in which it is currently prohibited. Specifically, I&M proposes removing the mode restrictions for the following Surveillance Requirements: 3.8.1.10 (DG single largest load rejection test), 3.8.1.11 (DG full load rejection test), and 3.8.1.15 (DG endurance run).

I&M has evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded that they involve no significant hazards consideration. to this letter provides an affirmation statement pertaining to the information contained herein. Enclosure 2 provides I&M's evaluation of the proposed TS change. Enclosures 3 and 4 provide Unit 1 and Unit 2 TS pages marked to show the proposed changes. Enclosures 5 and 6 provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. Bases markups are included for information only. New clean Unit 1 and Unit 2 TS pages with proposed changes incorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing Project Manager when requested.

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

Copies of this letter and its enclosures are being transmitted to the Michigan Public Service Commission and Michigan Department of Environmental Quality, in accordance with the requirements of 10 CFR 50.91.

AooI

U. S. Nuclear Regulatory Commission AEP-NRC-2014-70 Page 2 There are no new regulatory commitments made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely, Q. Shane Lies Engineering Vice President JMT/amp

Enclosures:

1. Affirmation

2. Proposed License Amendment Request Regarding Revision to Technical Specifications 3.8.1, "AC Sources - Operating"

3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes

4. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Proposed Changes.

5. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked To Show Proposed Changes.

6. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked To Show Proposed Changes c: M. L. Chawla, NRC Washington, D.C.

J. T. King - MPSC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III A. J. Williamson, AEP Ft. Wayne, w/o enclosures

Enclosure I to AEP-NRC-2014-70 AFFIRMATION of Indiana I, Q. Shane Lies, being duly sworn, state that I am Engineering Vice President with the U. S. Nuclear Michigan Power (I&M), that I am authorized to sign and file this request matters set Regulatory Commission on behalf of I&M, and that the statements made and the forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Q. Shane Lies Engineering Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS \A-.' DAY OF , 2014 DANIELLE BURGOYN6 Notary Public, State of Michigan County of Berrien My Commission Expires 04--04-2018 Acting In the County of 4 MyCNotareysblic My Commission Expires c)'-\)- - c)"*-\*J,*

Enclosure 2 to AEP-NRC-2014-70 Proposed License Amendment Request Regarding Revision to Technical Specifications 3.8.1, "AC Sources - Operating" 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify TS 3.8.1, "AC Sources - Operating," to allow surveillance testing of the onsite standby emergency diesel generators (EDG) during modes in which it is currently prohibited. Specifically, I&M proposes removing the Note that imposes the mode restrictions for the following Surveillance Requirements (SR): 3.8.1.10 (diesel generator (DG) single largest load rejection surveillance test), 3.8.1.11 (DG full load rejection surveillance test), and 3.8.1.15 (DG endurance surveillance test run).

2.0 DETAILED DESCRIPTION 2.1 Proposed Change I&M proposes the following changes in order to eliminate the Mode 1 and 2 Surveillance testing restrictions for SRs 3.8.1.10, 3.8.1.11, and 3.8.1.15, as discussed above. The changes would be effected by deleting the applicable Note for each surveillance, as follows:

2.1.1 Proposed Change to TS SR 3.8.1.10 (DG single largest load reiection surveillance test)

Note 1 in SR 3.8.1.10 currently states: "This Surveillance shall not normally be performed in Mode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR."

For the proposed change to this SR, this Note would be completely removed.

Additionally, compensatory measures for SR 3.8.1.10 would be added to the TS Bases, as shown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS bases changes are for information only and will be implemented under the CNP TS Bases control program.

2.1.2 Proposed Change to TS SR 3.8.1.11 (DG full load reiection surveillance test)

Note 1 in SR 3.8.1.11 currently states: "This Surveillance shall not normally be performed in Mode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR."

For the proposed change to this SR, this Note would be completely removed.

to AEP-NRC-2014-70 Page 2 Additionally, compensatory measures for SR 3.8.1.11 would be added to the TS Bases, as shown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS bases changes are for information only and will be implemented under the CNP TS Bases control program.

2.1.3 Proposed Change to TS SR 3.8.1.15 (DG endurance surveillance test run)

Note 2 in SR 3.8.1.15 currently states: "This Surveillance shall not normally be performed in Mode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR."

For the proposed change to this SR, this Note would be completely removed.

Additionally, compensatory measures for SR 3.8.1.15 would be added to the TS Bases, as shown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS bases changes are for information only and will be implemented under the CNP TS Bases control program.

The above changes, if approved, will allow the testing required by these SRs to be performed during all modes of operation such that the testing will no longer be required to be performed only during plant outages. This will help to reduce the complexity of coordinating work and testing activities during refueling outages and allow these activities to be performed online. The change will also reduce risk during a refueling outage where the plant is relying on a single train for core cooling. This also allows for shorter refueling outage durations which reduces the duration the plant is in an elevated risk condition.

The marked-up and revised Unit 1 and Unit 2 TS pages reflecting the above changes are provided in Enclosures 3 and 4 of this letter, respectively. In addition, the associated Unit 1 and Unit 2 TS Bases will be revised to reflect the changes to these TSs. A marked-up copy of the proposed Unit 1 and Unit 2 TS Bases changes is provided in Enclosures 5 and 6 of this letter, respectively, for information only. The TS Bases changes will be implemented in accordance with TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of the implementation of this amendment after NRC approval.

3.0 Background Description of Emergency Power System As stated in Updated Final Safety Analysis Report (UFSAR) Section 8.4, "Emergency Power System," the emergency power sources for the two units, including the DGs, are similar and are electrically and physically isolated from one another. Each unit has two full capacity DGs each supplying power to two safety-related 4160 volt (v) buses. Loss of voltage to the 4160v buses is sensed by loss of voltage relays. Upon sensing, master relays automatically start the DGs, trip the normal feed circuit breakers for the 4160v buses, and trip all motor feeder breakers and 480v bus transformer feeder breakers on the buses, the 600v bus tie breaker, non-essential 600v feeder breakers, and 480v bus breakers. The DG bus input circuit breakers which connect to AEP-NRC-2014-70 Page 3 the DG output to the 4160/600v bus system are automatically closed when voltage and speed approach rated values. The DGs supply power to the 600v buses through the 4160v buses and transformers, respectively.

Each DG comes up to speed and is capable of accepting load within 10 seconds. If either DG fails to start, the remaining one is capable of supplying the required engineered safeguard load.

A Safety Injection (SI) signal will also start the DGs. To avoid overloading of the DGs, all loads are shed when the SI occurs and the safety-related 4160v buses are energized from the DGs.

The safety loads are subsequently loaded in a sequential manner as required.

The DGs are sized at 3500 kilowatts (KW) each to assure available power to operate one train of safety equipment assuming a loss-of-offsite-power (LOOP) concurrent with a loss-of-coolant accident with or without containment spray.

UFSAR Section 8.1.2, "Functional Criteria," provides functional requirements employed on electrical systems to achieve maximum reliability and operating efficiency. One of the criteria is that motor loading does not exceed its nameplate rating.

Each diesel engine is a Worthington Type SWB-12, 12 cylinder, heavy duty turbocharged diesel engine, with a continuous rated output of 4900 brake horsepower at 514 revolutions per minute (RPM).

Each generator is a General Electric (GE), 4375 kilo volt amps (a), 3500KW at 0.8 power factor, 514 RPM, 3-phase, 60-cycle, 4160v, 25 percent (%) voltage regulation, direct engine-driven synchronous type generator. Each generator is equipped with a GE brushless exciter type 5AR with a field rated 5.8a and 100v direct current (DC) and, a static voltage regulator with its associated potential and sensing transformers.

The alternating current (AC) sources are designed to permit inspection and testing of all important areas and features, especially those that have a standby function, in accordance with Plant Specific Design Criterion (PSDC) 39. Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of U. S. Nuclear Regulatory Commission (NRC) Regulatory Guide 1.9, "Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants", and Institute of Electrical and Electronics Engineers (IEEE) Standard 387-1995 IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations.

to AEP-NRC-2014-70 Page 4

4.0 TECHNICAL EVALUATION

4.1 Changes to SR 3.8.1.10 (DG single largest load rejection surveillance test) 4.1.1 Deletion of mode restriction note from SR 3.8.1.10 DG single largest load rejection test.

The current approach for performance of the load rejection test in SR 3.8.1.10 has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG to the required load, and then open the DG output breaker. Opening of the DG output breaker separates the DG from its associated safety-related 4160v bus and allows the offsite circuit to continue to supply that bus.

The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs and safety-related 4160v buses is required to be operable. During testing the diesel being tested is inoperable, but available. This license amendment request (LAR) is proposing that this testing also be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.

The concerns associated with performing the single largest load rejection surveillance test in Mode 1 or 2 are that the DG being tested is susceptible to damage caused by grid disturbances, disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated load might cause electrical system perturbations, and the DG in test mode is more susceptible to tripping due to the extra protective trip relays that are in effect during test mode operations.

4.1.1.1 Grid Disturbances The concern of performing the single largest load rejection surveillance test in Mode 1 or 2, while connected to offsite power or generator output, is that the DG is. susceptible to grid disturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsite power system or generator output in the test mode of operation, the availability of the DG for subsequent emergency operation could be adversely affected due to the potential for common mode vulnerability. However, only one DG per unit is paralleled to offsite power or generator output at any one time and any grid disturbances would only possibly affect one DG.

Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, to prohibit switchyard work during performance of this surveillance. This will minimize the likelihood of a power disturbance or fault related to switchyard activities. Therefore, the justification for this proposed change is based-on the fact that the remaining DG would remain operable and is capable of mitigating a Design Based Accident (DBA). The redundant train of onsite AC power is fully capable of mitigating a DBA or providing for safe shutdown of the associated unit with the remaining DG operable.

In the case where a disturbance affects the DG being tested, protective relaying protects the DG from equipment damage. This feature causes the DG output breaker to trip, separating the DG from its associated safety-related 4160v bus. In the event of a DG protective device trip, the DG could be restored via operator action.

As a common practice at CNP, risk management considerations ensure that this and other SRs are not scheduled during periods where there is increased potential for grid or bus disturbance to AEP-NRC-2014-70 Page 5 (storms, grid emergencies, etc.). Performance of the single largest load rejection surveillance test per SR 3.8.1.10, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently tests its DGs paralleled to offsite power or generator output during required monthly surveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.

4.1.1.2 Electrical Perturbations The concern of performing the single largest load rejection surveillance test in Mode 1 or 2 is that suddenly disconnecting a DG from the associated bus on a single largest load rejection surveillance test could cause a voltage fluctuation on that bus which could potentially perturb the onsite AC electrical system. However, industry experience shows that there is no significant electrical distribution system effect on the associated bus during a single largest load rejection surveillance test. Furthermore, at CNP when the single largest load rejection surveillance test is performed at shutdown, the voltage recovery is within 2 seconds. During this testing there were no recorded voltage oscillations and the voltage change was a smooth step change, which would have no adverse impact on equipment performance. Therefore, performing load reject tests in accordance with SR 3.8.1.10 in any modes would not cause a significant perturbation that would adversely affect the onsite AC electrical system.

4.1.1.3 Protective Trip Relays During single largest load rejection surveillance testing of DGs while in test mode, non-emergency trip features are in effect to protect the DG from equipment damage due to equipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with these non-emergency trips in effect, the affected DG will automatically revert to the emergency mode and bypass these trips. No operator action is required. Upon detection of under voltage on the safety-related 4160v bus, load shedding for all vital loads and non-permanently connected loads from the 4160v bus would occur followed by re-sequencing of the vital loads back onto the affected 4160v bus. The operators receive indication and alarms in the control room that the preferred power source is lost. In addition, the proposed change does not impact voltage regulation and DG governor system operation during surveillance testing.

Finally, the proposed test configuration for the single largest load rejection surveillance test is similar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthly surveillance test run), which is performed while in Mode 1.

4.2 Changes to SR 3.8.1.11 (DG full load rejection surveillance test) 4.2.1 Deletion of mode restriction note from SR 3.8.1.11 The current approach for performance of the full load rejection surveillance test in SR 3.8.1.11 has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG to the required 100% load, and then open the DG output breaker. Opening of the DG output breaker separates the DG from its associated safety-related 4160v bus and allows the offsite circuit to continue to supply that bus.

to AEP-NRC-2014-70 Page 6 The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs and safety-related 4160v buses is required to be operable. Therefore, the current testing process does not require the DG and 4160v bus being tested to remain operable. This change request is proposing that testing also be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.

There are three concerns associated with performing the full load rejection surveillance test in Mode 1 or 2. The first concern is that the DG being tested is more susceptible to damage caused by grid disturbances. Secondly, disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated load could cause electrical system perturbations.

Finally, the DG in test mode is more susceptible to tripping due to the extra protective trip relays that are in effect during test mode operations.

4.2.1.1 Grid Disturbances The concern of performing the full load rejection surveillance test in Mode 1 or 2, while connected to offsite power or generator output, is that the DG is susceptible to grid disturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsite power system or generator output in the test mode of operation, the availability of the DG for subsequent emergency operation could be adversely affected due to the potential for common mode vulnerability. However, only one DG per unit is paralleled to offsite power or generator output at any one time and any grid disturbances would only possibly affect one DG.

Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, to prohibit switchyard work during performance of this surveillance. This will minimize the likelihood of a power disturbance or fault related to switchyard activities. Therefore, the justification for this proposed change is based on the fact that the remaining DG would remain operable and is capable of mitigating a DBA. The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdown of the associated unit with the remaining DG operable.

In the case where a disturbance affects the DG being tested, protective relaying protects the DG from equipment damage. This feature causes the DG output breaker to trip, separating the DG from its associated safety-related 4160v bus. In the event of a DG protective device trip, the DG could be restored via operator action.

As part of the online risk management process at CNP, risk management considerations ensure that this and other SRs are not scheduled during periods where there is increased potential for grid or bus disturbance (storms, grid emergencies, etc.). Performance of the full load rejection surveillance test per SR 3.8.1.11, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently tests its DGs paralleled to offsite power or generator output during required monthly surveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.

4.2.1.2 Electrical Perturbations The concern during this testing is that suddenly disconnecting a DG from the associated bus on a full load rejection surveillance test could cause a voltage fluctuation on that bus that could potentially perturb the onsite AC electrical system. However, industry experience shows that to AEP-NRC-2014-70 Page 7 there is no significant electrical distribution system effect on the associated bus during a full load rejection surveillance test. Therefore, performing full load rejection surveillance tests in accordance with SR 3.8.1.11 in any modes would not cause a significant perturbation that would adversely affect the onsite AC electrical system.

4.2.1.3 Protective Trip Relays During full load rejection surveillance testing of DGs while in test mode, non-emergency trip features are in effect to protect the DG from equipment damage due to equipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with these non-emergency trips in effect, the affected DG will automatically revert to the emergency mode and bypass these trips. No operator action is required. Upon detection of under voltage on the safety-related 4160v bus, load shedding for all vital loads and non-permanently connected loads from the 4160v bus would occur followed by re-sequencing of the vital loads back onto the affected 4160v bus. The operators receive indication and alarms in the control room that the preferred power source is lost. In addition, the proposed change does not impact voltage regulation and DG governor system operation during surveillance testing.

Finally, the proposed test configuration for the full load rejection surveillance test is similar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthly surveillance test run), which is performed during Mode 1.

4.3 Changes to SR 3.8.1.15 (DG endurance surveillance test run) 4.3.1 Deletion of mode restriction note from SR 3.8.1.15 The concerns of performing the DG endurance surveillance test run (8-hour load run) required by SR 3.8.1.15 in Mode 1 or 2 are the DG being tested is susceptible to grid disturbances and the additional protective trip features would be in place making the DG more vulnerable to a possible trip while being parallel with the offsite power or generator output source.

4.3.1.1 Grid Disturbances The concern with performing the endurance run in Mode 1 or 2, while connected to offsite power or generator output, is that the DG is susceptible to grid disturbances. Only one DG per unit is paralleled to offsite power or generator output at any one time and any grid disturbances would only possibly affect one DG. Therefore, the justification for this proposed change is based on the fact that the redundant train DG would remain operable and is capable of mitigating a DBA.

The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdown of the associated unit with the remaining DG operable.

In the case where a disturbance affects the DG being tested, protective relaying protects the DG from equipment damage. This feature causes the DG output breaker to trip, separating the DG from its associated safety-related 4160v bus. In the event of a DG protective device trip, the DG could be restored via operator action.

to AEP-NRC-2014-70 Page 8 As part of the online risk management process at CNP, risk management considerations ensure that this and other SRs are not scheduled during periods where there is increased potential for grid or bus disturbance (storms, grid emergencies, etc.). Performance of the endurance run surveillance test per SR 3.8.1.15, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently tests its DGs paralleled to offsite power or generator output during required monthly surveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while in Mode 1 or 2.

4.3.1.2 Trip Relays During endurance run surveillance testing of DGs while in test mode, non-emergency trip features are in effect to protect the DG from equipment damage due to equipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with these non-emergency trips in effect, the affected DG will automatically revert to the emergency mode and bypass these trips. No operator action is required. Upon detection of under voltage on the safety-related 4160v bus, load shedding for all vital loads and non-permanently connected loads from the 4160v bus would occur followed by re-sequencing of the vital loads back onto the affected 4160v bus. The operators receive indication and alarms in the control room that the preferred power source is lost. Therefore, these additional trip functions are not a significant concern during performance of the DG endurance surveillance test runs while in Mode 1 or 2.

In addition, the remaining DG will be available to respond and mitigate a DBA or provide safe shutdown capability.

Finally, the proposed test configuration for the DG endurance surveillance test run is similar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthly surveillance test run), which is performed while in Mode 1.

4.4 Risk assessment for performing DG single largest load rejection surveillance test (SR 3.8.1.10), DG full load reiection surveillance test (SR 3.8.1.11). and DG endurance surveillance test run (3.8.1.15) in Mode I or 2.

Currently, when the DG single largest load rejection surveillance test, the DG full load rejection surveillance test, and the DG endurance surveillance test run are performed they may be performed in Mode 5 or 6. When a DG is undergoing any of these three tests it is considered inoperable but available to respond to design based accidents.

Performing these tests in Mode 1 or 2 does not change the potential level of risk during these tests. As in Modes 5 and 6, the DG is available and capable of performing its safety functions.

The determination of availability of the DG in test is consistent with the definition of unavailable in NUMARC 93-01, Revision 4A, Appendix B, which states: "SSCs out of service for testing are considered unavailable, unless the test configuration is automatically- overridden by a valid starting signal, or the function can be promptly restored either by an operator in the control room or by a dedicated operator stationed locally for that purpose. Restoration actions must be contained in a written procedure, must be uncomplicated (a single action or a few simple actions), and must not require diagnosis or repair...." Per the above discussion, for these tests the DG in test will remain available per these guidelines. As a result, there is no increase in unavailability of the DG and there is a minimal increase in the risk.

to AEP-NRC-2014-70 Page 9 Also, a review was conducted of DG starts at CNP for the last 10 years (DG starts since January 1, 2004) as well as a search of the CNP Corrective Action Program for that same time period. This search included all four DGs (two DGs in Unit 1 and two DGs in Unit 2) and no results were found of an instance where any starts have caused additional problems to the DGs themselves, other CNP equipment, or the electrical grid any different regardless of the mode in which the DG was actually started.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Reguirements/Criteria Regulatory Requirements UFSAR Section 1.4, "Plant Specific Design Criteria (PSDC)", defines the principal criteria and safety objectives for the CNP design. The following PSDC is relevant to the proposed amendment:

"CRITERION 39 Emergency Power An emergency power source shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning of the ESF and protection systems required to avoid undue risk to the health and safety of the public. This power source shall provide this capacity assuming a failure of a single active component."

The design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the ESF systems. The onsite Class 1E AC distribution system for I&M is divided into two load groups. A safety-related 4160v bus is associated with each load group. The two load groups are 100% redundant and are electrically and physically separated such that the loss of either group does not prevent the minimum safety functions from being performed. Each load group has connections to either of two offsite power sources from the switchyard, and a single DG. Offsite power is supplied to the switchyard from the transmission network via two rights of way approaching the site from two different directions.

The proposed changes modify plant condition requirements for the test of the DGs which provide emergency power to the safety-related 4160v buses in the event of a LOOP. The test requirements are intended to verify and/or ensure continued OPERABILITY of the DGs. The proposed changes involve no changes to the required tests themselves except to allow certain tests to be performed during modes for which performance of the affected tests is currently prohibited. Evaluation of the proposed changes has determined that DG availability is not significantly affected by the proposed changes, that the potential for significantly adverse electrical perturbations during tests such as SR 3.8.1.11 (Full-Load Rejection Test) is acceptably low, and that the potential for a grid disturbance causing DG unavailability while a DG is in test is quite low. Further, only one DG will be tested at a time such that OPERABILITY of the redundant train DG and its associated bus and bus loads will be unaffected. Testing will thus continue in a manner that supports redundant train DG OPERABILITY so that both DGs to AEP-NRC-2014-70 Page 10 will be available to perform their intended safety function consistent with regulatory requirements.

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 and safety of the public.

5.2 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, I&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend the Appendix A TS to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes amending SR 3.8.1, "AC Sources". 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 design of plant equipment is not being modified by the proposed changes. In addition, the DGs and their associated emergency loads are accident mitigating features. As such, testing of the DGs themselves is not associated with any potential accident-initiating mechanism. Therefore, there will be no significant impact on any accident probabilities by the approval of the requested changes.

The changes include an increase in the time that a DG under test will be paralleled to the grid while the unit is in Modes 1 or 2. As such, the ability of the tested DG to respond to a DBA could be minimally adversely impacted by the proposed changes. However, the impacts are not considered significant based, in part, on the ability of the remaining DG to mitigate a DBA or provide safe shutdown. Experience shows that testing for these SRs typically does not perturb the electrical distribution system. In addition, operating experience supports the conclusion that the proposed changes do not involve any significant increases in the likelihood of a safety-related bus blackout or damage to plant loads.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an 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 capability to synchronize a DG to the offsite source (via the associated plant bus) and test the DG in such a configuration is a design feature of the DGs, including the test mode override in response to a safety injection signal. Paralleling the DG for longer periods of to AEP-NRC-2014-70 Page 11 time during plant operation may slightly increase the probability of incurring an adverse effect from the offsite source, but this increase in probability is judged to be still quite small and such a possibility is not a new or previously unrecognized consideration.

The proposed change does not introduce a new mode of plant operation and does not involve physical modification to the plant. The change does not introduce new accident initiators or impact assumptions made in the safety analysis.

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

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

Response: No The proposed changes do not exceed or alter a design basis or safety limit, so there is no significant reduction in the margin of safety. The margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation. These barriers include the fuel cladding, the reactor coolant system, and the containment system. The proposed changes do not directly affect these barriers, nor do they involve any significantly adverse impact on the DGs which serve to support these barriers in the event of an accident concurrent with a LOOP. The proposed changes to the testing requirements for the plant DGs do not affect the OPERABILITY requirements for the DGs, as verification of such OPERABILITY will continue to be performed as required (except during different allowed modes). The changes have an insignificant impact on DG availability, as the DGs remain available to perform their required function of providing emergency power to plant equipment that supports or constitutes the fission product barriers. Only one DG is to be tested at a time, so that the remaining DG will be available to safety shut down the plant if required. Consequently, performance of the fission product barriers will not be impacted by implementation of the proposed amendment.

In addition, the proposed changes involve no changes to setpoints or limits established or assumed by the accident analysis.

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

Based on the above, I&M concludes that the proposed amendment presents 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.

5.3 Conclusion 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 and safety of the public.

to AEP-NRC-2014-70 Page 12

6.0 ENVIRONMENTAL CONSIDERATION

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. However, 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(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 PRECEDENCE

1. Amendment 173 to Columbia Generating Station Operating License (

Subject:

Columbia Generating Station Operating License NPF-21 Request for Technical Specifications Amendment to Remove Operating Mode Restrictions for Emergency Diesel Generator Surveillance Testing, dated May 18, 2001.)

2. Amendment 154 to Wolf Creek Generating Station Operating License (

Subject:

Wolf Creek Generating Station - Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4

-AC and DC Sources, dated July 12, 2004.)

3. Amendment 167 to Palo Verde Generating Station Operating License (

Subject:

Palo Verde Nuclear Generating Station, Units 1, 2, and 3- Issuance of Amendments RE: AC Sources -

Operating Surveillance Requirements, dated May 16, 2007.

8.0 REFERENCES

1. 10 CFR 50.90, "Application for amendment of license, or construction permit, or early site permit"

2. 10 CFR 50.36, "Technical Specifications"

3. Indiana and Michigan Power D. C. Cook Nuclear Plant Updated Final Safety Analysis Report, Revision 25

Enclosure 3 to AEP-NRC-2014-70 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW CHANGES

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY i

SR 3.8.1.10 NOTES ---------------

1 Thist Su~eiir aR~i~c shall not nermaivh be wv anr~r~u~ -I ~.. '~ LI......

p~;IL;;f !R Mn 60FL A Sureilanc ma beperformned to reestablish OPERA.BILITY provided an assessment A-+-rmi.-p fhe- pfh rf +k- .,nw+0ý m..r-nt'nnippd flf k~2, 4Ln

+a fnr v

4. 4. Lý 4-: Ir 4&L-; 0 M HH" RAAA RVAP :R 19 5.- If performed with the DG synchronized with offsite power, it shall be performed at a power factor < 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG rejects a load greater than or equal 24 months to its associated single largest post-accident load, and:

a. Following load rejection, the frequency is

< 64.4 Hz;

b. Within 2 seconds following load rejection, the voltage is > 3910 V and < 4400 V; and

c. Within 2 seconds following load rejection, the frequency is > 59.4 Hz and < 60.5 Hz.

Cook Nuclear Plant Unit 1 3.8.1-9 Amendment No. 287, 294, 309

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY i

SR 3.8.1.11 NOTES ---------------

1. This Surveillance shall not normally be perfoermed in MODE 1 Or 2. However, this SurveillanGe may be performed to reestablish OPERA\BILITY provided an assessment determines the safety of the unit is maint-ained or enhanced. Credit may be taken for-i Jl m unpiaRneci events that satisry this Si.

fI2. If performed with DG synchronized with offsite power, it shall be performed at a power factor

< 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG does not trip and voltage is 24 months maintained < 5350 V during and following a load rejection of > 3150 kW and < 3500 kW.

Cook Nuclear Plant Unit 1 3.8.1-10 Amendment No. 27-7, 294, 295

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 NOTE--------------- ----------------

This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are bypassed on 24 months an actual or simulated loss of voltage signal on the emergency bus or an actual or simulated ESF actuation signal except:

a. Engine overspeed; and

b. Generator differential current.

SR 3.8.1.15 ------------- NOTES ---------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

, ~ ~~~~~

ue'mglfmIý,. I I

'I II n^

I nflrnI n II I f

in I~CW~ ,.. ~ ~ +hiy 2Suveilla;nrLe may be nerfOrmed to reestab-lish

/-%lr-*pl-* A I'*11 I'IP\I deterl Lmine E* t fGety of teniimntnine

1". * * .'J t"* .*,'J ;* 4 . ["* *1* $*

no t1, iain it e . v nts that stn*4 LIthus nR.

unclanned e'-ents that satisf'- this SR.

If performed with DG synchronized with offsite power, it shall be performed at a power factor

< 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months at a load 24 months

> 3150 kW and < 3500 kW.

Cook Nuclear Plant Unit 1 3.8.1-13 Amendment No. 287, 291

Enclosure 4 to AEP-NRC-2014-70 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGES MARKED TO SHOW CHANGES

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.10 -------------- NOTES ---------------

1I Thic. , h',il nr+

cmaI.n~ nr~n, =11y ho If nrnAt ;r RAfll ME ar 1) W-nna #k;hic c.

OPERABI LITY provided an assessment or enhanced. Credit may be taken-for unplanned events that satisfy this SRm E2. If performed with the DG synchronized with offsite power, it shall be performed at a power factor < 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG rejects a load greater than or equal 24 months to its associated single largest post-accident load, and:

a. Following load rejection, the frequency is

< 64.4 Hz;

b. Within 2 seconds following load rejection, the voltage is > 3910 V and < 4400 V; and

c. Within 2 seconds following load rejection, the frequency is > 59.4 Hz and < 60.5 Hz.

Cook Nuclear Plant Unit 2 3.8.1-9 Amendment No. 269, 27-3, 291

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 NOTES ---------------

I. This Su'p-eillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABI LITY provided an assessment detemnines the safety of the unit is maintained or enhan-ed. Cred-it ma" be taken Gfo unplanned events that satisfy this SR.

IE2. If performed with DG synchronized with offsite power, it shall be performed at a power factor

< 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG does not trip and voltage is 24 months maintained < 5350 V during and following a load rejection of > 3150 kW and < 3500 kW.

Cook Nuclear Plant Unit 2 3.8.1-10 Amendment No. 2-6-, 2-7-3, 276

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY i

SR 3.8.1.14 ----------------

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

This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the unit is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify each DG's automatic trips are bypassed on 24 months an actual or simulated loss of voltage signal on the emergency bus or an actual or simulated ESF actuation signal except:

a. Engine overspeed; and

b. Generator differential current.

SR 3.8.1.15 --------------- -NOTES ---------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

perfo)rmed inMODE 1 Or 2. However, this-Survillncemay be performed to reestablish OPEIR-ABILITY provided an assessment determnines the safety of the un~it is maintained

^r anOr~AfraA.+t M-, him +nLkat3 (p)

I e4m 4k +~e#+ M fý +hke

+.'na+~a~ QD urip Or1riv vvvri CY Ct VC1 0 0 E3-. If performed with DG synchronized with offsite power, it shall be performed at a power factor 5 0.86. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months at a load 24 months

> 3150 kW and <3500 kW.

Cook Nuclear Plant Unit 2 3.8.1-13 Amendment No. 2-69, 273

Enclosure 5 to AEP-NRC-2014-70 DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGES MARKED TO SHOW CHANGES (INFORMATIONAL)

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

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15% above nominal speed, whichever is lower. This corresponds to 64.4 Hz, which is the nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 2 seconds specified is equal to approximately 60% of the 3.49 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG. SR 3.8.1.1O.a corresponds to the maximum frequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steady state voltage and frequency values to which the system must recover following load rejection. The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performnance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This re*sFtitionr f rm Rormally performing the Surveillance in MODE 1 or 2 isfu'e amplified to allow the Surveillance to be performned for the purpose Of reestablishing OPERABILITY (e.g., post work testing fooIwInIg corrective mnaintenance, correctiVe modification, deficient Or incomplete sur-ve*ilance testing, and other un;anipae 0-PEABILITY concerns) provided an assessm.en determin*es unit saft is maintained G.

enhanced. This assessm~ent shall, as a minimum, consider the potential outcom~es and transients associated with a failed Surveillance_,a successful SuIveillance, and a perturbation of the offsite Or onsite system when they are tied together or operated idpnetyfor the Su,*eilla*ne; as well as the peratoFr prroedures available to cope With these outcomnes. These shall be measured against the avoided risk of a unit shutdown and startup to det6rMinP that uIt IRsafety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Revision No. 41 B 3.8.1-21 Cook Nuclear Plant Cook Nuclear Unit 1 Plant Unit 1 B 3.8.1-21 Revision No. 41

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

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

Note 2-]N ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of S 0.86.

This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2N allows the Surveillance to be conducted at a power factor other than < 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to < 0.86 results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

SR 3.8.1.11 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, this Surveillance demonstrates the DG capability to reject a full load (90% to 100% of the DG continuous rating) without overspeed tripping or exceeding the predetermined voltage limits. The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for Revision No. 41 1 B 3.8.1-22 Cook Plant Unit Nuclear Plant Cook Nuclear Unit 1 B 3.8.1-22 Revision No. 41

AC Sources - Operating B 3.8.1 future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR has been modified by two Notes. The reason f*F Note 1 is that during operation with the reactor critical, performance of this SR could Revision No. 41 Unit I1 B 3.8.1-23 Nuclear Plant Cook Nuclear Plant Unit B 3.8.1-23 Revision No. 41

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) challenge continued steady ,tate operation and, as a result, unit safet systems. This restriction from normally performing the Sur'veillance i v,,-,,-I for the pur.poe Of reestabli-h*ing PER.BI LITY (e.g., post work testing following corrective maintenance, corrective mmdification, deficient o n inGomplete surhvn IeillaesiRg, and othe runRantficipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enrhaned. This assessmenrt shall, as a minimumo, conider the potertial outonmes and transierts assciated with a failed Surveillance, a successful Suveillance, and a perturbeation of the offsite or onsite systemo when they are tied together oe operated independertly for the SuhveillaNce; as well as the operator procedures available to cope with these outconmes. These shall be measured against the avoided risk of a unit shutdown and startup to determnine that unit safety is mnaintained or enhanced when the Surveillance is perftorned in MODE 1 or 2. Risk inRsights OrFeemnsi methods mnay be used for this assessment.

redit may beetaken forgunplanned events that satisfy this SR. Note 2Fih ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of 5 0.86. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note ORjallows the Surveillance to be conducted at a power factor other than 5 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to

<ay0.86 results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

Revision No. 41 1 B 3.8.1-24 Cook Plant Unit Nuclear Plant Cook Nuclear Unit 1 B 3.8.1-24 Revision No. 41

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

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

SR 3.8.1.15 This Surveillance demonstrates the DGs can start and run continuously at full load capability (90% to 100% of the DG continuous rating) for an interval of not less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The run duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is consistent with IEEE Standard 387-1995 (Ref. 11). The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections being required in order to maintain DG reliability.

The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This Surveillance is modified by Frh Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, perfrmance of this Sue..illance could.,

cause perturbations to the electrical distribution systems that could challenge conAtinlued steady 6tate operation and, as a result, unit safety systemns. This restriction fromn noarmally performing the Surveillancc in Cook Nuclear Plant Unit 1 B 3.8.1-29 Revision No. 41

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) hA DF= I Cjr ') ffigfiir+kpr p lofipt4 +^ pllpjAg thp S;i impmIlpriga +a him niarfnpmad for the purpose of reestablishing OPERA.BILITY (e.g., post work testing following corrective mnaintenance, corrective II modification, deficient l . r .......

h or incomplete sun eillanTe testing, and other unaRticipated OPERABILITY concerns) provided an assessment determines unit safety is maiintainA.eda or enhanced. This assessment shall, as a mnimumn, consider the potential outcomes and transients associated with failed SRmveillane, -a succesfulSurveillance, and a perturbaptine of the offfsite or onsite system when they are tied together or operated idpnetyfor the Surveillance; as well as the operator procedures available to cope with these outcomnes. These shall be mneasured against the -avofidedrisk of a unit shutdown and startup to determnine that unit safety is mnaintained OF enhanced when the Surveillance is performned in MODE 1 or 2. Risk aR~ioht5 or dteF in~tir-Mothnir;Fnay be h used for thus assesment Credit may be taken for unplanned evens* that satisfy this SR.. Note..12 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of < 0.86. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note P21233 allows the Surveillance to be conducted as a power factor other than < 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to < 0.86 results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

SR 3.8.1.16 Revision No. 41 Unit 1 B 3.8.1-30 Nuclear Plant Cook Nuclear Plant Unit 1 B 3.8.1-30 Revision No. 41

Enclosure 6 to AEP-NRC-2014-70 DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGES MARKED TO SHOW CHANGES (INFORMATIONAL)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) derived from Regulatory Guide 1.9 (Ref. 3) recommendations for response during load sequence intervals. The 2 seconds specified is equal to approximately 60% of the 3.49 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG. SR 3.8.1.10.a corresponds to the maximum frequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steady state voltage and frequency values to which the system must recover following load rejection. The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Thir SR is modified by two .ntes. The reason for Note 1 is that during operation with the reac.to critical, peFor.mance of this SR could cause perturbations to the e ical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This, restriction from normally perfo~rming the Survefillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose-of reestablishing OPERA~BILITY (e'g., post work testing following corrective main~tenance, corri-rectivemoifiaton deficient Or incomplete surveillance testfing, and Other u-nanticipated OPERABILITY concerns) enhanced. This assessment shall, astadminimum, consider the potential outcomes and transients associated ith a fpaile.d SuWh a-eilnchronzed, successful Supreillanre, anda perti ation of the onduite onsite system when they aro tied together or operated inenddetntl for the Surveillance; as well as the operator procedures avalilableA to-cope with these outcomnes. These shall be measured against the avoided risk of a unit shutdown and startup to determ~ine that unit safety is mnaintained or enhadned wherthe Surveillance is performed in MODE 1 or 2. Risk insights or determfinistic methods may be used for this assessment.

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

Note F1j2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of *5 0.86.

This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note rlj!2 allows the Surveillance to be conducted at a power factor other than - 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power fertfnr *n< n RR raci nlfQ in \,nlri n nn thp Pmmsrnr-nr% hi nQ=P thnt nrm fnn41 3.8.1-21 Revision No.

2 Unit 2 Plant Unit B Nuclear Plant Cook Nuclear B 3.8.1-21 Revision No. 41

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

Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

SR 3.8.1.11 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, this Surveillance demonstrates the DG capability to reject a full load (90% to 100% of the DG continuous rating) without overspeed tripping or exceeding the predetermined voltage limits. The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG does not trip upon loss of the load. These acceptance criteria provide for DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus ifthe trip initiator can be corrected or isolated.

The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR has, been Modified by two Notes. The resnfor Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribu1tion systems6 that col Ghallenqe continued- steady state opeation and, as a result, unit safety Cook Nuclear Plant Unit 2 B 3.8.1-22 Revision No. 41

AC Sources - Operating B 3.8.1 systems. T-his restriction fromn normally pedorm~ing the Surveillance in MODE 1 Or 2 is fudther amplified to allow the Surveillance to be perfrmed for the purpose of reestablishing OPERABILITY (e.g., post work testiRg following corrective mnaintenance, co~rrective moedification, deficient or incGomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment d~eterm~ines unit safety is Maintained o-r enhanc~ed. This assess6ment shall, as a minimum, consider the potential ou1tcomes and transients associated with a failed Surveillance, a successfiul Surveilln*ce, and a pedIurbationof the offsite or onsito system vR ter irey aIr Lieu tn! eTrlIC C* U-JCILC at irnuependuenrtly i9 te-Cook Nuclear Plant Unit 2 B 3.8.1-23 Revision No. 41

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

Survleillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a unit shutdown andstartup to deter;ine that unit safety is maintained er enhan-edd When the Suirveillance is performned On MODE 1 or 2. Risk ins~ights or determn~iistic methods m;ay be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note F120 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of < 0.86. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note N allows the Surveillance to be conducted at a power factor other than < 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to

< 0.86 results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

SR 3.8*1.12 Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.4, this Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltag'e and frequency within the specified time.

The DG autostart time of 10 seconds is derived from requirements of the a(;I*, enI aaly58 W rOesp1 MolaeSgll a I2 1asi I1a-I e reaK t, U ,. I Me Cook Nuclear Plant Unit 2 B 3.8.1-24 Revision No. 41

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

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

SR 3.8.1.15 This Surveillance demonstrates the DGs can start and run continuously at full load capability (90% to 100% of the DG continuous rating) for an interval of not less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The run duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is consistent with IEEE Standard 387-1995 (Ref. 11). The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections being required in order to maintain DG reliability.

The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This Surveillance is modified by e Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test.

Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance couild cause perturbationS to the electrical distribution systems that ceuld challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to alloW the Su1,rveillaRne to be performed for the purpose of reestablishing OPERA.BILITY (e.g., post work testing following correctiVe maintenance, corrective modification, deficient or incomplete surveillancGe testing, and other unanticipated OPERABI LITY concerns) provided an assessment determines unit safety is maintained or enhanced. This assessment shall a a miniMum, consider the potential ouGtmres ad tran.s* ets s;oqcSated with a failed SureillaRe, a Successful Su.veillance, and a perturbation of the offs.te Or olsite system when they are tied together Or operated independently for the-Sureilane;as well as the operator procedures available to cope with Cook Nuclear Plant Unit 2 B 3.8.1-27 Revision No. 41

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) these outcomes. These shall be measured against the aoddrisk of a unit shutdown and startup to determine that unit safety is maintained or enhanced when. the Sur....eil.an.e is performed in MODE 1 or 2. Risk 4nsgnis or eRIne!noaS may Be used TOF Mis asses .

Credit may be taken for unplanned events that satisfy this SR-. Note M3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of < 0.86. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note M3 allows the Surveillance to be conducted as a power factor other than < 0.86. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to < 0.86 results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to 0.86 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.86 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained close as practicable to 0.86 without exceeding the DG excitation limits.

Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessment shall be performed to determine that plant safety is maintained. As part of this assessment weather conditions will be assessed, and the SR will not be scheduled when severe weather conditions and/or unstable grid conditions are predicted or present. Also, no discretionary maintenance activities will be scheduled which could cause a line outage or challenge offsite power availability. Additionally, no switchyard activities will be allowed during the performance of this surveillance.

SR 3.8.1.16 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances, and achieve the required voltage and frequency within 10 seconds. The 10 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. The 24 month Frequency is based on engineering judgement, taking into consideration unit conditions required to perform the Surveillance.

Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load ban isprvded to Cook Nuclear Plant Unit 2 B 3.8.1-28 N 41 Re vision No.