Text

License Amendment Request to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability
	ML15041A069
Person / Time
Site:	Cook
Issue date:	02/06/2015
From:	Lies Q; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2015-03
	Download: ML15041A069 (25)
	v • d • e

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POW.ER*

One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power IndianaMichiganPower.com February 6, 2015 AEP-NRC-2015-03 10 CFR 50.90 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant, Units 1 and 2 LICENSE AMENDMENT REQUEST TO ADOPT TSTF-427, REVISION 2, "ALLOWANCE FOR NON TECHNICAL SPECIFICATION BARRIER DEGRADATION ON SUPPORTED SYSTEM OPERABILITY"

Reference:

TSTF-427, Revision 2, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," dated May 3, 2006.

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Indiana Michigan Power Company (I&M) is submitting a request for an amendment to the Technical Specifications (TS) for Donald C. Cook Nuclear Plant, Units 1 and 2. The proposed changes would modify TS requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.8. to this letter provides an affirmation statement pertaining to the information contained herein. Enclosure 2 provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications.

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. provides a summary of the regulatory commitments made in this submittal.

I&M would like to request NRC review and approval of the proposed change by April 15, 2015, to support plant maintenance activities. This amendment will allow for maintenance activities on the motor driven auxiliary feed water pump (MDAFP) room coolers while at power, which has historically taken greater than the 72-hour Completion Time allowed by the TS Action Statement for inoperability of one MDAFP train.

The MDAFPs require their attendant room coolers to be functional to maintain operability. With the room cooler out of service for maintenance, room cooling can be established by opening the door to the MDAFP room. However, opening the door breaches the boundary that protects the MDAFP from a High Energy Line Break. The addition of this LCO permits the barrier to be breached during room cooler maintenance without having to enter the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months action statement for the MDAFP, thereby avoiding the need for a potential plant

U. S. Nuclear Regulatory Commission Page 2 AEP-NRC-2015-03 shutdown.

The MDAFP room cooler can perform its function with cooling water alone when lakewater (the source of cooling) temperature is below 55 degrees (0) Fahrenheit (F). Above that temperature, supplemental cooling is required. Recent performance of the supplemental cooling equipment has indicated the increased potential for room cooler replacement. Therefore, approval of the proposed change is requested by April 15, 2015, since historical average lake temperature approaches the 55 0F threshold in the second half of April.

The proposed change will be implemented within 90 days of NRC approval and sooner if needed based on plant conditions.

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.

Should you have any questions, please Manager, at (269) 466-2649.

Sincerely, Quinton S. Lies Engineering Vice President Indiana Michigan Power Company DB/amp

Enclosures:

contact Mr. Michael K. Scarpello, Regulatory Affairs

1.

Affirmation

2.

Evaluation of Proposed Changes

3.

Donald C. Cook Nuclear Plant Unit 1 Proposed Changes

4.

Donald C. Cook Nuclear Plant Unit 2 Proposed Changes.

5.

Donald C. Cook Nuclear Plant Unit 1 Show Proposed Changes.

6.

Donald C. Cook Nuclear Plant Unit 2 Show Proposed Changes

7.

Regulatory Commitments Technical Specification Pages Marked To Show Technical Specification Pages Marked To Show Technical Specification Bases Pages Marked To Technical Specification Bases Pages Marked To c:

M. L. Chawla, NRC Washington DC 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-2015-03 AFFIRMATION I, Quinton S. Lies, being duly sworn, state that I am the Engineering Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the U. S. 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 Quinton S. Lies Engineering Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF Ve--c,.o,.c, 2015 MyCommissiNotary Pirs My Commission Expires

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DANIELLE BURGOYNE Notary Public, State of Michioan my cornounty of Berrien Acting rnssion Expires 04-04-2018 f th. COunty to AEP-NRC-2015-03 Evaluation of Proposed Changes This letter is a request to amend Operating License Numbers DPR-58 and DPR-74 for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, respectively.

In this request, Indiana Michigan Power Company (I&M) proposes to implement Technical Specification Task Force (TSTF) change traveler TSTF-427, Revision 2,

"Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," dated May 3, 2006, at CNP.

1.0 DESCRIPTION

The proposed amendment would modify Operating License Numbers DPR-58 and DPR-74 for CNP Units 1 and 2, respectively. In this request, I&M proposes to revise Technical Specification (TS) requirements for unavailable barriers by adding Limiting Condition for Operation (LCO) 3.0.8.

The changes are consistent with U. S. Nuclear Regulatory Commission (NRC) approved Industry/TSTF Standards TS change TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," Revision 2. The availability of this TS improvement was published in the Federal Register on October 3, 2006 (71 FR 58444), as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation I&M has reviewed the safety evaluation (SE) published on October 3, 2006 (71 FR 58444), as part of the CLIIP, "Notice of Availability of the Model Safety Evaluation." This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-427. I&M has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to CNP and justify this amendment for the incorporation of the changes to the CNP TS.

2.2 Optional Changes and Variations I&M is not proposing any technical variations or deviations from the TS changes described in the TSTF-427, Revision 2, or the NRC staff's model SE dated September 25, 2006. However, there is one administrative deviation which is in the numbering scheme associated with the CNP Unit 1 and Unit 2 TSs. CNP does not currently have an LCO 3.0.8; therefore, when reviewed and approved by the NRC, I&M will be adding LCO 3.0.8 into the TSs instead of 3.0.9 as described in TSTF 427, Revision 2.

In addition, I&M used Regulatory Guide (RG) 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3, dated May 2012, as basis for this change.

to AEP-NRC-2015-03 Page 2 RG 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," Revision 0, was specified in the TSTF; however, it was subsequently withdrawn.

RG 1.160, supersedes RG 1.182, Revision 0 and endorses Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

Revision 4A, dated April 2011.

3.0 REGULATORY ANALYSIS

3.1 No significant Hazards Consideration Determination I&M has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP.

I&M has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to I&M and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on September 25, 2006, for this TS improvement, plant-specific verifications were performed as follows:

1. I&M commits to the guidance of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Section 11, which provides guidance and details on the assessment and management of risk during maintenance.

2. I&M will revise procedures to ensure that the risk assessment and management process described in Nuclear Energy Institute 04-08, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427) Industry Implementation Guidance," March 2006, is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.8 are applied, in accordance with an overall configuration risk management program to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided.

3. I&M will establish the TS Bases for LCO 3.0.8 as adopted with the applicable license amendment. The TS bases markup pages are in Enclosures 5 and 6 of this letter. The TS bases changes are for information only and will be implemented in accordance with CNP TS 5.5.12, TS Bases Control Program.

4.0 ENVIRONMENTAL EVALUATION I&M has reviewed the SE published on October 3, 2006 (71 FR 58444) as part of the CLIIP, "Notice of Availability of the Model Safety Evaluation."

I&M has concluded that the staff's findings presented in that evaluation are applicable to I&M and the evaluation is hereby incorporated by reference for this application.

to AEP-NRC-2015-03 Page 3

5.0 REFERENCES

1. Federal Register Notice (71 FR 58444), dated October 3, 2006, "Notice of Availability of Model Application concerning Technical Specification Improvement To Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process."

2. Technical Specification Task Force Improved Technical Specification Change Traveler, TSTF-427, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY," Revision 2, Agencywide Documents Access and Management System Accession No. ML061240055.

to AEP-NRC-2015-3 Donald C. Cook Nuclear Plant Unit I Technical Specification Pages Marked to Show Proposed Changes

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 aa41-LCO 3.0.7, and LCO LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b.

MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c.

MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or Cook Nuclear Plant Unit 1 3.0-1 Amendment No. 287

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 (continued)

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, "PHYSIC TESTS Exceptions - MODE 2,"

allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO 3.0.8 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be Cook Nuclear Plant Unit 1 3.0-2 Amendment No. 287

LCO Applicability 3.0 concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

Cook Nuclear Plant Unit 1 3.0-3 Amendment No. 287 to AEP-NRC-2015-03 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked to Show Proposed Changes

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.

aPAd-LCO 3.0.7, and LCO M

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a.

MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b.

MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c.

MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or Cook Nuclear Plant Unit 2 3.0-1 Amendment No. 269

LCO Applicability 3.0 3.0 LCO Applicability LCO 3.0.4 (continued)

c.

When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.13, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, "PHYSIC TESTS Exceptions - MODE 2,"

allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

LCO 3.0.8 When one or more required barriers are unable to perform their related support function(s), any supported system LCO(s) are not required to be declared not met solely for this reason for up to 30 days provided that at least one train or subsystem of the supported system is OPERABLE and supported by barriers capable of providing their related support function(s), and risk is assessed and managed. This specification may be Cook Nuclear Plant Unit 2 3.0-2 Amendment No. 269

LCO Applicability 3.0 concurrently applied to more than one train or subsystem of a multiple train or subsystem supported system provided at least one train or subsystem of the supported system is OPERABLE and the barriers supporting each of these trains or subsystems provide their related support function(s) for different categories of initiating events.

If the required OPERABLE train or subsystem becomes inoperable while this specification is in use, it must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the provisions of this specification cannot be applied to the trains or subsystems supported by the barriers that cannot perform their related support function(s).

At the end of the specified period, the required barriers must be able to perform their related support function(s) or the supported system LCO(s) shall be declared not met.

Cook Nuclear Plant Unit 2 3.0-3 Amendment No. 269 to AEP-NRC-2015-03 Donald C. Cook Nuclear Plant Unit I Technical Specification Bases Pages Marked to Show Proposed Changes (For Information Only)

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.7-9 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.9 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a.

Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b.

Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be Cook Nuclear Plant Unit 1 B 3.0-1 Revision No. 0 Cook Nuclear Plant Unit 1 B 3.0-1 Revision No. 0

LCO Applicability B 3.0 BASES LCO 3.0.6 (continued) emergency electrical power source (refer to the definition of OPERABILITY).

When loss of safety function is determined to exist, and the SFDP requires entry into the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists, consideration must be given to the specific type of function affected. Where a loss of function is solely due to a single Technical Specification support system (e.g., loss of automatic start due to inoperable instrumentation, or loss of pump suction source due to low tank level) the appropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately address the inoperabilities of that system without reliance on entering its supported system LCO. When the loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the supported system.

LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.

Test Exception LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2,"

allows specified Technical Specification (TS) requirements to be changed to permit performances of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.

The Applicability of a Test Exception LCO represents a condition not necessarily in compliance with the normal requirements of the TS.

Compliance with Test Exception LCOs is optional. A special operation may be performed either under the provisions of the appropriate Test Exception LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Test Exception LCO, the requirements of the Test Exception LCO shall be followed.

LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical specifications, that support the performance of the safety function of Cook Nuclear Plant Unit 1 B 3.0-10 Revision No. 0

LCO Applicability B 3.0 systems described in the Technical specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support function(s) under the described conditions. LCO 3.0.8 allows 30 days before declaring the supported system(s) inoperable and the LCO(s) associated with the supported system(s) not met. A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored.

However, the allowable duration may be less than the specified maximum time based on the risk assessment.

If the allowed time expires and the barriers are unable to perform their related support function(s), the supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

This provision does not apply to barriers which support ventilation systems or to fire barriers. The Technical Specifications for ventilation systems provide specific Conditions for inoperable barriers. Fire barriers are addressed by other regulatory requirements and associated plant programs. This provision does not apply to barriers which are not required to support system OPERABILITY (see NRC Regulatory Issue Summary 2001-09, "Control of Hazard Barriers," dated April 2, 2001).

The provisions of LCO 3.0.8 are justified because of the low risk associated with required barriers not being capable of performing their related support function. This provision is based on consideration of the following initiating event categories:

Loss of coolant accidents; High energy line breaks; Feedwater line breaks; 0

Internal flooding; External flooding; Turbine missile ejection; and Tornado or high wind.

I The risk impact of the barriers which cannot perform their related support function(s) must be addressed pursuant to the risk assessment and management provisions of the Maintenance Rule, 10 CFR 50.65 (a)(4),

and the associated implementation guidance, Regulatory Guide 1.160, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This guidance provides for the consideration of dynamic plant configuration issues, emergent conditions, and other aspects pertinent to plant operation with the barriers unable to perform their related support function(s). These considerations may result in risk management and other compensatory Cook Nuclear Plant Unit 1 B 3.0-11 Revision No. 0

LCO Applicability B 3.0 actions being required during the period that barriers are unable to perform their related support function(s).

LCO 3.0.8 may be applied to one or more trains or subsystems of a system supported by barriers that cannot provide their related support function(s), provided that risk is assessed and managed (including consideration of the effects on Large Early Release and from external events). If applied concurrently to more than one train or subsystem of a multiple train or subsystem supported system, the barriers supporting each of these trains or subsystems must provide their related support function(s) for different categories of initiating events. For example, LCO 3.0.8 may be applied for up to 30 days for more than one train of a multiple train supported system if the affected barrier for one train protects against internal flooding and the affected barrier for the other train protects against tornado missiles. In this example, the affected barrier may be the same physical barrier but serve different protection functions for each train.

If during the time that LCO 3.0.8 is being used, the required OPERABLE train or subsystem becomes inoperable, it must be restored to OPERABLE status with 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Otherwise, the train(s) or subsystem(s) supported by barriers that cannot perform their related support function(s) must be declared inoperable and the associated LCOs declared not met.

This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period provides time to respond to emergent conditions that would otherwise likely lead to entry into LCO 3.0.3 and a rapid plant shutdown, which is not justified given the low probability of an initiating event which would require the barrier(s) not capable of performing their related support function(s). During this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the plant risk associated with the existing conditions is assessed and managed in accordance with 10 CFR 50.65(a)(4).

Cook Nuclear Plant Unit 1 B 3.0-12 Revision No. 0 to AEP-NRC-2015-03 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked to Show Proposed Changes (For Information Only)

LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.M7-establish the general requirements applicable to all Specifications in Sections 3.1 through 3.9 and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a.

Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b.

Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS.) The second type of Required Action specifies the remedial measures that permit continued operation of the unit that is not further restricted by the Completion Time. In this case, compliance with the Required Actions provides an acceptable level of safety for continued operation.

Completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.

The nature of some Required Actions of some Conditions necessitates that, once the Condition is entered, the Required Actions must be Cook Nuclear Plant Unit 2 B 3.0-1 Revision No. 0