Text

Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term
	ML16197A269
Person / Time
Site:	Cook
Issue date:	07/12/2016
From:	Lies Q; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2016-56
	Download: ML16197A269 (22)
	v • d • e

m INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, Ml 49106 A unit ofAmerican Electric Power lndianaMichiganPower.corn July 12, 2016 AEP-NRC-2016-56 10 CFR 50.90

Docket Nos. 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook NuclearPlant Unit 1 and Unit 2 Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term

References:

1. Letter from J. P. Gebbie, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRG), "Donald C. Cook Nuclear Plant, Units 1 and 2, License Amendment Request to Adopt TSTF-490, Revision 0, 'Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification' and Implement Full-Scope Alternative Source Term," dated November 14, 2014, Agencywide Documents Access and Management System (ADAMS) Accession No. ML14324A209.

2. Letter from J. P. Gebbie, l&M, to NRG, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2 -

Supplemental Information for the License Amendment Request to Adopt TSTF-490, Revision 0, 'Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification' and Implement Full-Scope Alternative Source Term," dated February 12, 2015, ADAMS Accession No. ML15050A247.

3. E-mail capture from A. W. Dietrich, NRG, to H. L. Kish, l&M, "D.C. Cook Units 1 and 2 -ARCS RAI Concerning LAR to Adopt TSTF-490 and Implement Full-Scope AST (CAC Nos. MF5184 and MF5185)," dated June 14, 2016.

This letter provides Indiana Michigan Power Company's (l&M), licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, response to the seventh Request for Additional Information {RAI) by the U. S. Nuclear Regulatory Commission (NRG) regarding a license amendment request (LAR) to adopt Technical Specification Task Force (TSTF)-490 and implement alternative source term (AST).

By .Reference 1, as supplemented by Reference 2, l&M submitted a request to amend the Technical Specifications (TS) to CNP Units 1 and 2 Renewed Facility Operating Licenses DPR-58 and

.DPR-74. l&M proposes to adopt TSTF-490, Revision 0, and implement full scope AST radiological analysis methodology. By Reference 3, the NRG transmitted an RAI from the Radiation Protection

U. S. Nuclear Regulatory Commission AEP-NRC-2016-56 Page2 and Consequence Branch (ARCB) regarding the LAR submitted by l&M in Reference 1. Telephone conferences were held between NRC staff and l&M on June 6, 2016, and June 13, 2016 to clarify the information requested. to this letter provides an affirmation statement. Enclosure 2 to this letter provides l&M's response to the RAI contained in Reference 3, which resulted in changes to the marked up TS pages and TS Bases pages provided *in Reference 1. The revised marked up TS and TS Bases pages are provided in the following additional enclosures to this letter:

Enclosure 3, CNP Unit 1 TS Pages Marked to Show Proposed Changes

Enclosure 4, CNP Unit 1 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

Enclosure 5, CNP Unit 2 TS Pages Marked to Show Pr9posed Changes.

Enclosure 6, CNP Unit 2 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

The revised marked up pages replace only the affected pages. All other marked up TS and TS Bases pages provided in Reference 1 remain- valid. The No Significant Hazards Consideration determination provided in Reference 1 is not altered by this apditional information.

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

There are no new regulatory commitments made in this letter. Should you have any questions,

please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

. f~i E, Sincerely, Q. Shane Lies Site Vice President .

TLC/mll

Enclosures:

1. Affirmation

2. Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term

3. .CNP Unit 1 TS Pages Marked to Show Proposed Changes

4. CNP Unit 1 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

5. CNP Unit 2 TS Pages Marked to Show Proposed Changes

6. CNP Unit 2 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

U. S. Nuclear Regulatory Commission AEP-NRC-2016-56 .

Page 3 c: R J. Ancona, MPSC A. W. Dietrich, NRC, Washington, D.C.

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

Enclosure 1 to AEP-NRC-2016-56 AFFIRMATION I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U, S. Nuclear Regulatory Commission on behalf of l&M, and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company 1~J.C

~ane Lies Site Vice President SWORN TO .AND SUBSCRIBED BEFORE ME

\ d-t\-. DAY OF , 2016 My Commission Expires 0\ };;n \~\'8

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Enclosure 2 to AEP-NRC-2016-56 Response to Seventh Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term By letter dated November 14, 2014 (Reference 1), as supplemented by letter dated February 12, 2015 (Reference 2), Indiana Michigan Power Company (l&M), the licensee for the Donald C. Cook Nuclear Plant (CNP), Units 1 and 2, submitted a license amendment request.

The proposed amendment consists of adoption of Technical Specifications Task Force (TSTF)-490, Revision 0, "Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification," and implementation of a full scope alternative source term (AST) radiological analysis methodology.

The U. S. Nuclear Regulatory Commission (NRC) staff in the Radiation Protection and Consequence Branch (ARCB) of the Office of Nuclear Reactor Regulation is currently reviewing the submittal, as supplemented, and has determined that additional information is needed in order* to complete the review (Reference 3). The text of the request for additional information (RAI) and l&M's response are provided below.

RAl-ARCB-10 The proposed change to the Donald C. Cook Nuclear Plant (CNP}, Units 1 and 2, technical specification (TS) 3.4. 16, in part, modifies Condition 8 to provide a Condition and Required Action for dose equivalent Xe-133 instead of gross specific activity. In the current TS 3.4.16, Condition A specifies that when dose equivalent 1-131 is greater than 1.0 microcuries per gram (µCi/gm), the required action is to restore dose equivalent 1-131 to within limit, with a Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . During this Condition, Limiting Condition for Operation (LCO) 3.0.4.c is applicable. If the dose equivalent 1-131 is not restored within limit in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , the required action is to be in Mode 3 with average reactor coolant temperature (Tavg) less than 500 °F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

For the modified Condition 8, the licensee proposes a Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore dose equivalent Xe-133 within limits. A Note is also added allowing the applicability

. of LCO 3.0.4.c.

Technical Specification Task Force (TSTF)-490, Revision 0, provided the following justification for this change:

The Completion Time for revised TS 3.4.16 Required Action 8.1 will require restoration of Dose Equivalent Xe-133 to within limit in 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This is consistent with the Completion Time for current Required Action A.2 for Dose Equivalent 1-131.

The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for revised Required Action 8. 1 is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of an accident occurring during this time period

While it is a correct statement that the proposed change makes the Completion Times of TS 3.4.16 Required Action A.2 and 8.1 in NUREG-1431, "Standard Technical Specifications to AEP-NRC-2016-56 Page2 Westinghouse Plants," consistent, it is not clear why the Completion Times should be consistent. The plant Conditions for these Required Actions are different.

The CNP TS 3.4.16 Required Action A.2 is required when the plant is in a condition analyzed in the design basis accident analyses (reactor coolant dose equivalent 1-131 is bound between 1 and 60 µCi/gm). The new proposed TS 3.4. 16 Required Action B. 1 is required when the plant is in a condition not analyzed in the design basis accident analyses (dose equivalent Xe-133 is greaterthan 215.1 µCi/gm).

Typically, the Required Action for a condition not analyzed requires the plant to take immediate actions to begin shutdown of the plant. The proposed change does not require immediate actions to begin shutdown of the plant, but allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months before the plant is required to begin shutting down.

Provide justification for the proposed Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for TS 3.4. 16 Condition B, to include why it is acceptable to be in an unanalyzed condition for 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months when the reactor coolant dose equivalent Xe-133 is greater than 215. 1 µCi/gm without an upper bound.

l&M Response to RAl-ARCB-10:

In response to this RAI, l&M conducted additional reviews of the information related to the establishment of the Completion Time (CT) for TS 3.4.16, "RCS Specific Activity," Condition B.

As described in the proposed TS Bases B 3.4.16 Applicable Safety Analyses section, the analyses for the steam line break and steam generator tube rupture accidents establish the acceptance limits for reactor coolant system (RCS) specific activity. For those accidents, the analysis assumptions include an initial condition of a source term equivalent to 1% failed fuel but with no further fuel damage occurring as a result of the accident, as discussed in Enclosure 5 of Reference 4, which replaced Enclosure 9 of Reference 1. The assumption of an initial condition of a source term equivalent to 1% failed fuel for these accidents is the basis for the established CNP TS 3.4.16 limit on Dose Equivalent Xenon-133 (DEX) activity.

Any spike in the RCS DEX activity levels that exceeded the limit specified in TS 3.4.16 would be expected to be caused by failed fuel elements and DEX activity increases caused by failed fuel cannot be returned to acceptable levels within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Since there is not a current analysis that provides a value for DEX that is greater than 215.1 µCi/gm but below which the radiological consequences of the increased activity would not exceed the 10 CFR 50.67 dose guidelines, l&M concluded that the allowed CT for Condition B of TS 3.4.16 should be changed. Based on that conclusion, l&M has revised the proposed TS amendment request so that the CT is consistent with the CT for other unanalyzed conditions, which require the unit to be in Mode 3 within six hours. Therefore, the previous request to allow 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore CNP TS 3.4.16 DEX activity within limits is revised to require the unit to be in Mode 3 within six hours and Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months if the DEX activity limit is exceeded.

The l&M response to this RAI is the same as the response previously provided by Tennessee Valley Authority (TVA) for Sequoyah Nuclear Plant (Reference 5) to a similar RAI they received during NRC review of their LAR for conversion to Improved Technical Specifications and adoption of TSTF-490. The proposed response by TVA to require being in Mode 3 within six to AEP-NRC-2016-56 Page 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for DEX not within limit was approved by the NRC on September 30, 2015 (Reference 6).

The CNP TS markups have been revised to reflect the proposed changes to TS 3.4.16 Condition B, which will now state, "Required Action and associated Completion Time of Condition A not met, OR DOSE EQUIVALENT 1-131 > 60 µCi/gm, OR DOSE EQUIVALENT XE-133 not within limit." Condition A remains the same as previously proposed in Reference 1.

The previously proposed TS 3.4.16 Condition C has been deleted. In addition, the proposed CT for the new Condition B has been revised to reflect the change from 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore DEX within limit to the requirement to be in Mode 3 within six hours and Mode 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The TS Bases have been revised to reflect the proposed changes to TS 3.4.16. In TS Bases B 3.4.16, the Actions seetion is revised to remove reference to a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months CT and remove the discussion of the ability to restore DEX activity within limits.. In addition, the originally proposed TS B 3.4.16 Actions section for Conditions C.1 and C.2 has been deleted and .the information from that section moved under the discussion for Conditions B.1 and B.2.

Also in TS Bases B 3.4.16, the Surveillance Requirement (SR) section has been revised to remove the discussion of a Note that modifies SRs 3.4.16.1 and 3.4.16.2 to allow entry into MODES 2, 3, and.4 prior to performing the SR. That information should not have been included in the TS Bases mark-ups of the original LAR because those Notes were not included in TS 3.4.16 mark-ups for the original LAR.

REFERENCES

1. Letter from J. P. Gebbie, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant, Units 1 and 2, License Amendment Request to Adopt TSTF-490, Revision 0, 'Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification' and Implement Full-Scope Alternative Source Term," dated November 14, 2014, Agencywide Documents Access and Management System (ADAMS) Accession No. ML14324A209.

2. Letter from J. P. Gebbie, l&M, to NRC, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2 -

Supplemental Information for the License Amendment Request to Adopt TSTF-490, Revision O,* 'Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification' and Implement Full-Scope Alternative Source Term, dated February 12, 2015, ADAMS Accession No. ML15050A247. /

3. E-mail capture from AW. Dietrich, NRC, to H. L. Kish, l&M, "D.C. Cook Units 1 and 2 -ARCB RAI Concerning LAR to Adopt TSTF-490 and Implement Full-Scope AST (CAC Nos. MF5184 and MF5185)," dated June 14, 2016.

4. Letter from Q. S. Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2 -

Response to Sixth Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-490 and Implement Alternative Source Term, dated May 6, 2016.

to AEP-NRC-2016-56 Page4

5. Letter from J. W. Shea, Tennessee Valley Authority (TVA), to NRC, "Sequoyah Nuclear Plant Units 1and2-Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS 10) - Supplement 2," dated June f9, 2015, ADAMS Accession No. ML15176A649.

6. Letter from NRC to J. W. Shea, TVA, "Sequoyah Nuclear Plant Units 1 and 2 - Issuance of Amendments for the Conversion to the Improved Technical Specifications with Beyond Scope Issues (TAC Nos. MF3128 and 3129)," dated September 30, 2015, ADAMS Accession No. ML152388460.

Enclosure 3 to AEP-NRC-2016-56 CNP Unit 1 TS Pages Marked to Show Proposed Changes

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within limits.

RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

I APPLICABILITY: MODES 1 and 2, 1. 2. 3. and 4.

MODE 3 with RCS average temperature (Tavg) > 500°F.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

A. DOSE EQUIVALENT LCO 3.0.4.c is applicable.

I 131 > 1.0 µCi/gm. not ------------------------------------------------

within limit.

A.1 Verify DOSE EQUIVALENT Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1-131 witl=lin tl=le aceeptable region of Figure 3.4.16 1.

~ 60 µCi/gm.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limit.

B. Required Action and B.1 Be in MODE 3-witR 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Tavg < 500°F.

Time of Condition A not met. AND OR 8.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months DOSE EQUIVALENT 1-131 +n--tAe unacceptable region of Figure 3.4.16 1.> 60

µCi/gm.

OR DOSE EQUIVALENT XE-133 Gress specifie activity of tl=le reactor sealant not within limit.

I Cook Nuclear Plant Unit 1 3.4.16-1 Amendment No. ~

RCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant ~DOSE EQUIVALENT 7 days XE-133 specific activity s 100/E 215.1 µCi/gm.

SR 3.4.16.2 NOTE Only required to be performed in MOD~

Verify reactor coolant DOSE EQUIVALENT 1-131 14 days specific activity s 1.0 µCi/gm.

Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of~ 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period SR 3.4.16.3 NOTE Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for> 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine E from a sample taken in MODE 1 after a 184 days minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for> 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

I Cook Nuclear Plant Unit 1 3.4.16-2 Amendment No. 28-7

Enclosure 4 to AEP-NRC-2016-56 CNP Unit 1 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued)

A Note permits the use of the provisions of LCO 3.0.4 .c. This allovvance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allo\\'ance is acceptable due to the significant conservatism incorporated into the specific activity limit, the 1011.' probability of an event 1

..vhich is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the unit remains at, or proceeds to power operation.

With the DOSE EQUIVALENT 1-131 greater than the LCO limit, samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to demonstrate that the specific activity is ::;; 60.0 µCi/gm. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample. Sampling is continued every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to provide a trend.

The DOSE EQUIVALENT 1-131 must be restored to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is acceptable since it is expected that, if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. Also. there is a low probability of a SLB or SGTR occurring during this time period.

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S), relying on Required Actions_

A.1 and A.2 while the DOSE EQUIVALENT 1-131 LCO limit is not met.

This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event that is limiting due to exceeding this limit. and the ability to restore transient-specific activity excursions while the plant remains at, or proceeds to, power operation.

B.1 and B.2 If any Required Action and associated Completion Time of Condition p., is not met, if the DOSE EQUIVALENT I 131 is in the unacceptable region of Figure 3.4 .16 1, or if gross specific activity of the reactor coolant is not within limit, the reactor must be brought to MODE 3 1Nith RCS average temperature < 500°F 1.vithin 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 500°F from full power conditions in an orderly manner and without challenging unit systems.

If the Required Action and associated Completion Time of Condition A is not met, if the DOSE EQUIVALENT 1-131 is> 60.0 µCi/gm, or if DOSE EQUIVALENT XE-133 is not within limit, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an Cook Nuclear Plant Unit 1 B 3.4.16-6 Revision No. 0

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued) orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4 .16.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. While basically a quantitative measure of radionuclides Nith half 1

lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross specific activity.

Trending the results of this Surveillance allows proper remedial action to

be taken before reaching the LCO limit under normal operating conditions. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time.

SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant at least once every 7 days. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in the noble gas specific activity.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The 7-day Frequency considers the low probability of a gross*

fuel failure during this time.

Due to the inherent difficulty in detecting Kr-85 in a reactor coolant sample due to masking from radioisotopes with similar decay energies.

such as F-18 and 1-134, it is acceptable to include the minimum detectable activity for Kr-85 in the SR 3.4.16.1 calculation. If a specific noble gas nuclide listed in the definition of DOSE EQUIVALENT XE-133 is not detected, it should be assumed to be present at the minimum detectable activity.

SR 3.4.16.2 This Surveillance requires the verification that the reactor coolant DOSE EQUIVALENT I 131 specific activity is \Nithin limit. This Surveillance is accomplished by performing an isotopic analysis of a reactor coolant sample. This Surveillance is performed in MODE 1 only to ensure iodine remains within limit during normal operation and following fast power changes \Nhen fuel failure is more apt to occur. The 14 day Frequency is Cook Nuclear Plant Unit 1 B 3.4.16~7 Revision No. 0

RCS Specific Activity B 3.4.16 BASES SURVEILLANCE REQUIREMENTS (continued) adequate to trend changes in the iodine activity level, considering gross activity is monitored every 7 days. The Frequency, between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change > 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time follov,ling fuel failure; samples at other times vvould provide inaccurate results.

This Surveillance is performed to ensure iodine specific activity remains within the LCO limit during normal operation and following fast power changes when iodine spiking is more apt to occur. The 14-day Frequency is adequate to trend changes in the iodine activity level, considering noble gas activity is monitored every 7 days. The Frequency, between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change > 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time following iodine spike initiation; samples at other times would provide inaccurate results.

SR 3.4.16.3 A radiochemical anafysis for E determination is required every 184 days 1

.vith the unit operating in MODE 1 equilibrium conditions. The E determination directly relates to the LCO and is required to verify unit operation within the specified gross activity LCO limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than 15 minutes, excluding iodines. The Frequency of 184 days recognizes E does not change rapidly.

This SR has been modified by a Note that indicates sampling is not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor V.'as last subcritical for at least 4 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal e-veA-h REFERENCES 1. 10CFR100.11.

1. 10 CFR 50.67.

2. Standard Review Plan (SRP) Section 15.0.1 "Radiological Consequence Analyses Using Alternative Source Terms."

3.~. UFSAR, Section 14.2.4.

4. UFSAR, Section 14.2.5.

Cook Nuclear Plant Unit 1 B 3.4.16-8 Revision No. 0

Enclosure 5 to AEP-NRC-2016-56 CNP Unit 2 TS Pages Marked to Show Proposed Changes

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within limits.

RCS DOSE EQUIVALENT 1-131 and DOSE EQUIVALENT XE-133 specific activity shall be within limits.

I APPLICABILITY: MODES 1 and 2, 1. 2. 3, and 4.

MODE 3 11ith RCS average temperature (Tavg) > 500°F.

1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

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

A DOSE EQUIVALENT LCO 3.0.4.c is applicable.

I 131 > 1.0 µCi/gm. not ------------------------------------------------

within limit.

A.1 Verify DOSE EQUIVALENT Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1-131 within the acceptable region of Figure 3.4 .16 1.

60 µCi/gm.

~

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limit.

B. Required Action and B.1 Be in MODE 3-witJ:l 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Tavg < 500°F.

Time of Condition A not met. AND OR B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months DOSE EQUIVALENT 1-1 31 ffi--tfle unacceptable region of Figure 3.4.16 1.> 60

µCi/gm.

OR DOSE EQUIVALENT XE-133 Gross specific activity of the reactor coolant not within limit.

Cook Nuclear Plant Unit 2 3.4.16-1 Amendment No. ~

RCS Specific Activity 3.4.16 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.16.1 Verify reactor coolant ~DOSE EQUIVALENT 7 days XE-133 specific activity ::; 100/E 215.1 µCi/gm.

SR 3.4.16.2 NOTE Only required to be performed in MODE 1.

Verify reactor coolant DOSE EQUIVALENT 1-131 14 days specific activity ::; 1.0 µCi/gm.

AND Between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a THERMAL POWER change of 2:: 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period SR 3.4.16.3 NOTE Not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for> 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Determine E from a sample taken in MODE 1 after a 184 days minimum of 2 effective full pmver days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for> 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

Cook Nuclear Plant Unit 2 3.4.16-2 Amendment No. ~

Enclosure 6 to AEP-NRC-2016-56 CNP Unit 2 TS Bases Pages Marked to Show Proposed Changes (For Information Only)

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued)

A-Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S) while relying on the ACTIONS.

This allowance is acceptable due to the significant conservatism

incorporated into the specific activity limit, the lo*.v probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions \Vhile the unit remains at, or proceeds to power operation.

With the DOSE EQUIVALENT 1-131 greater than the LCO limit, samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to demonstrate that the specific activity is :s; 60.0 µCi/gm. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample. Sampling is continued every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to provide a trend.

The DOSE EQUIVALENT 1-131 must be restored to within limit within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is acceptable since it is expected that, if there were an iodine spike, the normal coolant iodine concentration would be restored within this time period. Also, there is a low probability of a SLB or SGTR occurring during this time period.

A Note permits the use of the provisions of LCO 3.0.4.c. This allowance permits entry into the applicable MODE(S), relying on Required Actions A.1 and A.2 while the DOSE EQUIVALENT 1-131 LCO limit is not met.

This allowance is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event that is limiting due to exceeding this limit, and the ability to restore transient-specific activity excursions while the plant remains at, or proceeds to, power operation.

B.1 and B.2 If any Required Action and associated Completion Time of Condition A is not met, if the DOSE EQUIVALENT I 131 is in the unacceptable region of Figure 3.4 .16 1, or if gross specific activity of the reactor coolant is not*

.vithin limit, the reactor must be brought to MODE 3 vvith RCS average temperature < 500°F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 500°F from full power conditions in an orderly manner and *.vithout challenging unit systems.

If the Required Action and associated Completion Time of Condition A is not met, if the DOSE EQUIVALENT 1-131is>60.0 µCi/gm, or if DOSE EQUIVALENT XE-133 is not within limit. the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to Cook Nuclear Plant Unit 2 B 3.4.16-6 Revision No. 0

RCS Specific Activity B 3.4.16 BASES ACTIONS (continued) reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the gross specific activity of the reactor coolant at least once every 7 days. VVhile basically a quantitative measure of radionuclides *.vith half lives longer than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in gross specific activity.

Trending the results of this Surveillance allmvs proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time.

SR 3.4.16.1 requires performing a gamma isotopic analysis as a measure of the noble gas specific activity of the reactor coolant at least once every 7 days. This measurement is the sum of the degassed gamma activities and the gaseous gamma activities in the sample taken. This Surveillance provides an indication of any increase in the noble gas specific activity.

Trending the results of this Surveillance allows proper remedial action to be taken before reaching the LCO limit under normal operating conditions. The 7-day Frequency considers the low probability of a gross fuel failure during this time.

Due to the inherent difficulty in detecting Kr-85 in a reactor coolant sample due to masking from radioisotopes with similar decay energies, such as F-18 and 1-134, it is acceptable to include the minimum detectable activity for Kr-85 in the SR 3.4.16.1 calculation. If a specific noble gas nuclide listed in the definition of DOSE EQUIVALENT XE-133 is not detected, it should be assumed to be present at the minimum detectable activity.

SR 3.4.16.2 This Surveillance requires the verification that the reactor coolant DOSE EQUIVALENT I 131 specific activity is within limit. This Surveillance is accomplished by performing an isotopic analysis of a reactor coolant sample. This Surveillance is performed in MODE 1 only to ensure iodine Cook Nuclear Plant Unit 2 B 3.4.16-7 Revision No. 0

RCS Specific Activity .

B 3.4.16 BASES SURVEILLANCE REQUIREMENTS (continued) remains within limit during normal operation and following fast pmver.

changes Nhen fuel failure is more apt to occur. The 14 day Frequency-IB 1

adequate to trend changes in the iodine activity level, considering gross activity is monitored every 7 days. The Frequency, beti.veen 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a povver change > 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time following fuel failure; samples at other times Nould provide inaccurate results.

1 This Surveillance is performed to ensure iodine specific activity remains within the LCO limit during normal operation and following fast power changes when iodine spiking is more apt to occur. The 14-day Frequency is adequate to trend changes in the iodine activity level, considering noble gas activity is monitored every 7 days. The Frequency, between 2 and 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after a power change > 15% RTP within a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months period, is established because the iodine levels peak during this time following iodine spike initiation; samples at other times would provide inaccurate results.

SR 3.4.16.3 A radiochemical analysis for E determination is required every 184 days with the unit operating in MODE 1 equilibrium conditions. The E determination directly relates to the LCO and is required to verify unit operation \Vithin the specified gross activity LCO limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than 15 minutes, excluding iodines. The Frequency of 184 days recognizes E does not change rapidly.

This SR has been modified by a Note that indicates sampling is not required to be performed until 31 days after a minimum of 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This ensures that the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal eveflt.

REFERENCES 1. 10CFR100.11.

1. 10 CFR 50.67.

2. . Standard Review Plan (SRP) Section 15.0.1 "Radiological Consequence Analyses Using Alternative Source Terms."

3.2. UFSAR, Section 14.2.4.

4. UFSAR, Section 14.2.5.

Cook Nuclear Plant Unit 2 B 3.4.16-8 Revision No. 0

v t e Letter Sequence Request
CAC:MF5184, (Approved, Closed)
Initiation Request, Request Acceptance... Supplement Administration Questions 14 June 2016 Answers Results Approval, Approval Other: ML16007A180, ML16203A268
MONTHYEAR2016-03-31 [Table View]

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