Text

Follow-up Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to License Control-Risk Informed Technical Specification Task Force
	ML16258A145
Person / Time
Site:	Cook
Issue date:	09/09/2016
From:	Lies Q; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2016-69
	Download: ML16258A145 (47)
	v • d • e

m IN DIANA MICHIGAN POWER A unit of American Electric Power September 9, 2016 Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 lndianaMichiganPower.com AEP-NRC-2016-69 10 CFR 50.90 Follow-Up Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control-Risk Informed Technical Specification Task Force (RITSTF) Initiative 58

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-425-A, Revision 3_, 'Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 58'," dated November 19, 2015, Agencywide Documents Access and Management System (ADAMS) Accession No. ML15328A469.

2. Letter from Q. Shane Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Supplement to License Amendment Request to Adopt TSTF-425-A, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF)

Initiative 58',"

dated February

4,

2016, ADAMS Accession No. ML16039A240.

3. Letter from A. W. Dietrich, NRC, to J. P. Gebbie, l&M, "Donald C'. Cook Nuclear Plant, Units 1 and 2 -

Request for Additional Information Regarding License Amendment Request to Relocate Surveillance Frequencies to Licensee Control (CAC Nos. MF7114 and MF7115},"

dated May 11, 2016, ADAMS Accession No. ML16127A079.

4. Letter from Q. S. Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control-Risk Informed Technical Specification Task Force (RITSTF) Initiative 58," dated June 16, 2016, ADAMS Accession No. ML16173A256.

U.S. Nuclear Regulatory Commission Page2 AEP-NRC-2016-69

5. Letter from A. W. Dietrich, NRC, to J. P. Gebbie, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Follow-Up Request for Additional Information Regarding License Amendment Request to Relocate Surveillance Frequencies to Licensee Control (CAC Nos. MF7114 and MF7115)", dated August 1, 2016, ADAMS Accession No. ML16211A015.

6. Letter from A. W. Dietrich, NRC to J. P. Gebbie, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendments to Revise Technical Specifications to Adopt Technical Specifications Task Force - 523, 'Generic Letter 2008-01, Managing Gas Accumulation' (CAC Nos. MF7294 and MF7295)", dated August 4, 2016, ADAMS Accession No. ML16195A004.

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 Request for Additional Information (RAI) by the U. S. Nuclear Regulatory Commission (NRC) regarding a license amendment request (LAR) to adopt Technical Specification Task Force (TSTF)-425-A, Revision 3, "Relocate Surveillance Frequencies to Licensee Control-Risk Informed Technical Specification Task Force (RITSTF) Initiative 5B."

In addition, this letter provides a supplement to Reference 1. By Reference 6, the NRC approved TSTF-523, which added new surveillance frequencies to CNP Technical Specifications (TS). These surveillance frequencies are consistent with NRC approved lndustryfTSTF Standard TS changes in TSTF-425, Revision 3, and should therefore be considered as part of the TSTF-425 application.

By Reference 1, as supplemented by Reference 2, l&M submitted a request to amend the TS to CNP Units 1 and 2 Renewed Facility Operating Licenses DPR-58 and DPR-74 to adopt TSTF-425, Revision 3. By Reference 3, the NRC transmitted an RAI regarding the LAR submitted by l&M in Reference 1. By Reference 4, l&M Responded to the Reference 3 RAI. By Reference 5, the NRG transmitted a follow-up to the Reference 3 RAI. By Reference 6, the NRC approved TSTF-523 for use at CNP. Enclosure 1 to this letter provides an affirmation statement. Enclosure 2 to this letter provides l&M's response to the follow-up RAI contained in Reference 5.

Enclosures 3 and 4 provide marked-up license pages for Units 1 and 2, respectively. provides the supplement to the LAR to adopt TSTF-425-A, Revision 3. Enclosures 6 and 7 provide marked-up TS Pages for Units 1 and 2 respectively. Enclosures 8 and 9 provide marked-up TS Bases Pages for Units 1 and 2 respectively.

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.

Sin?~iG is;ne Lies Site Vice President

U. S. Nuclear Regulatory Commission Page 3 AEP-NRC-2016-69 DB/mll

Enclosures:

1.

2.

3.

4.

5.

6.

7.

8.

9.

c:

Affirmation Follow-Up Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control Donald C. Cook Nuclear Plant Unit 1 Mark-Up License Page Donald C. Cook Nuclear Plant Unit 2 Mark-Up License Page Supplement to License Amendment Request to Adopt TSTF-425-A, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5B" Donald C. Cook Nuclear Plant Unit 1 Mark-Up Technical Specification Pages Donald C. Cook Nuclear Plant Unit 2 Mark-Up Technical Specification Pages Donald C. Cook Nuclear Plant Unit 1 Mark-Up Technical Specification Bases Pages Donald C. Cook Nuclear Plant Unit 2 Mark-Up Technical Specification Bases Pages 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 to AEP-NRC-2016-69 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 2~i~

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to AEP-NRC-2016-69 Follow-Up Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control

By [[letter::AEP-NRC-2015-46, Enclosures 6 - 11: CNP Units 1 & 2 TS Bases, TSTF-425 Versus CNP TS Cross-Reference, Proposed No Significance Hazards Consideration, Proposed Inserts and Regulatory Commitments|letter dated November 19, 2015]], (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15328A450), as supplemented by *letter dated February 4, 2016 (ADAMS Accession No. ML16039A240}, Indiana Michigan Power Company (l&M}, the licensee for Donald C. Cook Nuclear Plant (CNP), Units 1 and 2, submitted a request to amend the Technical Specifications to CNP Units 1 and 2 Renewed Facility Operating Licenses DPR-58 and DPR-74 to adopt TSTF-425, Revision 3.

The U. S. Nuclear Regulatory Commission (NRC) staff is currently reviewing the submittal, as supplemented, and has determined that additional information is needed in order to complete the review. The requests for additional information (RAl)s and l&M's responsE'.ls are provided below.

RAl-PRA-1-01 In response to RAl-PRA-1, Indiana Michigan Power Company (l&M, the licensee) stated that the dispositions to the Facts and Observations (F&Os) on the pre-initiator Human Reliability Analysis (HRA) from the license amendment request (LAR) have been "replaced by a new analysis," similar to a methodology used by other licensees. Based on this. response, it would seem that the methodology for pre-initiator HRA is a new methodologYand constitutes a PRA upgrade as stated in the American Society of Mechanical Engineers/American Nuclear Society (ASMEIANS) PRA standard, in that "new should be interpreted as new to the subject PRA even thqugh the methodology in question has been applied in other PRAs" (Section 1-A.1 of ASMEIANS RA-Sa-

. 2009). Specifically cited as "Example 24" in Section 1-A.3.24 of ASMEIANS RA-Sa-2009 is that employing a different HRA approach to human error analysis constitutes a PRA upgrade.

a) If the "new analysis" fits the definition and criteria of ASMEIANS RA-Sa-2009 of a new methodology, and, therefore, a PRA upgrade, perform a focused scope peer review on the affected supporting requirements (i.e., at a mfnimum, those related to HRA in the applicable parts of ASMEIANS RA-Sa-2009), and provide the F&O's with a description of the impact to the TSTF-425 program.

b) If the 'new analysis" does not fit the definition and criteria of a new methodology, explain why it does not fit the definition of a PRA upgrade as defined in the ASMEIANS standard.

l&M Response to RAl-PRA-1-01:

In developing the response to this request, CNP Probabilistic Risk Assessment (PRA) staff performed a review of the previously used method for the development of pre-initiator Human Failure Events (HFEs) and the method used in the development of the current pre-initiator HFEs as described in the response to RAl-PRA-1 in Reference 5. This review was necessary to understand if a new methodology had been utilized and, if so, what specific Supporting Requirements of the Standard were impacted and thus provide the focus for the limited scope peer review if needed.

to AEP-NRC-2016-69 Page 2 Based on this review, it was identified that a new method, relative to the CNP PRA model, in the identification and screening of pre-initiator HFEs was used. Though this new method did result in a more comprehensive set of pre-initiator HFEs to incorporate into the PRA model, the application of the definition of a PRA upgrade per section 1-2 of Reference 6 and guidance from section 1-A.2 of Reference 6 resulted in the determination that a PRA Upgrade had occurred. Following guidance in section 1-5.4 of Reference 6 that a PRA Upgrade "... shall receive a peer review in accordance with the requirements specified in the Peer Review Section of each respective Part of this Standard, but limited to aspects of the PRA that have been upgraded", CNP has arranged for a focused-scope peer review of the Supporting Requirements (SRs) associated with the identification and screening of pre-initiator HFEs. The selected SRs (HR-A 1 through HR-C3) bound the SRs identified in the response to RAl-PRA-01 as described in Reference 5.

This focused-scope peer review will follow the guidance in section 1-6 of Reference 6 and in*

NEI 05-04, Revision 3, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard" (Reference 7).

The current schedule has completion of the focused-scope peer review, including publication of the focused-scope peer review report, in the 4th quarter 2016.

RAl-PRA-11-01 Regulatory Guide 1.200 directs that the risk perspective used in a risk-informed application is based

on a consideration of the total risk, which includes contributions from initiating events whose causes are attributable to both internal and external hazards. /&M's LAR and response to RAl-PRA-11 does not explain how the external hazards evaluated in the licensee's Individual Plant Examination of External Events are updated to reflect new information when used in performing a qualitative or bounding analysis. Hazard characteristics can change over time due to physical changes and changes in the available information.

Discuss the process for incorporating new information in these qualitative or bounding analyses and how this process adequately supports implementation of the surveillance frequency control program.

l&M Response to RAl-PRA-11-01:

As noted in the response to RAl-PRA-11 provided in Reference 5, l&M expects to address the impact of external hazards using a qualitative approach that follows the methodology of NEI 04-10 (Reference 3).

While it is recognized that the Individual Plant Examination of External Events (IPEEE) assessments have remained static since they were completed, they do form the basis for an initial understanding of insights from external hazards. These base insights would then be assessed to account for any updated information or attributes that may have changed since the IPEEE to better reflect the as-built, as-operated plant. Acceptability for the proposed surveillance requirement frequency change for that particular external hazard would then be determined and factored into the overall acceptability of the proposed change. This process will be contained in the Surveillance Frequency Control Program procedure and contained within each evaluation.

to AEP-NRC-2016-69 Page 3 RAl-PRA-12-01 In Enclosure 3, "Revised Regulatory Commitments, " to the RAJ response dated June 16, 2016, l&M discussed a number of F&Os whose dispositions will be incorporated into the PRA of record prior to program implementation. The completion of these actions is necessary in order for the NRG staff to conclude that the LAR is acceptable. Such commitments are normally elevated to license conditions.

Provide these commitments as license conditions, or provide justification for not including them.

l&M Response to RAl-PRA-12-01:

Table 1 below, identifies those implementation items that will be completed by l&M prior to the.

implementation of new surveillance frequency control program. These items will be completed within 120 days after issuance of approval for this LAR, and are included as a license condition (Enclosures 3 and 4 of this letter).

Table 1 Re-integrated the Fire Probabilistic Risk Assessment (PRA)

Prior to program implementation model with the Internal Events PRA model.

The Computer Aided Fa1..Jlt Tree Analysis platform will be Prior to program implementation implemented for the Internal Events PRA Model of Record.

Implement the resolution for Supporting Requirement LE-C7 Prior to program implementation from the Fire PRA focused Scope Peer Review Technical Adequacy Justification Table (AEP-NRC-2016-17, Enclosure 2).

The Human Reliability Analysis Notebook will be signed off and Prior to program implementation the PRA model will be approved as the model of record with final resolution for the following Supporting Requirements prior to the development of any surveillance extension ~ssessment:

HR-A2, HR-A3, HR-81, HR-82, HR-C2, HR-03, HR-G6, HR-11, HR-12, HR-E3, HR-G5,.SY-810, Hr-G4, DA-C15, IFSN-A16, IFSN-A17, IFEV-A8, IFQU-A3, Updated modeling of the reactor protection system I engineered Prior to program implementation safety features actuation system has been incorporated into the working version of the PRA model. Final resolution and Facts and Observation closure will be attained when the PRA model is approved as the new model of record prior to the development of any surveillance extension assessment for the following Supporting Requirements from RAl-PRA-4 Table:

LE-E1, PRM-814, PRM-815 have updated status in table RAI-

PRA-4 to AEP-NRC-2016-69 Page4 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-425-A, Revision 3, 'Relocate Surveillance.Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 58'," dated November 19, 2015, Agencywide Documents Access and Management System (ADAMS)

Accession No. ML15328A450.

2. Letter from Q. Shane Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Supplement to License Amendment Request to Adopt TSTF-425-A, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control - Risk Informed technical Specification Task Force (RITSTF) Initiative 58'," dated February 4, 2016, ADAMS Accession No. ML16039A240.

3. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb Risk-Informed Method for Control of Surveillance Frequencies".

4. Letter from A. W. Dietrich, NRC, to J. P. Gebbie, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding License Amendment Request to Relocate Surveillance Frequencies to Licensee Control (CAC Nos. MF7114 and MF7115)," dated May 11, 2016, ADAMS Accession No. ML16127A079.

5. Letter from Q. S. Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Response to Request for Additional Information Regarding the License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to Licensee Control-Risk Informed Technical Specification Task Force (RITSTF) Initiative* 58," dated June 16, 2016, ADAMS Accession No. ML16173A256.

6. ASME/ANS RA-Sa-2009, "Addenda to ASME/ANS RA-S-2008 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications",

February 2009 r

7. NEI 05-04, Revision 3, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard" Donald C. Cook Nuclear Plant Unit 1 Mark-Up License Page (19) Operation with Vacuum Fill:

The licensee is authorized to operate the facility using Reactor Coolant System (RCS) vacuum fill operation in accordance with TS 3.4.3, "RCS Pressure and Temperature (Pff) Limits," with corresponding revisions to Figure 3.4.3-1, "Reactor Coolant System Pressure versus Temperature Limits - Heatup Limit, Criticality Limit, and Leak Test Limit (Applicable for service period up to 32 EFPY)," and Figure 3.4.3-2, "Reactor Coolant System Pressure versus Temperature Limits - Various Cooldown Rates Limits (Applicable for service period up to 32 EFPY)," as approved in License Amendment No. 323 to Renewed Facility Operating License No. DPR-58. This includes an approved extension to -14. 7 pounds per square inch gage to bound the RCS conditions required to support vacuum fill operation. The licensee shall submit an analysis of the Prr curves in Figures 3.4.3-1 and 3.4.3-2 within one year of the date of issuance of License Amendment No. 323, which demonstrates consideration of all ferritic reactor vessel materials as defined in Appendix G to 1 O CFR Part 50, including non-beltline ferritic reactor vessel materials."

(20) The licensee shall implement the items listed in Enclosure 2, Table 1, of l&M letter AEP-NRC-2016-69, dated September 9, 2016, prior to program implementation.

D.

Physical Protection The Indiana Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revision to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Donald C. Cook Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1,"

submitted by letter dated May 10, 2006.

The Indiana and Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved Donald C. Cook Nuclear Plant Cyber Security Plan (CSP), including changes made pursuant to the authority of 1 O CFR 50.90 and 10 CFR 50.54(p). The Donald C. Cook Nuclear Plant CSP was approved by License Amendment No. 315 as supplemented by changes approved by License Amendment Nos. 319 and 325.

E.

Deleted by Amendment No. 80 F.

Deleted by Amendment No. 80 G.

In all places of this renewed operating license, the reference to the Indiana and Michigan Electric Company is amended to read Indiana Michigan Power Company.

H.

Deleted by Amendment No. 287 Renewed License No. DPR-58 Amendment No. ~. J4.9, ~. ~. 325 Donald C. Cook Nuclear Plant Unit 2 Mark-Up License Page (II I)

The first performance of the periodic measurement of CRE pressure, TS 5.5.16.d, shall be within 24 months, plus the 182 days allowed by SR 3.0.2, as measured from the date of the most recent successful pressure measurement test, or within 182 days if not performed previously.

(gg) Operation with V~cuum Fill:

The licensee is authorized to operate the facility using Reactor Coolant System (RCS) vacuum fill operation in accordance with TS 3.4.3, "RCS Pressure and Temperature (Pfr) Limits," with corresponding revisions to Figure 3.4.3-1, "Reactor Coolant System Pressure versus Temperature Limits

- Heatup Limit, Criticality Limit, and Leak Test Limit (Applicable for service period up to 32 EFPY)," and Figure 3.4.3-2, "Reactor Coolant System Pressure versus Temperature Limits - Various Cooldown Rates Limits (Applicable for service period up to 32 EFPY)," as approved in License Amendment No. 306 to Renewed Facility Operating License No. DPR-74.

This includes an approved extension to -14.7 pounds per square inch gage to bourid the RCS conditions required to support vacuum fill operation. The licensee shall submit an analysis of the Prr curves in Figures 3.4.3-1 and 3.4.3-2 within one year of the date of issuance of License Amendment No.

306, which demonstrates consideration of all ferritic reactor vessel materials as defined in Appendix G to 10 CFR Part 50, including non-beltline ferritic reactor vessel materials."

(hh)

The licensee shall implement the items listed in Enclosure 2, Table 1, of l&M letter AEP-NRC-2016-69, dated September 9, 2016, prior to program implementation.

D.

Physical Protection The Indiana Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans1, which contain Safeguards Information protected under 10 CFR.73.21, is entitled: "Donald C. Cook Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1,"

submitted by letter dated May 10, 2006.

The Indiana and Michigan Power Company shall fully implement and maintain in effect all provisions of the Commission-approved Donald C. Cook Nuclear Plant Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Donald C. Cook Nuclear Plant CSP was approved by License Amendment No. 299 as supplemented by changes approved by License Amendment Nos. 303 and 308.

E.

Deleted by Amendment No. 63 Renewed License No. DPR-74 Amendment No. 299, JW, JG§, JOO, 308 to AEP-NRC-2016-69 Supplement to License Amendment Request to Adopt TSTF-425-A, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 58 Description of Proposed Changes

1.0 DESCRIPTION

By Reference 4, Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP), proposed to amend Unit 1 and Unit 2 Technical Specifications (TS) by relocating specific surveillance frequencies to a licensee controlled program with the adoption of Technical Specification Task Force (TSTF)-425, Revision 3, "Relocate Surveillance Frequencies to Licensee.Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative 5b."

Additionally, the change would add a new program, the* Surveillance Frequency Control Program (SFCP), to TS Section. 5, Administrative Controls.

Subsequent to submitting this license amendment, by Reference 3, the U. S. Nuclear Regulatory Commission (NRC) approved TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation" for CNP Units 1 and 2 by Amendments 331 and 312, respectively.

This supplement to Reference 4 adds the new surveillance requirements approved by Reference 3.

The changes incorporated by TSTF-523 are consistent with NRG-approved lndustry/TSTF Standard TS change TSTF-425, Revision 3.

The Federal Register notice published on July 6, 2009, (74 FR 31996), announced the availability of TSTF-425, Revision 3, TS improvement.

2.0 ASSESSMENT

2.1 Applicability of Published Safety Evaluation (l&M) reviewed the safety evaluation (SE) dated July 6, 2009, (74 FR 31996) as part of the initial License Amendment Request (LAR). This review included a review of the NRC staff's evaluation, TSTF-425, Revision 3, and the requirements specified in Nuclear Energy Institute 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies,"* dated April 2007.

l&M's conclusion for this section remains the same, for this supplement, as the original LAR (Reference 4).

2.2 Optional Changes and Variations The proposed amendment is consistent with the standard TS changes described in TSTF-425, Revision 3; however, l&M proposes the following deviations for this supplement:

1. Subsequent to the original submittal of l&M's submittal for TSTF-425, the NRC approved TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation" for CNP Units 1 and

2. TSTF-523 contains new surveillance frequencies consistent with those contained in TSTF-425; however, the SRs were not contained in NUREG-1431, therefore, are not to AEP-NRC-2016-69

. Page 2 included in the NUREG-1431 surveillance provided in TSTF-425. l&M has determined that the relocation of the new frequencies is consistent with TSTF-425, Revision 3, and with the NRG staff's model SE dated July 6, 2009, (74 FR 31996). Changes to the frequencies for these plant-specific surveillances would be controlled under the SFCP.

3.0 BACKGROUND

There have been no changes to Section 3 or subsections of Section 3 since the initial LAR was submitted as a result of this supplement.

3.1 No Significant Hazards Consideration Previously in Reference 4, l&M has reviewed the proposed no significant hazards consideration (NSHC) determination published in the Federal Register on July 6, 2009, (74 FR 31996), and has concluded that the proposed NSHC presented in the Federal Register notice is applicable to CNP and is not affected by this supplement.

3.2 Applicable Regulatory Requirements A description of the proposed changes, and their relationship to applicable regulatory requirements, is provided in TSTF-425, Revision 3, and the NRC's model SE published in the Notice of Availability dated July 6, 2009, (74 FR 31996).

l&M has concluded that the relationship.of the proposed changes to the applicable regulatory requirements presented in the Federal Register notice is applicable to CNP.

3.3 Precedent This supplement to Reference 4 is similar to License Amendment No. 152 issued to Nine Mile Point Nuclear Station, Unit 2, on November 30, 2015, (Agencywide Documents Access and Management System (ADAMS) ML15317A307},

3.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public wiff 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.

4.0 ENVIRONMENTAL CONSIDERATION

l&M has reviewed the environmental consideration included in the NRG staff's model SE published in the Federal Register on July 6, 2009, (74 FR-31996). l&M has concluded that the staff's findings presented therein are applicable to CNP, and the determination is hereby incorpo,rated by reference for this supplement to the original application (Reference 4).

Enclosure S to AEP-NRC-2016-69 Page3 S.O REFERENCES

1. TSTF-42S, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb," March 18, 2009, ADAMS Accession No: ML0908S0642.

2. NRC Notice of Availability of Technical Specification Improvement to Relocate Surveillance Frequencies to Licensee Control - Risk-Informed Technical Specification Task Force (RITSTF} Initiative Sb, Technical Specification Task Force - 42S, Revision 3, published on July 6, 2009 (74 FR 31996).

3. Letter from A. W. Dietrich, NRC to J. P. Gebbie, l&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Issuance of Amendm.ents to Revise Technical Specifications to Adopt Technical Specifications Task Force - S23, 'Generic Letter 2008-01, Managing Gas Accumulation' (CAC Nos. MF7294 and MF729S)", dated August 4, 2016, ADAMS Accession No. ML 1619SA004.

4. 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-42S-A, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specification Task Force (RITSTF) Initiative SB'," dated November 19, 201S, Agencywide Documents Access and Management System (ADAMS) Accession No. ML 1 S328A469.

Donald C. Cook Nuclear Plant Unit 1 Mark-Up Technical Specification Pages 3.4.6-2 3.4.7-3 3.4.8-2 3.5.2-3 3.6.6-2 3.9.4-2 3.9.5-3

ACTIONS (continued)

CONDITION REQUIRED ACTION RCS Loops - MODE 4 3.4.6 COMPLETION TIME B. Two required loops inoperable.

B.1 Suspend operations that Immediately OR Required loop not in operation.

AND would cause introduction of coolant into the RCS with boron concentration less than required to meet the requirements of LCO 3.1.1.

B.2 Initiate action to restore one Immediately loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.2 Verify SG secondary side water levels are above the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lower tap of the SG wide range level instrumentation by ~ 420 inches for required RCS loops.

SR 3.4.6.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required pump.

SR 3.4.6.4

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 3-1,.J./~-fnl entering Mode 4.

accordance with!

the Surveillance!

Verify required RHR loop locations susceptible to Frequencvl gas accumulation are sufficiently filled with water.

Control Program!

Cook Nuclear Plant Unit 1 3.4.6-2 Amendment No. 2:&7, 331

RCS Loops - MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.7.2 Verify SG secondary side water level is above the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lower tap of the SG wide range level instrumentation by <:: 420 inches in required SGs.

SR 3.4.7.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required RHR pump.

SR 3.4.7.4 Verify required RHR loop locations susceptible to d~ says fn1 gas accumulation are sufficiently filled with water.

accordance with!

the surveillance!

FrequencYI Control Program/

Cook Nuclear Plant Unit 1 3.4.7-3 Amendment No. 2&7-, 331

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No required RHR loop B.1 Suspend operations that Immediately OPERABLE.

would cause introduction of coolant into the RCS with OR boron concentration less than required to meet Required RHR loop not requirements of LCO 3.1.1.

in operation.

AND B.2 Initiate action to restore one Immediately RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY -

SR 3.4.8.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2

N 0 TE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required RHR pump.

SR 3.4.8.3 Verify RHR loop locations susceptible to gas

')'1 "'~ *~~

~

-1 accumulation are sufficiently filled with water.

accordance withl the Surveillance!

Frequencvl Control Program!

Cook Nuclear Plant Unit 1 3.4.8-2 Amendment No. 2&7, 331

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.

Valve Number 1-Sl-121 N 1-Sl-121 S 1-Sl-141 L 1 1-Sl-141 L2 1-Sl-141 L3 1-Sl-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal

corrosion.

SR 3.5.2.8 Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.

ECCS - Operating 3.5.2 FREQUENCY 24 months 24 months a~ aays fnl accordance with!

~he Surveillance!

Frequencvl Control Program!

Cook Nuclear Plant Unit 1 3.5.2-3 Amendment No. 2-87, 2-99, 331

Containment Spray System 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.3

~-------------------------N 0 TE------------------------------

In MODE 4, only the manual portion of the actuation signal is required.

Verify. each automatic containment spray valve in 24 months the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.4

N 0 TE------------------------------

In MODE 4, only the manual portion of the actuation signal is required.

Verify each containment spray pump starts 24 months automatically on an actual or simulated actuation signal.

SR 3.6.6.5 Verify each spray nozzle is unobstructed.

Following maintenance that could result in nozzle blockage SR 3.6.6.6*

Verify containment spray locations susceptible to a~ Elays fnl gas accumulation are sufficiently filled with water.

accordance withl.

the Surveillance!

Frequenc~

Control Prooraml Cook Nuclear Plant Unit 1 3.6.6-2 Amendment No. ~. J44, 331

RHR and Coolant Circulation - High Water Level 3.9.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 AND A.5 Close equipment hatch and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months secure with four bolts.

Close one door in each air lock.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.6 Verify each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by an OPERABLE Containment Purge Supply and Exhaust System.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.4.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of~ 2000 gpm.

SR 3.9.4.2 Verify required RHR loop locations susceptible to a~ Elays [ill]

gas accumulation are sufficiently filled with water.

accordance with!

~he Surveillance!

Frequencvl Control ProQraml Cook Nuclear Plant Unit 1 3.9.4-2 Amendment No. ~. 331

RHR and Coolant Circulation - Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of:=:: 2000 gpm.

SR 3.9.5.2

N 0 TE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation.

Verify correct breaker alignment and indicated 7 days power available to the required RHR pump that is not in operation.

SR 3.9.5.3 Verify RHR loop locations susceptible to gas d~ says [fi1]

. accumul~tion are sufficiently filled with water.

accordc;ince with!

~he Surveillance!

Frequenc~

Control Program!

Cook Nuclear Plant Unit 1 3.9.5-3 Amendment No. ~. 331 Donald C. Cook Nuclear Plant Unit 2 Mark-Up Technical Specification Pages 3.4.6-2 3.4.7-3 3.4.8-2 3.5.2-3 3.6.6-2 3.9.4-2 3.9.5-3

ACTIONS (continued)

CONDITION

REQUIRED ACTION RCS Loops - MODE 4 3.4.6 COMPLETION TIME B. Two required loops inoperable.

B.1 Suspend operations that Immediately OR Required loop not in operation.

AND would cause introduction of coolant into the RCS with boron concentration less than required to meet the requirements of LCO 3.1.1.

B.2 Initiate action to restore one Immediately loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify required RHR or RCS loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.6.2 Verify SG secondary side water levels are above the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lower tap of the SG wide range level instrumentation by <:: 418. 77 inches for required RCS loops.

SR 3.4.6.3

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

Not required to. be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required pump.

SR 3.4.6.4

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering Mode 4.

d~ Elays ITni accordance with!

~he Surveillance!

Verify required RHR loop locations susceptible to Frequencvl gas accumulation are sufficiently filled with water.

Control Proqraml Cook Nuclear Plant Unit 2 3.4.6-2 Amendment No. 299, 312

RCS Loops - MODE 5, Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.7.2 Verify SG secondary side water level is above the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months lower tap of the SG wide range level instrumentation by ~ 418. 77 inches in required SGs.

SR 3.4.7.3

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required RHR pump.

SR 3.4.7.4 Verify required RHR loop locations susceptible to a~ Elays [ill]

gas accumulation are sufficiently filled with water.

accordance withl

~he Surveillance!

Frequenc~

Control Program/

Cook Nuclear Plant Unit 2 3.4.7-3 Amendment No. 299, 312

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No required RHR loop B.1 Suspend operations that Immediately OPERABLE.

would cause introduction of coolant into the RCS with OR boron concentration less than required to meet Required RHR loop not requirements of LCO 3.1.1.

in operation.

AND B.2 Initiate action to restore one Immediately RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify required RHR loop is in operation.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required pump is not in operation.

Verify correct breaker alignment and indicated 7 days power are available to each required RHR pump.

SR 3.4.8.3 Verify RHR loop locations susceptible to gas 3~ Elays fnl accumulations are sufficiently filled with water.

accordance with[

~he Surveillance[

Frequencvl Control Program!

Cook Nuclear Plant Unit 2 3.4.8-2 Amendment No. 269, 312

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.

Valve Number 2-Sl-121 N 2-Sl-121 s 2-Sl-141 L 1 2-Sl-141 L2 2-Sl-141 L3 2-Sl-141 L4 SR 3.5.2.7 Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and the suction inlet strainers show no evidence of structural distress or abnormal corrosion.

SR 3.5.2.8 Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.

ECCS - Operating 3.5.2 FREQUENCY 24 months 24 months a~ says fnl accordance with[

the Surveillance!

Frequencvl Control' Program[

Cook Nuclear Plant Unit 2 3.5.2-3 Amendment No..aw,~. 312

Containment Spray System 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.3

N()TE------------------------------

In M()DE 4, only the manual portion of the actuation signal is required.

Verify each automatic containment spray valve in 24 months the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

SR 3.6.6.4

N()TE------------------------------

In M()DE 4, only the manual portion of the actuation signal is required.

Verify each containment spray pump starts 24 months automatically on an actual or simulated actuation signal.

SR 3.6.6.5 Verify each spray nozzle is unobstructed.

Following maintenance that could result in nozzle blockage SR 3.6.6.6 Verify containment spray locations susceptible to a~ Elays fnl gas accumulation are sufficiently filled with water.

accordance withl

~he Surveillance!

FrequencYI Control Program!

Cook Nuclear Plant Unit 2 3.6.6-2 Amendment No. 2-W, 2-98, 312

RHR and Coolant Circulation - High Water Level

3.9.4 ACTIONS (continu*ed)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 AND A.5 Close equipment hatch and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months secure with four bolts.

Close one door in each air lock.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A.6 Verify each penetration 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing direct access from the containment atmosphere to the outside atmosphere is either closed with a manual or automatic isolation valve, blind flange, or equivalent, or is capable of being closed by an OPERABLE Containment Purge Supply and Exhaust Syst_em.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY.

SR 3.9.4.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of;::: 2000 gpm.

SR 3.9.4.2 Verify required RHR loop locations susceptible to a~ Elays fnl gas accumulation are sufficiently filled with water.

accordance withl the Surveillance!

Frequenc~

Control Program!

Cook Nuclear Plant Unit 2 3.9.4-2 Amendment No. 2-99, 312

RHR and Coolant Circulation - Low Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 Verify one RHR loop is in operation and circulating 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months reactor coolant at a flow rate of 2: 2000 gpm.

SR 3.9.5.2

N()TE------------------------------

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a required RHR pump is not in operation.

~--------------------------------------------------------

Verify correct breaker alignment and indicated 7 days power available to the required RHR pump that is not in operation.

SR 3.9.5.3 Verify RHR loop locations susceptible to gas a~ Eiays ~

accumulation are sufficiently filled with water.

accordance with[

~he Surveillance!

Frequencvl,

Control Program[

Cook Nuclear Plant Unit 2 3.9.5-3 Amendment No. 2-W, 312 Donald C. Cook Nuclear Plant Unit 1 Mark-Up Technical Specification Bases Pages 3.4.. 6-6 3.4.7-6 3.4.8-4 3.5.2-10 3.6.6-8 3.9.4-5 3.9.5-5

BASES RCS Loops - MODE 4 B 3.4.6 SURVEILLANCE REQUIREMENTS (continued) trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown, there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation. The Surveillance Frequenc is controlled under the Surveillance Fre uenc Control Program.

REFERENCES None.

Cook Nuclear Plant Unit 1 B 3.4.6-6 Revision No. XX - -.

BASES RCS Loops - MODE 5, Loops Filled B 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations, ~lternative methods (e.g.,

operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potenti_al accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

1.

NRC Information Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation."

Cook Nuclear Plant Unit 1 B 3.4.7-6 Revision No. XX

BASES RCS Loops - MODE 5, Loops Not Filled B 3.4.8 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System ts not rendered inoperable by the

. accumulated-gas (i.e., the system is sufficiently filled with water), the Surveillance may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote moniforing) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

None.

Cook Nuclear Plant Unit 1 B 3.4.8-4 Revision No. XX

BASES ECCS - Operating B 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by mo"nitoring a representative sub-set of susceptible locations. Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety.

F_or these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the EGGS piping and the procedural controls governing system operation.

he Surveillance -Frequenc is controlled under the Surveillance Fre uenc Control Pro ram.

1.

UFSAR, Section 1.4.7.

2.

10 CFR 50.46.

3.

UFSAR, Section 14.3.1.

4.

UFSAR, Section 14.3.2.

5.

UFSAR, Section 14.2.4.

6.

UFSAR, Section 14.2.5.

7.

UFSAR, Section 14.3.4.

8.

NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

9.

IE Information Notice No. 87-01

10.. ASl\\/IE, Operations and Maintenance Standards and Guides (OM Codes).

Cook Nuclear Plant Unit 1 B 3.5.2-10 Revision No. XX

BASES Containment Spray System B 3.6.6 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES controls governing system operation. The Surveillance Frequenc controlled under the Surveillance Fre uenc Control Program.

1.

UFSAR, Section 1.4.7.

2.

UFSAR, Section 14.3.4.

3.

10 CFR 50.49.

4.

10 CFR 50, Appendix K.

5.

ASME, Operation and Maintenance Standards and Guides (OM Codes).

Cook Nuclear Plant Unit 1 B 3.6.6-8 Revision No. XX

BASES RHR and Coolant Circulation - High Water Level B 3.9.4 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method.used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

1.

UFSAR, Section 9.3.2.

Cook Nuclear Plant Unit 1 B 3.9.4-5 Revision No. XX

BASES RHR and Coolant Circulation - Low Water Level B 3.9.5 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES criteria for the location. Susceptible locations in the same system flow

, path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

.Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of

the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

"The 31 day Frequency takes into consideration the gradual nature of gas

. accumulation. in the RHR System piping and the procedural controls governing system operation. The Surveillance Frequenc is controlled under the Surveillance Fre uenc Control Program.

1.

UFSAR, Section 9.3.2.

Cook Nuclear Plant Unit 1 B 3.9.5-5 Revision No. XX Donald C. Cook Nuclear Plant Unit 2 Mark-Up Technical Specification Bases Pages 3.4.6-6 3.4.7-6 3.4.8-4 3.5.2-10 3.6.6-8 3.9.4-5 3.9.5-5

BASES RCS Loops - MODE 4 B 3.4.6 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

This SR is modified by a Note that states the SR is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering MODE 4. In a rapid shutdown,

. there may be insufficient time to verify all susceptible locations prior to entering MODE 4.

None.

Cook Nuclear Plant Unit 2 B 3.4.6-6 Revision No. XX

BASES RCS Loops - MODE 5, Loops Filled B 3.4.7 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or

personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

1.

NRC lnformatio.n Notice 95-35, "Degraded Ability of Steam Generators to Remove Decay Heat by Natural Circulation."

Cook Nuclear Plant Unit 2 B 3.4.7-6 Revision No. XX

BASES RCS Loops - MODE 5, Loops Not Filled B 3.4.8 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES acceptance criterion for gas volume at the suction or discharge of a pump), the Surveillance is not met. If it is determined by subsequent evaluation that the RHR System is not rendered inoperable by the acc_umulated gas (i.e., the system is sufficiently filled with water), the Surveillance. may be declared met. Accumulated gas should be eliminated or brought within the acceptance criteria limits.

RHR System locations susceptible to gas accumulation are monitored and, if gas is found, the gas volume is compared to the acceptance criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations. that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location. Monitoring is not required for susceptible locations where. the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

None.

Cook Nuclear Plant Unit 2 B 3.4.8-4 Revision No. XX I

BASES ECCS - Operating B 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES For these locations, alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible location.

Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method *used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

system operation. The Surveillance Frequenc Surveillance Frequenc Control Program.

1.

U FSAR, Section 1.4. 7.

2.

10 CFR 50.46.

3.

UFSAR, Section 14.3.1.

4.

UFSAR, Section 14.3.2.BASES

5.

UFSAR, Section 14.2.4.

6.

UFSAR, Section 14.2.5.

7.

UFSAR, Section 14.3.4.

8.

NRC Memorandum to V. Stello, Jr., from R.L. Baer, "Recommended Interim Revisions to LCOs for ECCS Components,"

December 1, 1975.

9.

IE Information Notice No. 87-01.

10.

ASME, Operations and Maintenance Standards and Guides (OM Codes).

Cook Nuclear Plant Unit 2 B 3.5.2-10 Revision No. XX

BASES Containment Spray System B 3.6.6 susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system SURVEILLANCE REQUIREMENTS (continued REFERENCES OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

1.

UFSAR, Section 1.4.7.

2.

UFSAR, Section 14.3.4.

3.

10 CFR 50.49.

4.

10 CFR 50, Appendix K.

5.

ASME, Operation and Maintenance Standards and Guides (OM Codes).

Cook Nuclear Plant Unit 2 B 3.6.6-8 Revision No. XX

BASES RHR and Coolant Circulation - High Water Level B 3.9.4 SURVEILLANCE REQUIREMENT (continued)

REFERENCES

. location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the RHR System piping and the procedural controls governing system operation. The Surveillance Frequenc is controlled under the Surveillance Fre uenc Control Pro ram.

1.

UFSAR, Section 9.3.2.

Cook Nuclear Plant Unit 2 B 3.9.4-5 Revision No. XX

BASES RHR and Coolant Circulation - Low Water Level 8 3.9.5 SURVEILLANCE REQUIREMENTS (continued)

REFERENCES criteria for the location. Susceptible locations in the same system flow path which are subject to the same gas intrusion mechanisms may be verified by monitoring a representative sub-set of susceptible locations.

Monitoring may not be practical for locations that are inaccessible due to radiological or environmental conditions, the plant configuration, or personnel safety. For these locations alternative methods (e.g., operating parameters, remote monitoring) may be used to monitor the susceptible

location. Monitoring is not required for susceptible locations where the maximum potential accumulated gas void volume has been evaluated and determined to not challenge system OPERABILITY. The accuracy of the method used for monitoring the susceptible locations and trending of the results should be sufficient to assure system OPERABILITY during the Surveillance interval.

The 31 day Frequency takes into consideration the gradual nature of gas

. *accumulation in the RHR System piping and the procedural controls governing system operation. The Surveillance Frequenc is controlled under the Surveillance Frequenc Control Pro ram.

1.

UFSAR, Section 9.3.2.

Cook Nuclear Plant Unit 2 B 3.9.5-5 Revision No. XX I

v t e Letter Sequence Response to RAI
CAC:MF7114, (Approved, Closed)
Initiation Request, Request Acceptance... Supplement Administration Meeting Questions 11 May 2016 9 June 2016 1 August 2016 Answers 16 June 2016 9 September 2016 Results Approval Other:
MONTHYEAR2016-05-11 [Table View]

AEP-NRC-2016-69, Follow-up Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Relocate Surveillance Frequencies Program to License Control-Risk Informed Technical Specification Task Force

Text

References:

Enclosures:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 BACKGROUND

4.0 ENVIRONMENTAL CONSIDERATION

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