ML20315A483

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Issuance of Amendment Nos. 354 and 334 Adopt Technical Specification Task Force Traveler TSTF-412, Revision 3, Provide Actions for One Steam Supply to the Turbine Driven Afw/Efw Pump Inoperable
ML20315A483
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/30/2020
From: Scott Wall
Plant Licensing Branch III
To: Gebbie J
Indiana Michigan Power Co
Wall S
References
EPID L-2020-LLA-0084
Download: ML20315A483 (25)


Text

December 30, 2020 Mr. Joel P. Gebbie Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 354 AND 334 REGARDING ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER, TSTF-412, REVISION 3, PROVIDE ACTIONS FOR ONE STEAM SUPPLY TO THE TURBINE DRIVEN AFW/EFW PUMP INOPERABLE (EPID L-2020-LLA-0084)

Dear Mr. Gebbie:

The U S Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 354 and 334 to Renewed Facility Operating License Nos. DPR-58 and DPR-74, for the Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2, respectively. The amendments consist of changes to the license and technical specifications (TSs) in response to your application dated April 7, 2020, as supplemented by letter dated October 27, 2020.

The amendments revise Conditions, Required Actions, and Completion Times in the TSs for the Condition where one steam supply to the turbine-driven auxiliary feedwater (AFW) pump is inoperable concurrent with an inoperable motor-driven AFW train.

In addition, the amendments revise the TSs that establish specific Actions: (1) for when two motor-driven AFW trains are inoperable at the same time and; (2) for when the turbine-driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply.

The amendments are consistent with NRC-approved Technical Specification Task Force (TSTF)

Traveler, TSTF-412, Revision 3, Provide Actions for One Steam Supply to Turbine Driven AFW/EFW [Emergency Feedwater] Pump Inoperable. The availability of this technical specification improvement was announced in the Federal Register on July 17, 2007 (72 FR 39089), as part of the consolidated line item improvement process.

J. Gebbie A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Amendment No. 354 to DPR-58
2. Amendment No. 334 to DPR-74
3. Safety Evaluation cc: Listserv

INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-315 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 354 License No. DPR-58

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Indiana Michigan Power Company dated April 7, 2020, as supplemented by letter dated October 27, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-58 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 354, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Robert Robert F. F. Kuntz Date: 2020.12.30 Kuntz 10:20:08 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: December 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 354 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-315 Renewed Facility Operating License No. DPR-58 Replace the following page of the Renewed Facility Operating License No. DPR-58 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

REMOVE INSERT Technical Specifications Replace the following pages of the Renewed Facility Operating License, Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

REMOVE INSERT 3.7.5-1 3.7.5-1 3.7.5-2 3.7.5-2 3.7.5-3 3.7.5-3

-- 3.7.5-4

and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3304 megawatts thermal in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 354, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Less than Four Loop Operation The licensee shall not operate the reactor at power levels above P-7 (as defined in Table 3.3.1-1 of Specification 3.3.1 of Appendix A to this renewed operating license) with less than four reactor coolant loops in operation until (a) safety analyses for less than four loop operation have been submitted, and (b) approval for less than four loop operation at power levels above P-7 has been granted by the Commission by amendment of this license.

(4) Fire Protection Program Indiana Michigan Power Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensees amendment request dated July 1, 2011, as supplemented by letters dated September 2, 2011, April 27, 2012, June 29, 2012, August 9, 2012, October 15, 2012, November 9, 2012, January 14, 2013, February 1, 2013, Renewed License No. DPR-58 Amendment No: 332, 334, 335, 336, 337, 338, 343, 344, 345, 346, 347, 348, 349, 350, 351, 352, 354

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.


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

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS


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

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected equipment 7 days train inoperable due to to OPERABLE status.

one inoperable steam AND supply.

10 days from OR discovery of failure to meet the LCO


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

Only applicable if MODE 2 has not been entered following refueling.

Turbine driven AFW pump inoperable in MODE 3 following refueling.

Cook Nuclear Plant Unit 1 3.7.5-1 Amendment No. 287, 354

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable in MODE 1, OPERABLE status.

2, or 3 for reasons other AND than Condition A.

10 days from discovery of failure to meet the LCO C. Turbine driven AFW C.1 Restore the steam supply 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train inoperable due to to the turbine driven train to one inoperable steam OPERABLE status.

supply.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW train to OPERABLE train inoperable. status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

E. Three AFW trains E.1 --------------NOTE--------------

inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately AFW train to OPERABLE status.

Cook Nuclear Plant Unit 1 3.7.5-2 Amendment No. 287, 354

AFW System 3.7.5 ACTIONS (Continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required AFW train F.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------NOTE------------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each required AFW manual, power operated, In accordance and automatic valve in each water flow path, and in with the both steam supply flow paths to the steam turbine Surveillance driven pump, that is not locked, sealed, or otherwise Frequency secured in position, is in the correct position. Control Program SR 3.7.5.2 -------------------------------NOTE------------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 850 psig in the steam generator.

Verify the developed head of each required AFW In accordance pump at the flow test point is greater than or equal with the to the required developed head. INSERVICE TESTING PROGRAM Cook Nuclear Plant Unit 1 3.7.5-3 Amendment No. 287, 334, 335, 354

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 -------------------------------NOTES----------------------------

1. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.
2. Only required to be met in MODES 1, 2, and 3.

Verify each AFW automatic valve that is not locked, In accordance sealed, or otherwise secured in position, actuates to with the the correct position on an actual or simulated Surveillance actuation signal. Frequency Control Program SR 3.7.5.4 ------------------------------NOTES-----------------------------

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 850 psig in the steam generator.
2. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.
3. Only required to be met in MODES 1, 2, and 3.

Verify each AFW pump starts automatically on an In accordance actual or simulated actuation signal. with the Surveillance Frequency Control Program Cook Nuclear Plant Unit 1 3.7.5-4 Amendment No. 287, 334, 354

INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-316 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 334 License No. DPR-74

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Indiana Michigan Power Company dated April 7, 2020, as supplemented by letter dated October 27, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-74 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 334, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Robert Robert F. F. Kuntz Date: 2020.12.30 Kuntz 10:20:44 -05'00' Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: December 30, 2020

ATTACHMENT TO LICENSE AMENDMENT NO. 334 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-316 Renewed Facility Operating License No. DPR-74 Replace the following page of the Renewed Facility Operating License No. DPR-74 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.

REMOVE INSERT Technical Specifications Replace the following pages of the Renewed Facility Operating License, Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

REMOVE INSERT 3.7.5-1 3.7.5-1 3.7.5-2 3.7.5-2 3.7.5-3 3.7.5-3

-- 3.7.5-4

and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3468 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to the renewed operating license. The preoperational tests, startup tests and other items identified in Attachment 1 to this renewed operating license shall be completed.

Attachment 1 is an integral part of this renewed operating license.

(2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 334, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Additional Conditions (a) Deleted by Amendment No. 76 (b) Deleted by Amendment No. 2 (c) Leak Testing of Emergency Core Cooling System Valves Indiana Michigan Power Company shall prior to completion of the first inservice testing interval leak test each of the two valves in series in the Renewed License No. DPR-74 Amendment No. 313, 314, 316, 317, 318, 319, 320, 325, 326, 327, 328, 329, 330, 331, 332, 334

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.


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

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS


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

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected equipment 7 days train inoperable due to to OPERABLE status.

one inoperable steam AND supply.

10 days from OR discovery of failure to meet the LCO


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

Only applicable if MODE 2 has not been entered following refueling.

Turbine driven AFW pump inoperable in MODE 3 following refueling.

Cook Nuclear Plant Unit 2 3.7.5-1 Amendment No. 269, 334

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable in MODE 1, OPERABLE status.

2, or 3 for reasons other AND than Condition A.

10 days from discovery of failure to meet the LCO C. Turbine driven AFW C.1 Restore the steam supply 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train inoperable due to to the turbine driven train to one inoperable steam OPERABLE status.

supply.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW Train to OPERABLE train inoperable. status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 4. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

E. Three AFW trains E.1 --------------NOTE--------------

inoperable in MODE 1, LCO 3.0.3 and all other 2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately AFW train to OPERABLE status.

Cook Nuclear Plant Unit 2 3.7.5-2 Amendment No. 269, 334

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required AFW train F.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -------------------------------NOTE------------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each required AFW manual, power operated, In accordance and automatic valve in each water flow path, and in with the both steam supply flow paths to the steam turbine Surveillance driven pump, that is not locked, sealed, or otherwise Frequency secured in position, is in the correct position. Control Program SR 3.7.5.2 -------------------------------NOTE------------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 850 psig in the steam generator.

Verify the developed head of each required AFW In accordance pump at the flow test point is greater than or equal with the to the required developed head. INSERVICE TESTING PROGRAM Cook Nuclear Plant Unit 2 3.7.5-3 Amendment No. 269, 316, 317, 334

AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 -------------------------------NOTES----------------------------

1. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.
2. Only required to be met in MODES 1, 2, and 3.

Verify each AFW automatic valve that is not locked, In accordance sealed, or otherwise secured in position, actuates to with the the correct position on an actual or simulated Surveillance actuation signal. Frequency Control Program SR 3.7.5.4 ------------------------------NOTES-----------------------------

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 850 psig in the steam generator.
2. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.
3. Only required to be met in MODES 1, 2, and 3.

Verify each AFW pump starts automatically on an In accordance actual or simulated actuation signal. with the Surveillance Frequency Control Program Cook Nuclear Plant Unit 2 3.7.5-4 Amendment No. 269, 316, 334

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 354 AND 334 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-58 AND DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-315 AND 50-316

1.0 INTRODUCTION

By application dated April 7, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20126G454), as supplemented by letter dated October 27, 2020 (ADAMS Accession No. ML20307A102), Indiana Michigan Power Company (I&M, the licensee),

requested changes to the technical specifications (TSs) for the Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP 1 and 2).

The requested changes adopt Technical Specification Task Force (TSTF) Traveler TSTF-412, Revision 3, Provide Actions for One Steam Supply to the Turbine Driven AFW/EFW [Auxiliary Feedwater/Emergency Feedwater] Pump Inoperable. The U.S. Nuclear Regulatory Commission (NRC, the Commission) approval of these changes was announced in the Federal Register on July 17, 2007 (72 FR 39089), as part of the consolidated line item improvement process. The requested change would establish a new Condition and respective Required Actions and Completion Times (CT) for the Condition where one steam supply to the turbine-driven AFW train is inoperable concurrent with an inoperable motor-driven AFW train. It also modifies an existing Condition addressing two motor-driven AFW trains inoperable by limiting it to reasons other than the new Condition established. In addition, it proposes several conforming editorial changes.

The supplemental letter dated October 27, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published the Federal Register on June 16, 2020 (85 FR 36432).

2.0 REGULATORY EVALUATION

2.1 System Description The AFW system is designed to automatically supply sufficient water to the steam generators (SGs) to remove decay heat upon the loss of normal feedwater supply with SG pressure at the set point of the main steam safety valves. Subsequently, the AFW system supplies sufficient Enclosure 3

water to cool the unit to residual heat removal system entry conditions, with steam being released through the atmospheric dump valves. The AFW system is designed to provide sufficient make-up to the SGs when the main feedwater supply is not available, particularly under the following scenarios: Loss of main feedwater, station blackout, cooldown, rupture of main feedline and rupture of main steamline. Major rupture of a main feedwater pipe is not part of the CNP 1 licensing basis.

The AFW system at CNP 1 and 2 consist of two motor-driven AFW pumps and one steam turbine-driven pump configured into three trains. Each motor-driven pump is sized to supply the feedwater flow required for removal of 100 percent of the decay heat from the reactor. The turbine-driven pump is sized to supply up to twice the capacity of a motor-driven pump. The steam turbine-driven pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100 percent of the requirements of the turbine-driven AFW pump.

2.2 Proposed TS Changes

The TS 3.7.5 limiting condition for operation (LCO) statement requires three AFW trains to be OPERABLE. The LCO applies during MODES 1, 2, and 3. Condition A describes two situations when the LCO is not met due to an inoperable turbine-driven AFW pump. The first situation is currently described as One steam supply to turbine driven AFW pump inoperable.

The licensee proposed revising the description of the situation to Turbine driven AFW train inoperable due to one inoperable steam supply.

The licensee proposed adding new Condition C to describe the situation when the LCO is not met due to the turbine-driven AFW train being rendered inoperable by one inoperable steam supply concurrent with one inoperable motor-driven AFW train. Proposed Required Action C.1 would require restoring the inoperable steam supply to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Proposed Required Action C.2 would require restoring the inoperable motor-driven AFW train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The required Actions would be separated by a logical OR operator which has the effect of allowing continued operation once one of the required actions is completed within the respective CT.

Current Condition C describes the situation when the LCO is not met because two AFW trains are inoperable. It states Two AFW trains inoperable in MODE 1, 2, or 3. As a result of the new proposed Condition C, the licensee proposed revising the description of current Condition C to state Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

The licensee also proposed re-lettering current Conditions C, D, and E along with their associated actions to Conditions and associated actions D, E, and F, respectively.

2.3 Guidance and Requirements Considered by NRC Staff In Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.36, the Commission established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36(c), TS are required to include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements; (4) design features; and (5) administrative controls.

The regulation at 10 CFR 50.36(c)(2) states, in part: Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. The remedial actions must provide reasonable assurance that the applicant will comply with the Commissions regulations, and that the health and safety of the public will not be endangered.

Guidance for NRC staff review of TSs is contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor]

Edition, Section 16.0, Technical Specifications. The NRC staff has prepared standard technical specifications (STS) for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The guidance specifies that the staff review whether content and format of proposed TS are consistent with the applicable STS. Where TS provisions depart from the reference TSs, the staff determines whether proposed differences are justified by uniqueness in plant design or other considerations. The applicable current STS for CNP are contained in NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0. TSTF-412, Revision 3 was approved by NRC prior to issuance of Revision 4.0 of NUREG-1431. TSTF-412 has been incorporated into Revision 4 of NUREG-1431.

3.0 TECHNICAL EVALUATION

3.1 Method of Review The NRC staff reviewed the licensees proposed changes to the TS, as well as the justifications and evaluations provided in the license amendment request and supplemental letter. To perform the review, the NRC staff compared the licensees proposal to the standard language in NUREG-1431, and the NRC staff also compared the licensees proposal to the request for, and approval of, TSTF-412. The NRC staff determined that CNP TS is consistent with NUREG-1431, Standard Technical Specifications - Westinghouse Plants, Revision 4.0.

3.2 LCO 3.7.5 Condition A (as proposed)

Condition A is modified to refer to the inoperability of a turbine-driven AFW train due to an inoperable steam supply, instead of referring to the inoperability of a turbine-driven AFW pump.

The proposed change has the effect of making Condition A train-oriented instead of component-oriented, consistent with the other Conditions that are included in NUREG-1431 STS 3.7.5. The NRC staff determined the train-oriented approach is consistent with the preferred approach that is generally reflected in the STS, and, therefore, the proposed change is acceptable.

3.3 New TS 3.7.5, Condition C NUREG-1431 typically allows a 72-hour or longer CT for Conditions where the remaining operable equipment is able to mitigate postulated accidents without assuming a concurrent single active failure. TSTF-412, as approved by the staff, only allows a 24-hour CT for the situation where the AFW system would be able to perform its function for most postulated events and would only be challenged by a main steam line break (MSLB) or feedwater line break (FLB) that renders the remaining operable steam supply to the turbine-driven AFW pump inoperable. Additionally, depending on the capacity of the operable motor-driven AFW pump, it

may be able to mitigate MSLB and FLB accidents during those instances when it is not aligned to the faulted SG. The selection of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the CT during development of TSTF-412 was based on the remaining operable steam supply to the turbine-driven AFW pump and the continued functionality of the turbine-driven AFW train, the remaining operable motor-driven AFW train, and the low likelihood of an event occurring during this 24-hour period that would challenge the capability of the AFW system to provide feedwater to the SGs. The CT for this particular situation is consistent with what was approved for the Waterford Steam Electric Station, Unit 3, by License Amendment 173 for a similar Condition (ADAMS Accession No. ML012840538), and it is consistent with the STS in that the proposed CT is much less than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> that is allowed for the situation where accident mitigation capability is maintained.

I&M proposed a new Condition C, consistent with TSTF-412, with two possible Required Actions (C.1 or C.2) for the situation when the turbine-driven AFW train is inoperable due to one inoperable steam supply and one motor-driven AFW train is inoperable at the same time.

Required Action C.1 requires restoration of the affected steam supply to the turbine-driven train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Alternatively, Required Action C.2 requires restoration of the inoperable motor-driven AFW train within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

New Condition C provides two proposed CTs that are dependent upon the capacity of the remaining operable motor-driven AFW train to provide AFW to the SGs. A proposed 24-hour CT is applicable to plants that may provide insufficient flow to the SGs in accordance with accident analyses assumptions if an MSLB or FLB were to occur that renders the remaining steam supply to the turbine-driven AFW pump inoperable (a concurrent single failure is not assumed). Insufficient feedwater flow could result, for example, if a single motor-driven AFW train does not have sufficient capacity to satisfy accident analyses assumptions, or if the operable pump is feeding the faulted SG (i.e., the SG that is aligned to the operable steam supply for the turbine-driven AFW pump). This would typically apply to plants with each AFW motor-driven pump having less than 100 percent of the required flow. The 24-hour CT is reasonable based on the remaining OPERABLE steam supply to the turbine-driven AFW pump, the availability of the remaining OPERABLE motor-driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine-driven AFW pump. Therefore, the NRC staff agrees that the proposed 24-hour CT is acceptable for this particular situation.

3.4 Re-lettered TS 3.7.5, Condition D The current Condition C and Required Actions are re-lettered as Condition D and Required Actions D.1 and D.2. Re-lettering is also applied within the statements in the Condition. The Condition description has been modified to account for new Condition C. The Condition description is modified from Two AFW trains inoperable in MODE 1, 2, or 3 to Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C. This change is necessary to recognize the situation specified by new Condition C, where one motor-driven AFW train is allowed to be inoperable at the same time that the turbine-driven AFW train is inoperable due to an inoperable steam supply to the pump turbine. Therefore, the NRC staff finds the proposed change to be acceptable 3.5 Re-lettered TS 3.7.5 Condition E The current Condition D and Required Action D.1 are re-lettered as Condition E and Required Action E.1. The Condition description has been modified to account for addition of new Condition C and related changes as well as to adopt NUREG-1431 language. The Required Action associated with this Condition was renamed from D.1 to E.1 but not otherwise changed.

The NRC staff finds these changes editorial and necessary for internal consistency of TS 3.7.5 as amended. Therefore, the NRC staff determined the proposed change is acceptable.

3.6 Re-lettered TS 3.7.5 Condition F The current Condition E and Required Action are re-lettered as Condition F and Required Action F.1. The NRC staff determined this change is editorial since no other changes are involved. Therefore, the NRC staff determined the proposed change is acceptable.

3.7 Technical Conclusion The NRC staff reviewed the proposed changes as well as the licensees justifications for the changes. In accordance with NUREG-0800, the NRC staff determined that the content and format of proposed TS are generally consistent with the NUREG-1431. Where TS provisions depart from NUREG-1431, the NRC staff determined the proposed differences are justified by uniqueness in plant design and licensing basis. The NRC staff determined that CNP 1 and 2 TSs, as modified by the proposed changes to the remedial actions, will continue to meet the regulatory requirements of 10 CFR 50.36(c)(2). Therefore, the NRC staff determined the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the State of Michigan official was notified of the proposed issuance of the amendments on November 10, 2020. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration as published in the Federal Register on June 16, 2020 (85 FR 36432), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be

conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: S. Wall, NRR C. Tilton, NRR A. Stubbs, NRR D. Scully, NRR Date: December 30, 2020

ML20315A483 *via e-mail OFFICE NRR/DORL/LPL3/PM* NRR/DORL/LPL3/LA* NRR/DSS/SCPB/BC* NRR/DSS/STSB/BC*

NAME SWall SRohrer (JBurkhardt for) BWittick VCusumano*

DATE 11/13/2020 11/13/2020 11/20/2020 11/18/2020 OFFICE OGC - NLO* NRR/DORL/LPL3/BC* NRR/DORL/LPL3/PM*

NAME CCarson NSalgado (RKuntz for) SWall DATE 12/29/2020 12/30/2020 12/30/2020