View source for AEP-NRC-2024-04, License Amendment Request Regarding a Change to Unit 1 Technical Specification 3.4.12, Low Temperature Overpressure Protection (LTOP) System

{{Adams
| number = ML24073A067
| issue date = 03/06/2024
| title = License Amendment Request Regarding a Change to Unit 1 Technical Specification 3.4.12, Low Temperature Overpressure Protection (LTOP) System
| author name = Ferneau K
| author affiliation = Indiana Michigan Power Co
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000315
| license number = 
| contact person = 
| case reference number = AEP-NRC-2024-04
| document type = Letter type:AEP, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment
| page count = 1
| project = 
| stage = Request
}}

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U.S. Nuclear Regulatory Commission AEP-NRC-2024-04 Page 2

==Enclosures:==
: 1. Affirmation.
: 2. Evaluation of Proposed Amendment to Revise Donald C. Cook Nuclear Plant (CNP) Unit 1 Technical Specification 3.4.12 Low Temperature Overpressure Protection (LTOP) System Completion Time for Required Action F.2.
: 3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification 3.4.12 Marked to Show Proposed Change.

c: EGLE - RMD/RPS J. B. Giessner - NRC Region III NRC Resident Inspector N. Quilico - MPSC R. M. Sistevaris - AEP Ft. Wayne S. P. Wall, NRC Washington D.C.
A. J. Williamson - AEP Ft. Wayne U.S. Nuclear Regulatory Commission AEP-NRC-2024-04 Page 3

bc: S. A. Dailey K. J. Ferneau R. B. Haemer K. M. Harper Q. S. Lies J. E. McClelland R. Ramirez M. K. Scarpello

Enclosure 2 to AEP-NRC-2024-04

Evaluation of Proposed Amendment to Revise Donald C. Cook Nuclear Plant (CNP) Unit 1 Technical Specification 3.4.12 Low Temperature Overpressure Protection (LTOP) System Completion Time for Required Action F.2.

1.0 

==SUMMARY==
DESCRIPTION

Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, requests an amendment to the CNP Unit 1 Operating License DPR-58, by incorporating the proposed change for the CNP Unit 1 Technical Specification (TS). The proposed amendment will add the Completion Time requirement Immediately to TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System, Actions Table to Condition F, Required Action F.2. Currently the Unit 1 TS 3.4.12, Condition F Completion Time for Required Action F.2 is left blank.

Adding the Completion Time for the Required Action F.2 of Condition F to the Unit 1 CNP, TS 3.4.12, LTOP System, will ensure consistency with the Unit 2 CNP, TS 3.4.12, LTOP System, to prevent misinterpretation of the omitted Completion Time Immediately and provide clarity for the Completion Time.

Approval of the proposed amendment is requested commensurate with the NRCs normal review schedule of approximately one year. The license amendment will be implemented within 90 days of NRC approval.

2.0 DETAILED DESCRIPTION

2.1 System Design and Operation

The LTOP System controls Reactor Coolant System (RCS) pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G. The reactor vessel is the limiting RCPB component for demonstrating such protection. TS 3.4.3, RCS Pressure and Temperature (P/T) Limits, provides the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Appendix G requirements during the LTOP System MODES of Applicability.

Limiting coolant input capability, during LTOP System conditions, requires that all Safety Injection (SI) pumps are incapable of injection into the RCS and isolation of the accumulators. Reactor Coolant Pumps (RCPs) shall not be started when RCS cold leg temperature is  degrees FDKUHQKHLW)
unless WKHVHFRQGDU\\ZDWHUWHPSHUDWXUHRIHDFKVWHDPJHQHUDWRULV  )DERYHHDFKRIWKH5&6
cold leg temperatures.

Due to the low pressures in the LTOP System MODES of Applicability and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve. In the event of a loss of RCS inventory, an SI pump can be placed in service for make up through manual actions.

Pressure relief for the LTOP System consists of one of the following:
to AEP-NRC-2024-04 Page 2
: 1) The Residual Heat Removal (RHR) suction relief valve with DVHWSRLQW SVLJ
and RCS cold leg WHPSHUDWXUH )
: 2) The Residual Heat Removal (RHR) suction relief valve with DVHWSRLQW SVLJ
and at least one 5&3UXQQLQJ
: 3) Two Power Operated Relief Valves (PORVs) ZLWKOLIWVHWWLQJV SVLJDQG
residual heat removal RHR suction relief valve ZLWKVHWSRLQW SVLJ
: 4) Two PORVs, with lift settings  SVLJDQG RCS cold leg WHPSHUDWXUH ) 
or
: 5) The RCS depressurized and an RCS vent of 2.0 square inches or any single PORV blocked open.

2.2 Current Technical Specifications Requirements

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

F. Required RCP not F.1 Do not start a RCP. Immediately running.
AND

F.2 Enter Condition G.

2.3 Reason for the Proposed Change

On April, 2020, I & M submitt ed a license amendment request for CNP Unit 1 (Reference 1). One of t he proposed changes in t his applicat ion was t o revise t he LTOP System requirements in TS 3. 4. 12 t o align with the updated LTOP System analysis.

In response to this amendment request the NRC has issued Amendment No. 356 to Renewed Facility Operating License No. DPR-58 for CNP Unit 1, on January 12, 2021 (Reference 3).

Similarly, the LTOP System analysis was subsequently updated for Unit 2. On June 15, 2021, I&M submitted a license amendment request for CNP Unit 2 (Reference 2).

The NRC has issued Amendment No. 341 to Renewed Facility Operating License No. DPR-4 for CNP Unit 2, on June 8, 2022 (Reference 4).

to AEP-NRC-2024-04 Page 3

After the Amendments were implemented in the CNP Unit 1 and Unit 2 TSs, it was identified that in TS 3.4.12 t he new Condition F Completion Time was different between the TS for Unit 1 and Unit 2.
In Unit 1 TS, Condition F Completion Time for Required Action F.2 is left blank.

The reason for the proposed change is to ensure that CNP Unit 1, TS 3.4.12, LTOP System, follows proper TS document formatting, to prevent misinterpretation of the omitted Completion Time Immediately, and provide clarity.

2.4 Description of the Proposed Change

I&M requests an amendment to the CNP Unit 1 Operating License DPR-58 by incorporating the proposed change for the CNP Unit 1 TS.

The request is to update Condition F, Required Action F.2 Completion Time, t o add Immediately for t he CNP Unit 1, TS 3.4.12, similarly t o h ow it is reflected f or t he CNP Unit 2, TS 3.4.12.

In the following mark up, the addition of text is shown by putting the new text in a box.

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

F. Required RCP not F.1 Do not start a RCP. Immediately running.
AND

F.2 Enter Condition G. Immediately

==3.0 TECHNICAL EVALUATION==
The basis for the proposed change to the CNP Unit 1, TS 3.4.12, is in the LTOP System analysis, included as Enclosure 6 of Reference 1, LTR-SCS-19-50, D.C. Cook Unit 1 Low Temperature Overpressure Protection (LTOP) System Analysis for 48 EFPY, Revision 0, dated March 5, 2020.

This LTOP System Analysis LTR-SCS-19-50, Revision 0, was performed and documented in Enclosure 6 to ensure the LTOP System prevents RCS over-pressurization for the postulated heat injection and mass injection transients. The LTOP System Analysis LTR-SCS-19-50, Revision 0, ensures the revised P/T limits contained in TS 3.4.3 are not exceeded.

The Unit 1, TS 3.4.12, was changed to reflect the requirements of the analysis documented in Enclosure 6 of Reference 1. These changes to the Limiting Condition of Operation (LCO) 3.4.12 reflect the minimum coolant input capability, limiting RCP startup transient, and pressure relief capacity per Analysis LTR-SCS-19-50, Revision 0.

Condition F was added to the CNP Unit 1, TS 3.4.12, to provide the actions necessary to take if the RCP required to be running by LCO 3.4.12 A.2.b is not running. Required Action F.1 ensures to AEP-NRC-2024-04 Page 4

that the RCP is not started because this could initiate a heat injection transient, and Required Action F.2 directs entry into Condition G Immediately to restore compliance with LTOP System pressure relief requirements.

==4.0 REGULATORY EVALUATION==
4.1 Applicable Regulatory Requirements/Criteria

Regulatory Requirements

The proposed change was developed in accordance with the following NRC regulations and guidance:

x 10 CFR 50 Appendix G x Regulatory Guide (RG) 1.99, Radiation Embrittlement of Reactor Vessel Materials, Revision 2 x ASME B&PV Code Section XI Appendix G, 1998 Edition through the 2000 Addenda x NRC Regulatory Issue Summary (RIS) 2014-11, Information on Licensing Applications for Fracture Toughness Requirements for Ferritic Reactor Coolant Pressure Boundary Components, dated October 14, 2014

10 CFR 50 Appendix G, by reference to ASME B&PV Code Section XI Appendix G specifies fracture toughness and testing requirements for the RCS carbon and low alloy steel materials.
10 CFR 50 Appendix G also requires prediction of the effects of neutron irradiation on vessel embrittlement by calculating the Adjusted Reference Temperature (ART) and the Charpy Upper Shelf Energy (USE). The methods provided in RG 1.99, Revision 2, defines the ART as the sum of unirradiated reference temperature, the increase of reference temperature resulting from neutron irradiation, and a margin to account for uncertainties in the prediction method.

As described in the CNP Updated Final Safety Analysis Report, Section 1.4, the Plant Specific Design Criteria (PSDC) defines the principal criteria and safety objectives for the CNP design. The following PSDC are relevant to the proposed amendment:

PSDC CRITERION 33 Reactor Coolant Pressure Boundary Capability

The reactor coolant pressure boundary shall be capable of accommodating without rupture the static and dynamic loads imposed on any boundary component as a result of an inadvertent and sudden release of energy to the coolant. As a design reference, this sudden release shall be taken as that which would result from a sudden reactivity insertion such as rod ejection (unless prevented by positive mechanical means), rod dropout, or cold water addition.

The proposed change is consistent with the above regulatory requirements and criteria. Therefore, the proposed change will assure safe operation by continuing to meet applicable regulations and requirements.

to AEP-NRC-2024-04 Page 5

4.2 No Significant Hazards Consideration

Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, is submitting a request for an amendment to the Technical Specification (TS) for CNP Unit 1, Operating License DPR-58. The proposed amendment will add the Completion Time requirement Immediately to TS 3.4.12, Low Temperature Overpressure Protection (LTOP) System, Actions Table to Condition F, Required Action F.2. Currently in Unit 1 TS 3.4.12, Condition F Completion Time for Required Action F.2 is left blank.

As required by 10 CFR 50.91(a), I&M, has evaluated the proposed change using the criteria in 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed TS change does not involve a significant increase in the probability or consequences of an accident previously evaluated. There are no physical changes to the plant being introduced by the proposed change. There are no changes in operating pressure, materials, or seismic loading.
The proposed change is adding clarity to TS 3.4.12, Required Action F.2, by providing a specific Completion Time and does not adversely affect the integrity of the RCS pressure boundary such that its function in the control of radiological consequences is affected.

Therefore, it is concluded that the proposed amendment does not involve a significant increase in the probability, or the consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed TS change does not create the possibility of a new or different kind of accident from any accident previously evaluated. No new modes of operation are introduced by the proposed change. The proposed change is adding clarity to TS 3.4.12, Required Action F.2, by providing a specific Completion Time and will not create any failure mode not bounded by previously evaluated accidents.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

to AEP-NRC-2024-04 Page 6

The proposed TS change does not involve a significant reduction in the margin of safety. The proposed change is adding clarity to TS 3.4.12, Required Action F.2, by providing a specific Completion Time and will continue to provide adequate margins of protection for the RCPB.

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

4.3 Conclusions

In conclusion, based on the considerations discussed above, there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.
Such activities will be conducted in compliance with the Commissions regulations. Issuance of the amendment will not be inimical to the common defense and security or to the health and safety of public.

==5.0 ENVIRONMENTAL CONSIDERATION==
Indiana Michigan Power Company (l&M) has evaluated the proposed amendments for environmental considerations. The review has resulted in the determination that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

==6.0 REFERENCES==
: 1) Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to the U. S. Nuclear Regulatory Commission (NRC), Donald C. Cook Nuclear Plant Unit 1 License Amendment Request Regarding a Change to the Reactor Coolant System Pressure and Temperature Limits and Low Temperature Overpressure Protection (LTOP) System, dated ApULO, 2020, Agencywide Documents Access and Management System Accession (ADAMS)
No. ML2 (.
: 2) Letter from Q. S. Lies, Indiana Michigan Power Company (I&M), to the U. S. Nuclear Regulatory Commission (NRC), Donald C. Cook Nuclear Plant Unit 2 License Amendment Request Regarding a Change to the Reactor Coolant System Pressure and Temperature Limits and Low Temperature Overpressure Protection (LTOP) System, dated June 15, 2021, Agencywide Documents Access and Management System Accession (ADAMS)
No. 0/ $.
: 3) Letter to J. P. Gebbie, Indiana Michigan Power Company (I&M), from the U.S. Nuclear Regulatory Commission (NRC), Donald C. Cook Nuclear Plant, Unit No.1 - Issuance of Amendment No 356 Re: Updating the Reactor Coolant System Pressure-Temperature Limits (EPID L-2020-LLA-0081), dated January 12, 2021, Agencywide Documents Access and Management System Accession (ADAMS) No. ML20329A001.
to AEP-NRC-2024-04 Page
: 4) Letter to J. P. Gebbie, Indiana Michigan Power Company (I&M), from the U.S. Nuclear Regulatory Commission (NRC), Donald C. Cook Nuclear Plant, Unit No.2 - Issuance of Amendment No 341 Re: Updating the Reactor Coolant System Pressure-Temperature Limits (EPID L-2021-LLA-0128), dated June 8, 2022, Agencywide Documents Access and Management System Accession (ADAMS) No. ML22055A001.
Enclosure 3 to AEP-NRC-2024-04

Donald C. Cook Nuclear Plant Unit 1 Technical Specification (TS) Page Marked To Show Proposed Changes TS 3.4.12 Required Action F.2 LTOP System 3.4.12

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

E. One required RCS relief E.1 Restore required RCS relief 24 hours valve inoperable in valve to OPERABLE status.
MODE 5 or 6 while complying with LCO A.2.c or A.2.d.

F. Required RCP not F.1 Do not start a RCP. Immediately running.
AND

F.2 Enter Condition G. Immediately

G. Two or more required G.1 Depressurize RCS and 12 hours RCS relief valves establish RCS vent of 2.0 inoperable. square inches or block open a single PORV.
OR

Required Action and associated Completion Time of Condition A, C, D, E, or F not met.

OR

LTOP System inoperable for any reason other than Condition A, B, C, D, E, or F.

Cook Nuclear Plant Unit 1 3.4.12-3 Amendment No. 287, 334, 356}}