View source for AEP-NRC-2020-09, Unit 2, Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 Provide Actions for One Steam, Supply to Turbine Driven Afw/Efw Pump Inoperable

{{Adams
| number = ML20126G454
| issue date = 04/07/2020
| title = Unit 2, Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 Provide Actions for One Steam, Supply to Turbine Driven Afw/Efw Pump Inoperable
| author name = Gebbie J
| author affiliation = Indiana Michigan Power Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000315, 05000316
| license number = DPR-058, DPR-074
| contact person = 
| case reference number = AEP-NRC-2020-09, TSTF-412, Rev 3
| document type = Legal-Affidavit, Letter type:AEP, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Bases Change
| page count = 25
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Indiana Michigan Power Company Nuclear Genera1,on Gro.,p INDIJINA                                                                              One Cook Place MICHIGAN                                                                               Bridgman. Ml 49106 POWIR                                                                                  aep.com April 7, 2020                                                                      AEP-NRC-2020-09 10 CFR 50.90 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant, Unit 1 and Unit 2 Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 "Provide Actions for
                  .One Steam, Supply to Turbine Driven AFW/EFW Pump Inoperable."
In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP), is submitting a request for an amendment to Technical Specifications (TS) for CNP Unit 1 and Unit 2.
The proposed amendment establishes Conditions, Required Actions, and Completion, Times in the Standard Technical Specifications (STS) 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, this amendment establishes changes to the STS 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 change is consistent with Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler, TSTF--412, Revision 3, ''Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable." The availability of this TS improvement was announced in the Federal Register on July 17, 2007 as part of the consolidated line item improvement process (CLIIP). provides an affirmation statement pertaining to the information contained herein. provides a description and assessment of the proposed changes.
Enclosures 3 and 4 provide existing Unit 1 and Unit 2 TS pages, respectively, marked up to show the proposed changes.

U. S. Nuclear Regulatory Commission                                               AEP-NRC-2020-09 .
Page 2
* Enclosures 5 and 6 provide existing Unit 1 and Unit 2 TS Bases pages, respectively, marked up to .
show the proposed changes. TS Bases markups are included for information only. Changes to the existing TS Bases will be implemented under TS 5.5.12, "Technical Specifications (TS) Bases Control Program."
New, clean, Unit 1 and Unit 2 TS pages, with proposed changes incorporated will be provided to the NRC Licensing Project Manager when requested .
. Approval of the proposed amendment is requested in accordance with the normal NRC review schedule for such changes. Once approved, the amendment shall be implemented within 90 days.
In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan state officials.
There are no new regulatory commitments made in this letter..Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.
Sincerely, Joel P. Gebbie Senior Vice President &
Chief Nuclear Officer DLW/mll

==Enclosures:==
: 1. Affirmation
: 2. Description and Assessment of the Technical Specification Changes
: 3. Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes                          *                                                .
: 4. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Proposed Changes
: 5. Donald C. Cook Nuclear Plant u*nit .1 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only)
: 6. Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only)

U. S. Nuclear Regulatory Commission                     AEP-NRC-2020-09 Page3
*c:     R J. Ancona - MPSC EGLE - RMD/RPS J.B. Giessner-NRC Region Ill NRC Resident Inspector D. J. Roberts - NRC Region Ill S.P. Wall - NRC, Washington, D.C.
A. J. Williamson - AEP Ft. Wayne, w/o enclosures to AEP*NRC-2020-09 Affirmation

Enclosure-1 to AEP*NRC-2020*09
. AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am the Senior Vice President and Chief Nuclear Officer 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 Qompany
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SWORN TO AND SUBSCRIBED BEFORE ME DANIELLE BURGOYNE 2020      Notary Publlo, State of. Mlohlr,,n County of Berrien My Commission Explrea04*04-2024 Acting ln_t~e County of:>> C:(,~
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Enclqsure 2 to AEP*NRC-2020*09 Description and Assessment of the Technical Specification Changes

==1.0 DESCRIPTION==

2.0 ASSESSMENT 2.1
* Applicability of Published Safety Evaluation 2.2   Optional Changes and Variations

==3.0 REGULATORY ANALYSIS==

3.1   No Significant Hazards Consideration Determination 3.2   Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION

Enclosure 2 to AEP-NRC-2020-09                                                          Page2

==1.0      DESCRIPTION==

The proposed License amendment establishes a new Completion Time in Standard Technical
* Specifications Section 3.7.5 where one steam supply to the turbine driven Auxiliary
  *Feedwater (AFW) pump is inoperable concurrent with an inoperable motor.driven AFW train. This amendment also establishes specific Conditions and Action requirements: (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 changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler;TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW Pump Inoperable." The *availability of this Technical Specification (TS) improvement was announced in the Federal Register on July 17, 2007 (72 FR 39089) as part of the consolidated line item improvement process (CLIIP).
2.0      ASSESSMENT 2.1      Applicability of Publlshed Safety Evaluation Indiana Michigan Power (l&M) the licensee for Donald C. Cook Nuclear Plant (CNP), Unit 1 and Unit 2. has reviewed the safety evaluation published on July 17, 2007 (72 FR 39089), as part of the CLIIP. This verification included a review of the NRC staff's evaluation, as well as the supporting information provided in TSTF-412, Revision 3. l&M has concluded that the justifications presented in TSTF-412 and the safety evaluation prepared by the NRC staff are applicable to CNP Unit 1 and Unit 2, including consideration of related information provided in NRC letter (ML15286A331) dated October 30, 2015, and justify this amendment for the incorporation of the changes to the CNP Unit 1 and Unit 2 TS.
2.2      Optional Changes and Variations l&M is not proposing any variations or deviations from the TS changes described in TSTF-412, Revision 3, or the NRC staff's model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089).                                                          .
Note that CNP Unit 1 and Unit' 2 TS 3.7.5 Actions A and B still contain the second Completion Time that limits the time from discovery ofa failure. TSTF-439 eliminated the second completion time and is reflected in the sample shown in TSTF-412 Revision 3. CNP has not adopted TSTF-439 and is. not requesting approval to eliminate the second Completion Time in this submittal.
* With respect to the Completion Times associated with new Required Actions C.1 and C.2, l&M has chosen a 24-hour Completion Time.

Enclosure 2 to AEP-NRC-2020-09                                                             Page3

==3.0     REGULATORY ANALYSIS==

A description of the proposed change and its relationship to applicable regulatory requirements and guidance was provided in the Notice of Availability published on July 17, 2007 (72 FR 39089).
3.1     No Significant Hazards Consideration Determination l&M has reviewed the proposed no significant hazards consideration determination published on July 17, 2007, as part of the CLIIP. l&M has concluded that the proposed determination presented
.in the notice is applicable to CNP Unit 1 and Unit 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2     Verification and Commitments .
There are no new regulatory commitments associated with this proposed change.
4.0     ENVIRONMENTAL EVALUATION l&M has reviewed the environmental evaluation included in the model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089), as part of the CLIIP. l&M has concluded that the NRC staff's findings presented in that evaluation are applicable to CNP Unit 1 and Unit 2, and the evaluation Is hereby incorporated by reference for this application.

Enclosure 3 to AEP-NRC-2020-09 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked to Show Proposed Changes 3.7.5-1 3.7.5-2 3.7.5-3

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 filJ.QQ.!y. One steam supply to turbine driven                                                              10 days from
       /\FW pump inoperable.                                                                 discovery of failure to meet the LCO OR
        ------------NOTE------------
Only applicable if MO DE 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. 2-8+

AFW System 3.7.5 ACTIONS (continued)
CONDITION                      REQUIRED ACTION                         COMPLETION TIME B. One AFW train              B.1       Restore AFW train to                   72 hours 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 suggly to the              24 hours train inogerable due to        turbine driven train to one inogerable steam           OPERABLE status.
suggly.
OR                                          24 hours AND C.2 Restore the motor driven AFW One motor driven AFW           train to OPERABLE status.
train inogerable.
GD. Required Action and       GD.1 Be in MODE 3.                               6 hours associated Completion Time fef-of Condition A,       AND
     ~ . or 8Q_not met.
GD.2     Be in MODE 4.                           18 hours OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.
Of..Three AFW trains          Q.f_.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, 334

AFW System 3.7.5 CONDITION                             REQUIRED ACTION                       COMPLETION TIME E. Required AFW train              E.1       Initiate action to restore          Immediately inoperable in MODE 4.                      AFW train to OPERABLE status.
SURVEI LLANCE 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 hours 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 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.
Cook Nuclear Plant Unit 1                            3.7.5-3                      Amendment No. 287, ~

Enclosure 4 to AEP-NRC-2020*09 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked to Show Proposed Changes 3.7.>1 3.7.>2 3.7.>3

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5        Auxiliary Feedwate,r (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 supply. One steam supply to turbine driven                                                            10 days from
       .A.'FW pump inoperable.                                                             discovery of failure to meet the LCO OR
       ------------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.--2e9

AFW System 3.7.5 ACTIONS (continued)
CONDITION               REQUIRED ACTION                         COMPLETION TIME B. One AFW train              B.1   Restore AFW train to                   72 hours 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 hours train inoperable due to         to the turbine driven train to one inoperable steam            OPERABLE status.
supply.
OR                                           24 hours AND C.2   Restore the motor driven One motor driven AFW            AFW train to OPERABLE train inoperable.               status.
GD. Required Action and       GD .1 Be in MODE 3.                          6 hours associated Completion Time fef-of Condition A  AND
     .12... or 8 Q not met.
GD.2  Be in MODE 4.                          18 hours OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.
Qf.Three AFW trains           Qf.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. 2e9,     a+e

AFW System 3.7.5 COND ITION                           REQUIRED ACTION                        COMPLETION TIME ef. Required AFW train             ef.1       Initiate action to restore           Immediately inoperable in MODE 4.                     AFW train to OPERABLE status.
SURVE ILLANCE REQUIR EMENTS 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 hours 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, ~

Enclosure 5 to AEP-NRC-2020-09 Donald C. Cook Nuclear Plant Unit 1 Technical Specification Bases Pages Marked to Show Proposed Changes (For Information Only) 83.7.5-4 B3.7.5-5 83.7.5-6 83.7.5-7

AFW System B 3.7.5 BASES LCO (continued)
The AFW System is configured into three trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.
This requires that the two motor driven AFW pumps be OPERABLE in two independent discharge paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of two main steam lines upstream of the SGSVs, and shall be capable of supplying AFW to all of the steam generators. The piping, valves, instrumentation, and controls required to perform the safety related function also are required to be OPERABLE.
The LCO is modified by a Note indicating that only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.
This is because of the reduced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump.
APPLICABILITY        In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.
In MODE 4 the AFW System may be used for heat removal via the steam generators.
In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.
ACTIONS              A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the Cook Nuclear Plant Unit 1                    B 3.7.5-4                             Revision No. O

AFW System B 3.7.5 BASES ACTIONS (continued) inoperable equ ipment to an OPERABLE status within 7 days. The 7 day Completion T ime is reasonable, based on the following reasons:
: a. For the inoperability of a steaFR s~1313ly ta the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events .
: b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation .
: c. For both the inoperability of a steaFR s~1313ly liRe te the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump whi le in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.
The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.
The 1O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO . This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 1O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.
Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling. Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour Completion T ime in Condition B. This longer Completion Time is based on the reduced decay heat following refuel ing and prior to the reactor being critical .
W ith one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2 , or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours. This Condition includes the Cook Nuclear Plant Unit 1                    B 3.7.5-5                               Revision No. 63

AFW System B 3.7.5 loss of two steam supply lines to the turbine driven AFW pump. The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a OBA occurring du ring this time period .
The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.
The 1O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours and 1O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.
C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours. Assuming no single active failures when in this condition, the accident (a MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the analysis requiring flow from two AFW pumps.
The 24 hour Completion Time 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 D.1 and D.2 When Required Action A.1.. &F 8 .1, C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 18 hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
Cook Nuclear Plant Unit 1                   B 3.7.5-6                             Revision No. 63

AFW System 8 3.7.5 BASES ACTIONS (continued)
In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.
If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.
Required Action GE. 1 is modified by a Note indicating that all required MODE changes or power roduotions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.
In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circu lation. This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.
SURVEILLANCE        SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the required AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. Verification of the AFW System water supply flow path includes both the suction (either a flow path from the CST or the Essential Service Water (ESW) System) and discharge flow paths. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
Cook Nuclear Plant Unit 1                  B 3.7.5-7                              Revision No. 63

Enclosure 6 to AEP-NRC-2020-09 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked to Show Proposed Changes (For Information Only) 83.7.5-5 83.7.5-6 83.7.5-7

AFW System B 3.7.5 BASES ACTIONS             A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
If ono of tt:io t1N-0 steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:
: a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.
: b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.
: c. For both the inoperability of a steam supply lino to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.
The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.
The 1O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 1O days Cook Nuclear Plant Unit 2                     B 3.7.5-5                             Revision No. O

AFW System B 3.7.5 BASES ACTIONS (continued) dictates that both Completion Times apply simultaneously, and the more restrictive must be met.
Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling. Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition 8. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.
With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA occurring during this time period.
The second Completion Time for Required Action 8 .1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.
The 1O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours and 1O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.
C. 1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the analysis requiring flow from two AFW .
Cook Nuclear Plant Unit 2                    B 3.7.5-6                             Revision No. O

AFW System B 3.7.5 BASES ACTIONS (continued)
The 24 hour Completion Time 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.
D.1 and D.2 When Required Action A.1 , GF B.1 , C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within 18 hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is requ ired in accordance with the Note that modifies the LCO. Although not req uired ,
the unit may continue to cool down and initiate RHR.
If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.
Required Action Gf.1 is modified by a Note indicating that all required MODE changes er 130*.ver reel1:1eti0As are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.
In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation . This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.
Cook Nuclear Plant Unit 2                  B 3.7.5-7                              Revision No. 0}}