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{{#Wiki_filter:zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPIPM R One Cook PlaceBridgman, Ml 49106A unit ofAmerican Electric Power IndianaMichiganPower.comDecember 17, 2014 AEP-NRC-2014-7010 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==SUBJECT:==
Donald C. Cook Nuclear Plant Unit 1 and Unit 2Docket Nos. 50-315 and 50-316License Amendment Request Regarding Technical Specification Section 3.8.1, "ACSources -Operating," Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15
 
==Dear Sir or Madam:==
Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook NuclearPlant Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to FacilityOperating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify the notesto TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of the onsite standbyemergency diesel generators (DG) during modes in which it is currently prohibited. Specifically,I&M proposes removing the mode restrictions for the following Surveillance Requirements: 3.8.1.10(DG single largest load rejection test), 3.8.1.11 (DG full load rejection test), and 3.8.1.15 (DGendurance run).I&M has evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded thatthey involve no significant hazards consideration.Enclosure 1 to this letter provides an affirmation statement pertaining to the information containedherein. Enclosure 2 provides I&M's evaluation of the proposed TS change. Enclosures 3 and 4provide Unit 1 and Unit 2 TS pages marked to show the proposed changes. Enclosures 5 and 6provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. Bases markupsare included for information only. New clean Unit 1 and Unit 2 TS pages with proposed changesincorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing ProjectManager when requested.I&M requests approval of the proposed change in accordance with the NRC's normal review andapproval schedule. The proposed change will be implemented within 90 days of NRC approval.Copies of this letter and its enclosures are being transmitted to the Michigan Public ServiceCommission and Michigan Department of Environmental Quality, in accordance with therequirements of 10 CFR 50.91.AooI U. S. Nuclear Regulatory CommissionPage 2AEP-NRC-2014-70There are no new regulatory commitments made in this letter. Should you have any questions,please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Q. Shane LiesEngineering Vice PresidentJMT/amp
 
==Enclosures:==
1.2.AffirmationProposed License Amendment Request Regarding Revision to Technical Specifications3.8.1, "AC Sources -Operating"3. Donald C. Cook Nuclear Plant UnitProposed Changes4. Donald C. Cook Nuclear Plant UnitProposed Changes.5. Donald C. Cook Nuclear Plant UnitShow Proposed Changes.6. Donald C. Cook Nuclear Plant UnitShow Proposed Changes1 Technical Specification Pages Marked To Show2 Technical Specification Pages Marked To Show1 Technical Specification Bases Pages Marked To2 Technical Specification Bases Pages Marked Toc: M. L. Chawla, NRC Washington, D.C.J. T. King -MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC Region IIIA. J. Williamson, AEP Ft. Wayne, w/o enclosures Enclosure I to AEP-NRC-2014-70AFFIRMATIONI, Q. Shane Lies, being duly sworn, state that I am Engineering Vice President of IndianaMichigan Power (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan PowerQ. Shane LiesEngineering Vice PresidentSWORN TO AND SUBSCRIBED BEFORE METHIS \A-.' DAY OF , 2014My CNotareysblicMy Commission Expires c)'-\)- -DANIELLE BURGOYN6Notary Public, State of MichiganCounty of BerrienMy Commission Expires 04--04-2018Acting In the County of 4  to AEP-NRC-2014-70Proposed License Amendment Request RegardingRevision to Technical Specifications 3.8.1, "AC Sources -Operating"1.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. CookNuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A TechnicalSpecifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revisethe licenses to modify TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of theonsite standby emergency diesel generators (EDG) during modes in which it is currentlyprohibited. Specifically, I&M proposes removing the Note that imposes the mode restrictions forthe following Surveillance Requirements (SR): 3.8.1.10 (diesel generator (DG) single largestload rejection surveillance test), 3.8.1.11 (DG full load rejection surveillance test), and 3.8.1.15(DG endurance surveillance test run).2.0 DETAILED DESCRIPTION2.1 Proposed ChangeI&M proposes the following changes in order to eliminate the Mode 1 and 2 Surveillance testingrestrictions for SRs 3.8.1.10, 3.8.1.11, and 3.8.1.15, as discussed above. The changes wouldbe effected by deleting the applicable Note for each surveillance, as follows:2.1.1 Proposed Change to TS SR 3.8.1.10 (DG single largest load reiection surveillancetest)Note 1 in SR 3.8.1.10 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.10 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.2 Proposed Change to TS SR 3.8.1.11 (DG full load reiection surveillance test)Note 1 in SR 3.8.1.11 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed. to AEP-NRC-2014-70Page 2Additionally, compensatory measures for SR 3.8.1.11 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.3 Proposed Change to TS SR 3.8.1.15 (DG endurance surveillance test run)Note 2 in SR 3.8.1.15 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.15 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.The above changes, if approved, will allow the testing required by these SRs to be performedduring all modes of operation such that the testing will no longer be required to be performedonly during plant outages. This will help to reduce the complexity of coordinating work andtesting activities during refueling outages and allow these activities to be performed online. Thechange will also reduce risk during a refueling outage where the plant is relying on a single trainfor core cooling. This also allows for shorter refueling outage durations which reduces theduration the plant is in an elevated risk condition.The marked-up and revised Unit 1 and Unit 2 TS pages reflecting the above changes areprovided in Enclosures 3 and 4 of this letter, respectively. In addition, the associated Unit 1 andUnit 2 TS Bases will be revised to reflect the changes to these TSs. A marked-up copy of theproposed Unit 1 and Unit 2 TS Bases changes is provided in Enclosures 5 and 6 of this letter,respectively, for information only. The TS Bases changes will be implemented in accordancewith TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of theimplementation of this amendment after NRC approval.3.0 BackgroundDescription of Emergency Power SystemAs stated in Updated Final Safety Analysis Report (UFSAR) Section 8.4, "Emergency PowerSystem," the emergency power sources for the two units, including the DGs, are similar and areelectrically and physically isolated from one another. Each unit has two full capacity DGs eachsupplying power to two safety-related 4160 volt (v) buses. Loss of voltage to the 4160v buses issensed by loss of voltage relays. Upon sensing, master relays automatically start the DGs, tripthe normal feed circuit breakers for the 4160v buses, and trip all motor feeder breakers and480v bus transformer feeder breakers on the buses, the 600v bus tie breaker, non-essential600v feeder breakers, and 480v bus breakers. The DG bus input circuit breakers which connect  to AEP-NRC-2014-70Page 3the DG output to the 4160/600v bus system are automatically closed when voltage and speedapproach rated values. The DGs supply power to the 600v buses through the 4160v buses andtransformers, respectively.Each DG comes up to speed and is capable of accepting load within 10 seconds. If either DGfails to start, the remaining one is capable of supplying the required engineered safeguard load.A Safety Injection (SI) signal will also start the DGs. To avoid overloading of the DGs, all loadsare shed when the SI occurs and the safety-related 4160v buses are energized from the DGs.The safety loads are subsequently loaded in a sequential manner as required.The DGs are sized at 3500 kilowatts (KW) each to assure available power to operate one trainof safety equipment assuming a loss-of-offsite-power (LOOP) concurrent with a loss-of-coolantaccident with or without containment spray.UFSAR Section 8.1.2, "Functional Criteria," provides functional requirements employed onelectrical systems to achieve maximum reliability and operating efficiency. One of the criteria isthat motor loading does not exceed its nameplate rating.Each diesel engine is a Worthington Type SWB-12, 12 cylinder, heavy duty turbocharged dieselengine, with a continuous rated output of 4900 brake horsepower at 514 revolutions per minute(RPM).Each generator is a General Electric (GE), 4375 kilo volt amps (a), 3500KW at 0.8 power factor,514 RPM, 3-phase, 60-cycle, 4160v, 25 percent (%) voltage regulation, direct engine-drivensynchronous type generator. Each generator is equipped with a GE brushless exciter type 5ARwith a field rated 5.8a and 100v direct current (DC) and, a static voltage regulator with itsassociated potential and sensing transformers.The alternating current (AC) sources are designed to permit inspection and testing of allimportant areas and features, especially those that have a standby function, in accordance withPlant Specific Design Criterion (PSDC) 39. Periodic component tests are supplemented byextensive functional tests during refueling outages (under simulated accident conditions). TheSRs for demonstrating the OPERABILITY of the DGs are in accordance with therecommendations of U. S. Nuclear Regulatory Commission (NRC) Regulatory Guide 1.9,"Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants", andInstitute of Electrical and Electronics Engineers (IEEE) Standard 387-1995 IEEE StandardCriteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear PowerGenerating Stations. to AEP-NRC-2014-70Page
 
==44.0 TECHNICAL EVALUATION==
4.1 Changes to SR 3.8.1.10 (DG single largest load rejection surveillance test)4.1.1 Deletion of mode restriction note from SR 3.8.1.10 DG single largest load rejectiontest.The current approach for performance of the load rejection test in SR 3.8.1.10 has been toparallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG tothe required load, and then open the DG output breaker. Opening of the DG output breakerseparates the DG from its associated safety-related 4160v bus and allows the offsite circuit tocontinue to supply that bus.The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. During testing the diesel being tested isinoperable, but available. This license amendment request (LAR) is proposing that this testingalso be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.The concerns associated with performing the single largest load rejection surveillance test inMode 1 or 2 are that the DG being tested is susceptible to damage caused by grid disturbances,disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated loadmight cause electrical system perturbations, and the DG in test mode is more susceptible totripping due to the extra protective trip relays that are in effect during test mode operations.4.1.1.1 Grid DisturbancesThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2,while connected to offsite power or generator output, is that the DG is. susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based-on the fact that the remaining DG would remainoperable and is capable of mitigating a Design Based Accident (DBA). The redundant train ofonsite AC power is fully capable of mitigating a DBA or providing for safe shutdown of theassociated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As a common practice at CNP, risk management considerations ensure that this and other SRsare not scheduled during periods where there is increased potential for grid or bus disturbance  to AEP-NRC-2014-70Page 5(storms, grid emergencies, etc.). Performance of the single largest load rejection surveillancetest per SR 3.8.1.10, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently testsits DGs paralleled to offsite power or generator output during required monthly surveillancetesting, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.4.1.1.2 Electrical PerturbationsThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2 isthat suddenly disconnecting a DG from the associated bus on a single largest load rejectionsurveillance test could cause a voltage fluctuation on that bus which could potentially perturbthe onsite AC electrical system. However, industry experience shows that there is no significantelectrical distribution system effect on the associated bus during a single largest load rejectionsurveillance test. Furthermore, at CNP when the single largest load rejection surveillance test isperformed at shutdown, the voltage recovery is within 2 seconds. During this testing there wereno recorded voltage oscillations and the voltage change was a smooth step change, whichwould have no adverse impact on equipment performance. Therefore, performing load rejecttests in accordance with SR 3.8.1.10 in any modes would not cause a significant perturbationthat would adversely affect the onsite AC electrical system.4.1.1.3 Protective Trip RelaysDuring single largest load rejection surveillance testing of DGs while in test mode,non-emergency trip features are in effect to protect the DG from equipment damage due toequipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demandoccurs with these non-emergency trips in effect, the affected DG will automatically revert to theemergency mode and bypass these trips. No operator action is required. Upon detection ofunder voltage on the safety-related 4160v bus, load shedding for all vital loads andnon-permanently connected loads from the 4160v bus would occur followed by re-sequencing ofthe vital loads back onto the affected 4160v bus. The operators receive indication and alarms inthe control room that the preferred power source is lost. In addition, the proposed change doesnot impact voltage regulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the single largest load rejection surveillance test issimilar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DGmonthly surveillance test run), which is performed while in Mode 1.4.2 Changes to SR 3.8.1.11 (DG full load rejection surveillance test)4.2.1 Deletion of mode restriction note from SR 3.8.1.11The current approach for performance of the full load rejection surveillance test in SR 3.8.1.11has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raisethe DG to the required 100% load, and then open the DG output breaker. Opening of the DGoutput breaker separates the DG from its associated safety-related 4160v bus and allows theoffsite circuit to continue to supply that bus. to AEP-NRC-2014-70Page 6The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. Therefore, the current testing processdoes not require the DG and 4160v bus being tested to remain operable. This change requestis proposing that testing also be allowed in Mode 1 or 2, when both DGs are required to beoperable per TS 3.8.1.There are three concerns associated with performing the full load rejection surveillance test inMode 1 or 2. The first concern is that the DG being tested is more susceptible to damagecaused by grid disturbances. Secondly, disconnecting the DG while paralleled to thesafety-related 4160v buses at 100% rated load could cause electrical system perturbations.Finally, the DG in test mode is more susceptible to tripping due to the extra protective trip relaysthat are in effect during test mode operations.4.2.1.1 Grid DisturbancesThe concern of performing the full load rejection surveillance test in Mode 1 or 2, whileconnected to offsite power or generator output, is that the DG is susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based on the fact that the remaining DG would remainoperable and is capable of mitigating a DBA. The onsite AC power system is fully capable ofmitigating a DBA or providing for safe shutdown of the associated unit with the remaining DGoperable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the full load rejectionsurveillance test per SR 3.8.1.11, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with noadverse effect.4.2.1.2 Electrical PerturbationsThe concern during this testing is that suddenly disconnecting a DG from the associated bus ona full load rejection surveillance test could cause a voltage fluctuation on that bus that couldpotentially perturb the onsite AC electrical system. However, industry experience shows that  to AEP-NRC-2014-70Page 7there is no significant electrical distribution system effect on the associated bus during a full loadrejection surveillance test. Therefore, performing full load rejection surveillance tests inaccordance with SR 3.8.1.11 in any modes would not cause a significant perturbation that wouldadversely affect the onsite AC electrical system.4.2.1.3 Protective Trip RelaysDuring full load rejection surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. In addition, the proposed change does not impact voltageregulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the full load rejection surveillance test is similar to theelectrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed during Mode 1.4.3 Changes to SR 3.8.1.15 (DG endurance surveillance test run)4.3.1 Deletion of mode restriction note from SR 3.8.1.15The concerns of performing the DG endurance surveillance test run (8-hour load run) requiredby SR 3.8.1.15 in Mode 1 or 2 are the DG being tested is susceptible to grid disturbances andthe additional protective trip features would be in place making the DG more vulnerable to apossible trip while being parallel with the offsite power or generator output source.4.3.1.1 Grid DisturbancesThe concern with performing the endurance run in Mode 1 or 2, while connected to offsite poweror generator output, is that the DG is susceptible to grid disturbances. Only one DG per unit isparalleled to offsite power or generator output at any one time and any grid disturbances wouldonly possibly affect one DG. Therefore, the justification for this proposed change is based onthe fact that the redundant train DG would remain operable and is capable of mitigating a DBA.The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdownof the associated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action. to AEP-NRC-2014-70Page 8As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the endurance runsurveillance test per SR 3.8.1.15, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while in Mode 1 or 2.4.3.1.2 Trip RelaysDuring endurance run surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. Therefore, these additional trip functions are not a significantconcern during performance of the DG endurance surveillance test runs while in Mode 1 or 2.In addition, the remaining DG will be available to respond and mitigate a DBA or provide safeshutdown capability.Finally, the proposed test configuration for the DG endurance surveillance test run is similar tothe electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed while in Mode 1.4.4 Risk assessment for performing DG single largest load rejection surveillance test(SR 3.8.1.10), DG full load reiection surveillance test (SR 3.8.1.11). and DGendurance surveillance test run (3.8.1.15) in Mode I or 2.Currently, when the DG single largest load rejection surveillance test, the DG full load rejectionsurveillance test, and the DG endurance surveillance test run are performed they may beperformed in Mode 5 or 6. When a DG is undergoing any of these three tests it is consideredinoperable but available to respond to design based accidents.Performing these tests in Mode 1 or 2 does not change the potential level of risk during thesetests. As in Modes 5 and 6, the DG is available and capable of performing its safety functions.The determination of availability of the DG in test is consistent with the definition of unavailablein NUMARC 93-01, Revision 4A, Appendix B, which states: "SSCs out of service for testing areconsidered unavailable, unless the test configuration is automatically- overridden by a validstarting signal, or the function can be promptly restored either by an operator in the control roomor by a dedicated operator stationed locally for that purpose. Restoration actions must becontained in a written procedure, must be uncomplicated (a single action or a few simpleactions), and must not require diagnosis or repair...." Per the above discussion, for these teststhe DG in test will remain available per these guidelines. As a result, there is no increase inunavailability of the DG and there is a minimal increase in the risk. to AEP-NRC-2014-70Page 9Also, a review was conducted of DG starts at CNP for the last 10 years (DG starts sinceJanuary 1, 2004) as well as a search of the CNP Corrective Action Program for that same timeperiod. This search included all four DGs (two DGs in Unit 1 and two DGs in Unit 2) and noresults were found of an instance where any starts have caused additional problems to the DGsthemselves, other CNP equipment, or the electrical grid any different regardless of the mode inwhich the DG was actually started.
 
==5.0 REGULATORY EVALUATION==
5.1 Applicable Regulatory Reguirements/CriteriaRegulatory RequirementsUFSAR Section 1.4, "Plant Specific Design Criteria (PSDC)", defines the principal criteria andsafety objectives for the CNP design. The following PSDC is relevant to the proposedamendment:"CRITERION 39 Emergency PowerAn emergency power source shall be provided and designed with adequateindependency, redundancy, capacity, and testability to permit the functioning of the ESFand protection systems required to avoid undue risk to the health and safety of thepublic. This power source shall provide this capacity assuming a failure of a single activecomponent."The design of the AC electrical power system provides independence and redundancy toensure an available source of power to the ESF systems. The onsite Class 1 E AC distributionsystem for I&M is divided into two load groups. A safety-related 4160v bus is associated witheach load group. The two load groups are 100% redundant and are electrically and physicallyseparated such that the loss of either group does not prevent the minimum safety functions frombeing performed. Each load group has connections to either of two offsite power sources fromthe switchyard, and a single DG. Offsite power is supplied to the switchyard from thetransmission network via two rights of way approaching the site from two different directions.The proposed changes modify plant condition requirements for the test of the DGs whichprovide emergency power to the safety-related 4160v buses in the event of a LOOP. The testrequirements are intended to verify and/or ensure continued OPERABILITY of the DGs. Theproposed changes involve no changes to the required tests themselves except to allow certaintests to be performed during modes for which performance of the affected tests is currentlyprohibited. Evaluation of the proposed changes has determined that DG availability is notsignificantly affected by the proposed changes, that the potential for significantly adverseelectrical perturbations during tests such as SR 3.8.1.11 (Full-Load Rejection Test) isacceptably low, and that the potential for a grid disturbance causing DG unavailability while aDG is in test is quite low. Further, only one DG will be tested at a time such that OPERABILITYof the redundant train DG and its associated bus and bus loads will be unaffected. Testing willthus continue in a manner that supports redundant train DG OPERABILITY so that both DGs  to AEP-NRC-2014-70Page 10will be available to perform their intended safety function consistent with regulatoryrequirements.In conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public.5.2 No Significant Hazards Consideration DeterminationPursuant to 10 CFR 50.90, I&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend theAppendix A TS to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes amendingSR 3.8.1, "AC Sources". I&M has evaluated whether a significant hazards consideration isinvolved with the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of amendment," as discussed below:1. Does the proposed change involve a significant increase in the probability of occurrence orconsequences of an accident previously evaluated?Response: NoThe design of plant equipment is not being modified by the proposed changes. In addition,the DGs and their associated emergency loads are accident mitigating features. As such,testing of the DGs themselves is not associated with any potential accident-initiatingmechanism. Therefore, there will be no significant impact on any accident probabilities bythe approval of the requested changes.The changes include an increase in the time that a DG under test will be paralleled to thegrid while the unit is in Modes 1 or 2. As such, the ability of the tested DG to respond to aDBA could be minimally adversely impacted by the proposed changes. However, theimpacts are not considered significant based, in part, on the ability of the remaining DG tomitigate a DBA or provide safe shutdown. Experience shows that testing for these SRstypically does not perturb the electrical distribution system. In addition, operatingexperience supports the conclusion that the proposed changes do not involve any significantincreases in the likelihood of a safety-related bus blackout or damage to plant loads.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accident fromany accident previously evaluated?Response: NoThe capability to synchronize a DG to the offsite source (via the associated plant bus) andtest the DG in such a configuration is a design feature of the DGs, including the test modeoverride in response to a safety injection signal. Paralleling the DG for longer periods of  to AEP-NRC-2014-70Page 11time during plant operation may slightly increase the probability of incurring an adverseeffect from the offsite source, but this increase in probability is judged to be still quite smalland such a possibility is not a new or previously unrecognized consideration.The proposed change does not introduce a new mode of plant operation and does notinvolve physical modification to the plant. The change does not introduce new accidentinitiators or impact assumptions made in the safety analysis.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: NoThe proposed changes do not exceed or alter a design basis or safety limit, so there is nosignificant reduction in the margin of safety. The margin of safety is related to theconfidence in the ability of the fission product barriers to perform their design functionsduring and following an accident situation. These barriers include the fuel cladding, thereactor coolant system, and the containment system. The proposed changes do not directlyaffect these barriers, nor do they involve any significantly adverse impact on the DGs whichserve to support these barriers in the event of an accident concurrent with a LOOP. Theproposed changes to the testing requirements for the plant DGs do not affect theOPERABILITY requirements for the DGs, as verification of such OPERABILITY will continueto be performed as required (except during different allowed modes). The changes have aninsignificant impact on DG availability, as the DGs remain available to perform their requiredfunction of providing emergency power to plant equipment that supports or constitutes thefission product barriers. Only one DG is to be tested at a time, so that the remaining DG willbe available to safety shut down the plant if required. Consequently, performance of thefission product barriers will not be impacted by implementation of the proposed amendment.In addition, the proposed changes involve no changes to setpoints or limits established orassumed by the accident analysis.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, I&M concludes that the proposed amendment presents no significanthazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.5.3 ConclusionIn conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public. to AEP-NRC-2014-70Page 1
 
==26.0 ENVIRONMENTAL CONSIDERATION==
A review has determined that the proposed amendment would change a requirement withrespect to installation or use of a facility component located within the restricted area, as definedin 10 CFR 20, or would change an inspection or surveillance requirement. However, theproposed amendment does not involve: (i) a significant hazards consideration, (ii) a significantchange in the types or significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion setforth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with the proposedamendment.7.0 PRECEDENCE1. Amendment 173 to Columbia Generating Station Operating License (
 
==Subject:==
ColumbiaGenerating Station Operating License NPF-21 Request for Technical SpecificationsAmendment to Remove Operating Mode Restrictions for Emergency Diesel GeneratorSurveillance Testing, dated May 18, 2001.)2. Amendment 154 to Wolf Creek Generating Station Operating License (
 
==Subject:==
Wolf CreekGenerating Station -Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4-AC and DC Sources, dated July 12, 2004.)3. Amendment 167 to Palo Verde Generating Station Operating License (
 
==Subject:==
Palo VerdeNuclear Generating Station, Units 1, 2, and 3- Issuance of Amendments RE: AC Sources -Operating Surveillance Requirements, dated May 16, 2007.
 
==8.0 REFERENCES==
: 1. 10 CFR 50.90, "Application for amendment of license, or construction permit, or early sitepermit"2. 10 CFR 50.36, "Technical Specifications"3. Indiana and Michigan Power D. C. Cook Nuclear Plant Updated Final Safety AnalysisReport, Revision 25  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.10---------------NOTES ---------------1 Thist Su~eiir aR~i~c shall not nermaivh beanr~r~u~ -I ~.. '~ LI......wvp~;IL;;f !R Mn 60FL ASureilanc ma beperformned to reestablishOPERA.BILITY provided an assessmentA-+-rmi.-p fhe- pfh rf +k- .,nw+ 0&#xfd; m..r-nt'nnippdk~2, +a 4Ln fnrflfv4. 4. L&#xfd; 4-: Ir 4&L-; 0 MHH" RAAA RVAP :R 195.- If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 13.8.1-9Amendment No. 287, 294, 309 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.11--------------NOTES ---------------1. This Surveillance shall not normally beperfoermed in MODE 1 Or 2. However, thisSurveillanGe may be performed to reestablishOPERA\BILITY provided an assessmentdetermines the safety of the unit is maint-ainedor enhanced. Credit may be taken for-i Jl munpiaRneci events that satisry this Si.fI2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-10Amendment No. 27-7, 294, 295 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15------------- NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.I II I II I, ~ ~~~~~ I ue'mglfmI&#xfd;,. 'I n^ nflrn''I n fin I~CW~ ,.. ~ ~ +hiy2Suveilla;nrLe may be nerfOrmed to reestab-lishA I'IP\Ideterl Lmine t fGety of teniimntnine41". .'J .no t1, iai t n i .e v nts that LIthus nR.unclanned e'-ents that satisf'- this SR.If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours at a load> 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-13Amendment No. 287, 291  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.10-------------- NOTES ---------------1 Thic. , cmaI.n~ h',il nr+ nr~n, =11y hoIIf nrnAt ;r RAfll ME ar 1) W-nna#k;hicc.OPERABI LITY provided an assessmentor enhanced. Credit may be taken-forunplanned events that satisfy this SRmE2. If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 23.8.1-9Amendment No. 269, 27-3, 291 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.11-----------------NOTES ---------------I. This Su'p-eillance shall not normally beperformed in MODE 1 or 2. However, thisSurveillance may be performed to reestablishOPERABI LITY provided an assessmentdetemnines the safety of the unit is maintainedor enhan-ed. Cred-it ma" be taken Gfounplanned events that satisfy this SR.IE2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-10Amendment No. 2-6-, 2-7-3, 276 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15--------------- -NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.perfo)rmed inMODE 1 Or 2. However, this-Survillncemay be performed to reestablishOPEIR-ABILITY provided an assessmentdetermnines the safety of the un~it is maintained^r anOr~AfraA.+t M-, him +nLkat3 (p)e4m +.'na +~a~ 4k +~ e#+ M f&#xfd; +hk e Q DIurip Or1riv vvvri CY Ct VC1 0 0E3-. If performed with DG synchronized with offsitepower, it shall be performed at a power factor5 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours at a load> 3150 kW and <3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-13Amendment No. 2-69, 273  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)
AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)b. Tripping its associated single largest post-accident load with the DGsolely supplying the bus.Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test isacceptable if the increase in diesel speed does not exceed 75% of thedifference between synchronous speed and the overspeed trip setpoint,or 15% above nominal speed, whichever is lower. This corresponds to64.4 Hz, which is the nominal speed plus 75% of the difference betweennominal speed and the overspeed trip setpoint.The time, voltage, and frequency tolerances specified in this SR arederived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.1O.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.This SR is modified by two Notes. The reason for Note 1 is that duringoperation with the reactor critical, performnance of this SR could causeperturbations to the electrical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems.This f rm Rormally performing the Surveillance in MODE 1 or 2is fu'e amplified to allow the Surveillance to be performned for thepurpose Of reestablishing OPERABILITY (e.g., post work testing fooIwInIgcorrective mnaintenance, correctiVe modification, deficient Or incompletesur-ve*ilance testing, and other un;anipae 0-PEABILITY concerns)provided an assessm.en unit saft is maintained G.enhanced. This assessm~ent shall, as a minimum, consider the potentialoutcom~es and transients associated with a failed Surveillance_,asuccessful SuIveillance, and a perturbation of the offsite Or onsite systemwhen they are tied together or operated idpnetyfor theas well as the peratoFr prroedures available to cope Withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to det6rMinP that uIt IRsafety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Cook Nuclear Plant Unit 1 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Credit may be taken foar unplanned events that satisfy this SR. Creditmnay be taken for unplanned events that satisfy this SR.Note 2-]N ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of S 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note 2N allows the Surveillance to be conducted ata power factor other than < 0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfactor to < 0.86 results in voltages on the emergency busses that are toohigh. Under these conditions, the power factor should be maintained asclose as practicable to 0.86 while still maintaining acceptable voltagelimits on the emergency busses. In other circumstances, the grid voltagemay be such that the DG excitation levels needed to obtain a powerfactor of 0.86 may not cause unacceptable voltages on the emergencybusses, but the excitation levels are in excess of those recommended forthe DG. In such cases, the power factor shall be maintained as close aspracticable to 0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forCook Nuclear Plant Unit 1 B 3.8.1-22 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1future application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has been modified by two Notes. The reason Note 1 is thatduring operation with the reactor critical, performance of this SR couldCook Nuclear Plant Unit I B 3.8.1-23 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)challenge continued steady ,tate operation and, as a result, unit safetsystems. This restriction from normally performing the Sur'veillance iv,,-,,-Ifor the pur.poe Of PER.BI LITY (e.g., post work testingfollowing corrective maintenance, corrective mmdification, deficient o ninGomplete surhvn IeillaesiRg, and othe runRantficipated OPERABILITYconcerns) provided an assessment determines unit safety is maintainedor enrhaned. This assessmenrt shall, as a minimumo, conider thepotertial outonmes and transierts assciated with a failed Surveillance, asuccessful Suveillance, and a perturbeation of the offsite or onsite systemowhen they are tied together oe operated independertly for theSuhveillaNce; as well as the operator procedures available to cope withthese outconmes. These shall be measured against the avoided risk of aunit shutdown and startup to determnine that unit safety is mnaintained orenhanced when the Surveillance is perftorned in MODE 1 or 2. RiskinRsights OrFeemnsi methods mnay be used for this assessment.redit may bee taken forg unplanned events that satisfy this SR. Note 2Fihensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of 5 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note ORj allows the Surveillance to be conducted at a powerfactor other than 5 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to<ay0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.Cook Nuclear Plant Unit 1 B 3.8.1-24 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-24Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)restriction from normally performing the Surveillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purposeof reestablishing OPERABILITY (e.g., post work testing followingcorrective maintenance, corrective modification, deficient or incompletesurveillance testing, and other unanticipated OPERABILITY concerns)provided an assessment determines unit safety is maintained orenhanced. This assessment shall, as a minimum, consider the potentialoutcomes and transients associated with a failed Surveillance, asuccessful Surveillance, and a perturbation of the offsite or onsite systemwhen they are tied together or operated independently for theSurveillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours. The run duration of 8 hours is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by Frh Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate thistest. Similarly, momentary power factor transients above the power factorlimit will not invalidate the test. The reason for Note 2 is that duringoperation with the reactor critical, perfrmance of this Sue..illance could.,cause perturbations to the electrical distribution systems that couldchallenge conAtinlued steady 6tate operation and, as a result, unit safetysystemns. This restriction fromn noarmally performing the Surveillancc inCook Nuclear Plant Unit 1B 3.8.1-29Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)hA DF= I Cjr ') ffig fiir+kpr p lofipt4 +^ pllpjAg thp S;i impmIlpriga +a him niarfnpmadII ,,,,.,.." .... ........l r hfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing corrective mnaintenance, corrective modification, deficient orincomplete sun eillanTe testing, and other unaRticipated OPERABILITYconcerns) provided an assessment determines unit safety is maiintainA.edaor enhanced. This assessment shall, as a mnimumn, consider thepotential outcomes and transients associated with failed SRmveillane, -asuccesfulSurveillance, and a perturbaptine of the offfsite or onsite systemwhen they are tied together or operated idpnetyfor theSurveillance; as well as the operator procedures available to cope withthese outcomnes. These shall be mneasured against the -avofided risk of aunit shutdown and startup to determnine that unit safety is mnaintained OFenhanced when the Surveillance is performned in MODE 1 or 2. Riska R~ioht5 or dteF in~tir- Mothnir;Fnay be h used for thus assesmentCredit may be taken for unplanned that satisfy this SR.. Note.. 12ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note P21233 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.16Cook Nuclear Plant Unit 1 B 3.8.1-30 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-30Revision No. 41  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)
AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)derived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.10.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.Thir SR is modified by two .ntes. The reason for Note 1 is that duringoperation with the reac.to critical, peFor.mance of this SR could causeperturbations to the e ical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems. This,restriction from normally perfo~rming the Survefillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purpose-of reestablishing OPERA~BILITY (e'g., post work testing followingcorrective main~tenance, corri-rectivemoifiaton deficient Or incompletesurveillance testfing, and Other u-nanticipated OPERABILITY concerns)enhanced. This assessment shall, astadminimum, consider the potentialoutcomes and transients associated ith a fpaile.d SuWh eilnchronzed, a-successful Supreillanre, anda perti ation of the onduite onsite systemwhen they aro tied together or operated inenddetntl for theSurveillance; as well as the operator procedures avalilableA to- cope withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to determ~ine that unit safety is mnaintained orenhadned wher the Surveillance is performed in MODE 1 or 2. Riski nsights or determfinistic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Creditma" be taken for unplanned eventS that satisfy this SR.Note F1j2 ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of 5 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note rlj!2 allows the Surveillance to be conducted ata power factor other than -0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfertfnr < n RR raci nlfQ in \,nlri n nn thp Pmmsrnr-nr% hi nQ=P thnt nrm fnnCook Nuclear Plant Unit 2 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 2B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forfuture application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has, been Modified by two Notes. The resn for Note 1 is thatduring operation with the reactor critical, performance of this SR couldcause perturbation to the electrical distribu1tion systems6 that colGhallenqe continued- steady state opeation and, as a result, unit safetyCook Nuclear Plant Unit 2B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1systems. T-his restriction fromn normally pedorm~ing the Surveillance inMODE 1 Or 2 is fudther amplified to allow the Surveillance to be perfrmedfor the purpose of reestablishing OPERABILITY (e.g., post work testiRgfollowing corrective mnaintenance, co~rrective moedification, deficient orincGomplete surveillance testing, and other unanticipated OPERABILITYconcerns) provided an assessment d~eterm~ines unit safety is Maintainedo-r enhanc~ed. This assess6ment shall, as a minimum, consider thepotential ou1tcomes and transients associated with a failed Surveillance, asuccessfiul and a pedIurbationof the offsite or onsito systemvR ter irey aIr Lieu tn!eTrlIC at U-JCILC irnuependuenrtly i9 te-Cook Nuclear Plant Unit 2B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Survleillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown andstartup to deter;ine that unit safety is maintained erenhan-edd When the Suirveillance is performned On MODE 1 or 2. Riskins~ights or determn~iistic methods m;ay be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Note F120ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note N allows the Surveillance to be conducted at a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to< 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86 maynot cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8*1.12Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.4, thisSurveillance demonstrates the as designed operation of the standbypower sources during loss of the offsite source. This test verifies allactions encountered from the loss of offsite power, including shedding ofthe nonessential loads and energization of the emergency buses andrespective loads from the DG. It further demonstrates the capability ofthe DG to automatically achieve the required voltag'e and frequency withinthe specified time.The DG autostart time of 10 seconds is derived from requirements of theenI aaly58 W rOesp1 Mo a *laeSgll I2 1asi 1a-I e I reaK t, U ,. I MeCook Nuclear Plant Unit 2 B 3.8.1-24 Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)as well as the operator procedures available to cope with these outcomes.These shall be measured against the avoided risk of a unit shutdown andstartup to determine that unit safety is maintained or enhanced when theSurveillance is performed in MODE 1 or 2. Risk insights or deterministicmethods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours. The run duration of 8 hours is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by e Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate this test.Similarly, momentary power factor transients above the power factor limitwill not invalidate the test. The reason for Note 2 is that during operationwith the reactor critical, performance of this Surveillance couild causeperturbationS to the electrical distribution systems that ceuld challengecontinued steady state operation and, as a result, unit safety systems.This restriction from normally performing the Surveillance inMODE 1 or 2 is further amplified to alloW the Su1,rveillaRne to be performedfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing correctiVe maintenance, corrective modification, deficient orincomplete surveillancGe testing, and other unanticipated OPERABI LITYconcerns) provided an assessment determines unit safety is maintainedor enhanced. This assessment shall a a miniMum, consider thepotential ouGtmres ad ets s;oqcSated with a failed SureillaRe, aSuccessful Su.veillance, and a perturbation of the offs.te Or olsite systemwhen they are tied together Or operated independently for the-Sureilane;as well as the operator procedures available to cope withCook Nuclear Plant Unit 2B 3.8.1-27Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)these outcomes. These shall be measured against the aoddrisk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when. the Sur....eil.an.e is performed in MODE 1 or 2. Risk4nsgnis or eRIne!noaS may Be used TOF Mis asses .Credit may be taken for unplanned events that satisfy this SR-. Note M3ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note M3 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.16This Surveillance demonstrates that the diesel engine can restart from ahot condition, such as subsequent to shutdown from normalSurveillances, and achieve the required voltage and frequency within10 seconds. The 10 second time is derived from the requirements of theaccident analysis to respond to a design basis large break LOCA. The24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR is modified by two Notes. Note 1 ensures that the test isperformed with the diesel sufficiently hot. The load ban isprvded toCook Nuclear Plant Unit 2 B 3.8.1-28 Re Nvision No. 41 zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPIPM R One Cook PlaceBridgman, Ml 49106A unit ofAmerican Electric Power IndianaMichiganPower.comDecember 17, 2014 AEP-NRC-2014-7010 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
 
==SUBJECT:==
Donald C. Cook Nuclear Plant Unit 1 and Unit 2Docket Nos. 50-315 and 50-316License Amendment Request Regarding Technical Specification Section 3.8.1, "ACSources -Operating," Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15
 
==Dear Sir or Madam:==
Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook NuclearPlant Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to FacilityOperating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify the notesto TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of the onsite standbyemergency diesel generators (DG) during modes in which it is currently prohibited. Specifically,I&M proposes removing the mode restrictions for the following Surveillance Requirements: 3.8.1.10(DG single largest load rejection test), 3.8.1.11 (DG full load rejection test), and 3.8.1.15 (DGendurance run).I&M has evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded thatthey involve no significant hazards consideration.Enclosure 1 to this letter provides an affirmation statement pertaining to the information containedherein. Enclosure 2 provides I&M's evaluation of the proposed TS change. Enclosures 3 and 4provide Unit 1 and Unit 2 TS pages marked to show the proposed changes. Enclosures 5 and 6provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. Bases markupsare included for information only. New clean Unit 1 and Unit 2 TS pages with proposed changesincorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing ProjectManager when requested.I&M requests approval of the proposed change in accordance with the NRC's normal review andapproval schedule. The proposed change will be implemented within 90 days of NRC approval.Copies of this letter and its enclosures are being transmitted to the Michigan Public ServiceCommission and Michigan Department of Environmental Quality, in accordance with therequirements of 10 CFR 50.91.AooI U. S. Nuclear Regulatory CommissionPage 2AEP-NRC-2014-70There are no new regulatory commitments made in this letter. Should you have any questions,please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Q. Shane LiesEngineering Vice PresidentJMT/amp
 
==Enclosures:==
1.2.AffirmationProposed License Amendment Request Regarding Revision to Technical Specifications3.8.1, "AC Sources -Operating"3. Donald C. Cook Nuclear Plant UnitProposed Changes4. Donald C. Cook Nuclear Plant UnitProposed Changes.5. Donald C. Cook Nuclear Plant UnitShow Proposed Changes.6. Donald C. Cook Nuclear Plant UnitShow Proposed Changes1 Technical Specification Pages Marked To Show2 Technical Specification Pages Marked To Show1 Technical Specification Bases Pages Marked To2 Technical Specification Bases Pages Marked Toc: M. L. Chawla, NRC Washington, D.C.J. T. King -MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC Region IIIA. J. Williamson, AEP Ft. Wayne, w/o enclosures Enclosure I to AEP-NRC-2014-70AFFIRMATIONI, Q. Shane Lies, being duly sworn, state that I am Engineering Vice President of IndianaMichigan Power (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan PowerQ. Shane LiesEngineering Vice PresidentSWORN TO AND SUBSCRIBED BEFORE METHIS \A-.' DAY OF , 2014My CNotareysblicMy Commission Expires c)'-\)- -DANIELLE BURGOYN6Notary Public, State of MichiganCounty of BerrienMy Commission Expires 04--04-2018Acting In the County of 4  to AEP-NRC-2014-70Proposed License Amendment Request RegardingRevision to Technical Specifications 3.8.1, "AC Sources -Operating"1.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. CookNuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A TechnicalSpecifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revisethe licenses to modify TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of theonsite standby emergency diesel generators (EDG) during modes in which it is currentlyprohibited. Specifically, I&M proposes removing the Note that imposes the mode restrictions forthe following Surveillance Requirements (SR): 3.8.1.10 (diesel generator (DG) single largestload rejection surveillance test), 3.8.1.11 (DG full load rejection surveillance test), and 3.8.1.15(DG endurance surveillance test run).2.0 DETAILED DESCRIPTION2.1 Proposed ChangeI&M proposes the following changes in order to eliminate the Mode 1 and 2 Surveillance testingrestrictions for SRs 3.8.1.10, 3.8.1.11, and 3.8.1.15, as discussed above. The changes wouldbe effected by deleting the applicable Note for each surveillance, as follows:2.1.1 Proposed Change to TS SR 3.8.1.10 (DG single largest load reiection surveillancetest)Note 1 in SR 3.8.1.10 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.10 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.2 Proposed Change to TS SR 3.8.1.11 (DG full load reiection surveillance test)Note 1 in SR 3.8.1.11 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed. to AEP-NRC-2014-70Page 2Additionally, compensatory measures for SR 3.8.1.11 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.3 Proposed Change to TS SR 3.8.1.15 (DG endurance surveillance test run)Note 2 in SR 3.8.1.15 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.15 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.The above changes, if approved, will allow the testing required by these SRs to be performedduring all modes of operation such that the testing will no longer be required to be performedonly during plant outages. This will help to reduce the complexity of coordinating work andtesting activities during refueling outages and allow these activities to be performed online. Thechange will also reduce risk during a refueling outage where the plant is relying on a single trainfor core cooling. This also allows for shorter refueling outage durations which reduces theduration the plant is in an elevated risk condition.The marked-up and revised Unit 1 and Unit 2 TS pages reflecting the above changes areprovided in Enclosures 3 and 4 of this letter, respectively. In addition, the associated Unit 1 andUnit 2 TS Bases will be revised to reflect the changes to these TSs. A marked-up copy of theproposed Unit 1 and Unit 2 TS Bases changes is provided in Enclosures 5 and 6 of this letter,respectively, for information only. The TS Bases changes will be implemented in accordancewith TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of theimplementation of this amendment after NRC approval.3.0 BackgroundDescription of Emergency Power SystemAs stated in Updated Final Safety Analysis Report (UFSAR) Section 8.4, "Emergency PowerSystem," the emergency power sources for the two units, including the DGs, are similar and areelectrically and physically isolated from one another. Each unit has two full capacity DGs eachsupplying power to two safety-related 4160 volt (v) buses. Loss of voltage to the 4160v buses issensed by loss of voltage relays. Upon sensing, master relays automatically start the DGs, tripthe normal feed circuit breakers for the 4160v buses, and trip all motor feeder breakers and480v bus transformer feeder breakers on the buses, the 600v bus tie breaker, non-essential600v feeder breakers, and 480v bus breakers. The DG bus input circuit breakers which connect  to AEP-NRC-2014-70Page 3the DG output to the 4160/600v bus system are automatically closed when voltage and speedapproach rated values. The DGs supply power to the 600v buses through the 4160v buses andtransformers, respectively.Each DG comes up to speed and is capable of accepting load within 10 seconds. If either DGfails to start, the remaining one is capable of supplying the required engineered safeguard load.A Safety Injection (SI) signal will also start the DGs. To avoid overloading of the DGs, all loadsare shed when the SI occurs and the safety-related 4160v buses are energized from the DGs.The safety loads are subsequently loaded in a sequential manner as required.The DGs are sized at 3500 kilowatts (KW) each to assure available power to operate one trainof safety equipment assuming a loss-of-offsite-power (LOOP) concurrent with a loss-of-coolantaccident with or without containment spray.UFSAR Section 8.1.2, "Functional Criteria," provides functional requirements employed onelectrical systems to achieve maximum reliability and operating efficiency. One of the criteria isthat motor loading does not exceed its nameplate rating.Each diesel engine is a Worthington Type SWB-12, 12 cylinder, heavy duty turbocharged dieselengine, with a continuous rated output of 4900 brake horsepower at 514 revolutions per minute(RPM).Each generator is a General Electric (GE), 4375 kilo volt amps (a), 3500KW at 0.8 power factor,514 RPM, 3-phase, 60-cycle, 4160v, 25 percent (%) voltage regulation, direct engine-drivensynchronous type generator. Each generator is equipped with a GE brushless exciter type 5ARwith a field rated 5.8a and 100v direct current (DC) and, a static voltage regulator with itsassociated potential and sensing transformers.The alternating current (AC) sources are designed to permit inspection and testing of allimportant areas and features, especially those that have a standby function, in accordance withPlant Specific Design Criterion (PSDC) 39. Periodic component tests are supplemented byextensive functional tests during refueling outages (under simulated accident conditions). TheSRs for demonstrating the OPERABILITY of the DGs are in accordance with therecommendations of U. S. Nuclear Regulatory Commission (NRC) Regulatory Guide 1.9,"Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants", andInstitute of Electrical and Electronics Engineers (IEEE) Standard 387-1995 IEEE StandardCriteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear PowerGenerating Stations. to AEP-NRC-2014-70Page
 
==44.0 TECHNICAL EVALUATION==
4.1 Changes to SR 3.8.1.10 (DG single largest load rejection surveillance test)4.1.1 Deletion of mode restriction note from SR 3.8.1.10 DG single largest load rejectiontest.The current approach for performance of the load rejection test in SR 3.8.1.10 has been toparallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG tothe required load, and then open the DG output breaker. Opening of the DG output breakerseparates the DG from its associated safety-related 4160v bus and allows the offsite circuit tocontinue to supply that bus.The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. During testing the diesel being tested isinoperable, but available. This license amendment request (LAR) is proposing that this testingalso be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.The concerns associated with performing the single largest load rejection surveillance test inMode 1 or 2 are that the DG being tested is susceptible to damage caused by grid disturbances,disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated loadmight cause electrical system perturbations, and the DG in test mode is more susceptible totripping due to the extra protective trip relays that are in effect during test mode operations.4.1.1.1 Grid DisturbancesThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2,while connected to offsite power or generator output, is that the DG is. susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based-on the fact that the remaining DG would remainoperable and is capable of mitigating a Design Based Accident (DBA). The redundant train ofonsite AC power is fully capable of mitigating a DBA or providing for safe shutdown of theassociated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As a common practice at CNP, risk management considerations ensure that this and other SRsare not scheduled during periods where there is increased potential for grid or bus disturbance  to AEP-NRC-2014-70Page 5(storms, grid emergencies, etc.). Performance of the single largest load rejection surveillancetest per SR 3.8.1.10, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently testsits DGs paralleled to offsite power or generator output during required monthly surveillancetesting, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.4.1.1.2 Electrical PerturbationsThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2 isthat suddenly disconnecting a DG from the associated bus on a single largest load rejectionsurveillance test could cause a voltage fluctuation on that bus which could potentially perturbthe onsite AC electrical system. However, industry experience shows that there is no significantelectrical distribution system effect on the associated bus during a single largest load rejectionsurveillance test. Furthermore, at CNP when the single largest load rejection surveillance test isperformed at shutdown, the voltage recovery is within 2 seconds. During this testing there wereno recorded voltage oscillations and the voltage change was a smooth step change, whichwould have no adverse impact on equipment performance. Therefore, performing load rejecttests in accordance with SR 3.8.1.10 in any modes would not cause a significant perturbationthat would adversely affect the onsite AC electrical system.4.1.1.3 Protective Trip RelaysDuring single largest load rejection surveillance testing of DGs while in test mode,non-emergency trip features are in effect to protect the DG from equipment damage due toequipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demandoccurs with these non-emergency trips in effect, the affected DG will automatically revert to theemergency mode and bypass these trips. No operator action is required. Upon detection ofunder voltage on the safety-related 4160v bus, load shedding for all vital loads andnon-permanently connected loads from the 4160v bus would occur followed by re-sequencing ofthe vital loads back onto the affected 4160v bus. The operators receive indication and alarms inthe control room that the preferred power source is lost. In addition, the proposed change doesnot impact voltage regulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the single largest load rejection surveillance test issimilar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DGmonthly surveillance test run), which is performed while in Mode 1.4.2 Changes to SR 3.8.1.11 (DG full load rejection surveillance test)4.2.1 Deletion of mode restriction note from SR 3.8.1.11The current approach for performance of the full load rejection surveillance test in SR 3.8.1.11has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raisethe DG to the required 100% load, and then open the DG output breaker. Opening of the DGoutput breaker separates the DG from its associated safety-related 4160v bus and allows theoffsite circuit to continue to supply that bus. to AEP-NRC-2014-70Page 6The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. Therefore, the current testing processdoes not require the DG and 4160v bus being tested to remain operable. This change requestis proposing that testing also be allowed in Mode 1 or 2, when both DGs are required to beoperable per TS 3.8.1.There are three concerns associated with performing the full load rejection surveillance test inMode 1 or 2. The first concern is that the DG being tested is more susceptible to damagecaused by grid disturbances. Secondly, disconnecting the DG while paralleled to thesafety-related 4160v buses at 100% rated load could cause electrical system perturbations.Finally, the DG in test mode is more susceptible to tripping due to the extra protective trip relaysthat are in effect during test mode operations.4.2.1.1 Grid DisturbancesThe concern of performing the full load rejection surveillance test in Mode 1 or 2, whileconnected to offsite power or generator output, is that the DG is susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based on the fact that the remaining DG would remainoperable and is capable of mitigating a DBA. The onsite AC power system is fully capable ofmitigating a DBA or providing for safe shutdown of the associated unit with the remaining DGoperable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the full load rejectionsurveillance test per SR 3.8.1.11, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with noadverse effect.4.2.1.2 Electrical PerturbationsThe concern during this testing is that suddenly disconnecting a DG from the associated bus ona full load rejection surveillance test could cause a voltage fluctuation on that bus that couldpotentially perturb the onsite AC electrical system. However, industry experience shows that  to AEP-NRC-2014-70Page 7there is no significant electrical distribution system effect on the associated bus during a full loadrejection surveillance test. Therefore, performing full load rejection surveillance tests inaccordance with SR 3.8.1.11 in any modes would not cause a significant perturbation that wouldadversely affect the onsite AC electrical system.4.2.1.3 Protective Trip RelaysDuring full load rejection surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. In addition, the proposed change does not impact voltageregulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the full load rejection surveillance test is similar to theelectrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed during Mode 1.4.3 Changes to SR 3.8.1.15 (DG endurance surveillance test run)4.3.1 Deletion of mode restriction note from SR 3.8.1.15The concerns of performing the DG endurance surveillance test run (8-hour load run) requiredby SR 3.8.1.15 in Mode 1 or 2 are the DG being tested is susceptible to grid disturbances andthe additional protective trip features would be in place making the DG more vulnerable to apossible trip while being parallel with the offsite power or generator output source.4.3.1.1 Grid DisturbancesThe concern with performing the endurance run in Mode 1 or 2, while connected to offsite poweror generator output, is that the DG is susceptible to grid disturbances. Only one DG per unit isparalleled to offsite power or generator output at any one time and any grid disturbances wouldonly possibly affect one DG. Therefore, the justification for this proposed change is based onthe fact that the redundant train DG would remain operable and is capable of mitigating a DBA.The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdownof the associated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action. to AEP-NRC-2014-70Page 8As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the endurance runsurveillance test per SR 3.8.1.15, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while in Mode 1 or 2.4.3.1.2 Trip RelaysDuring endurance run surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. Therefore, these additional trip functions are not a significantconcern during performance of the DG endurance surveillance test runs while in Mode 1 or 2.In addition, the remaining DG will be available to respond and mitigate a DBA or provide safeshutdown capability.Finally, the proposed test configuration for the DG endurance surveillance test run is similar tothe electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed while in Mode 1.4.4 Risk assessment for performing DG single largest load rejection surveillance test(SR 3.8.1.10), DG full load reiection surveillance test (SR 3.8.1.11). and DGendurance surveillance test run (3.8.1.15) in Mode I or 2.Currently, when the DG single largest load rejection surveillance test, the DG full load rejectionsurveillance test, and the DG endurance surveillance test run are performed they may beperformed in Mode 5 or 6. When a DG is undergoing any of these three tests it is consideredinoperable but available to respond to design based accidents.Performing these tests in Mode 1 or 2 does not change the potential level of risk during thesetests. As in Modes 5 and 6, the DG is available and capable of performing its safety functions.The determination of availability of the DG in test is consistent with the definition of unavailablein NUMARC 93-01, Revision 4A, Appendix B, which states: "SSCs out of service for testing areconsidered unavailable, unless the test configuration is automatically- overridden by a validstarting signal, or the function can be promptly restored either by an operator in the control roomor by a dedicated operator stationed locally for that purpose. Restoration actions must becontained in a written procedure, must be uncomplicated (a single action or a few simpleactions), and must not require diagnosis or repair...." Per the above discussion, for these teststhe DG in test will remain available per these guidelines. As a result, there is no increase inunavailability of the DG and there is a minimal increase in the risk. to AEP-NRC-2014-70Page 9Also, a review was conducted of DG starts at CNP for the last 10 years (DG starts sinceJanuary 1, 2004) as well as a search of the CNP Corrective Action Program for that same timeperiod. This search included all four DGs (two DGs in Unit 1 and two DGs in Unit 2) and noresults were found of an instance where any starts have caused additional problems to the DGsthemselves, other CNP equipment, or the electrical grid any different regardless of the mode inwhich the DG was actually started.
 
==5.0 REGULATORY EVALUATION==
5.1 Applicable Regulatory Reguirements/CriteriaRegulatory RequirementsUFSAR Section 1.4, "Plant Specific Design Criteria (PSDC)", defines the principal criteria andsafety objectives for the CNP design. The following PSDC is relevant to the proposedamendment:"CRITERION 39 Emergency PowerAn emergency power source shall be provided and designed with adequateindependency, redundancy, capacity, and testability to permit the functioning of the ESFand protection systems required to avoid undue risk to the health and safety of thepublic. This power source shall provide this capacity assuming a failure of a single activecomponent."The design of the AC electrical power system provides independence and redundancy toensure an available source of power to the ESF systems. The onsite Class 1 E AC distributionsystem for I&M is divided into two load groups. A safety-related 4160v bus is associated witheach load group. The two load groups are 100% redundant and are electrically and physicallyseparated such that the loss of either group does not prevent the minimum safety functions frombeing performed. Each load group has connections to either of two offsite power sources fromthe switchyard, and a single DG. Offsite power is supplied to the switchyard from thetransmission network via two rights of way approaching the site from two different directions.The proposed changes modify plant condition requirements for the test of the DGs whichprovide emergency power to the safety-related 4160v buses in the event of a LOOP. The testrequirements are intended to verify and/or ensure continued OPERABILITY of the DGs. Theproposed changes involve no changes to the required tests themselves except to allow certaintests to be performed during modes for which performance of the affected tests is currentlyprohibited. Evaluation of the proposed changes has determined that DG availability is notsignificantly affected by the proposed changes, that the potential for significantly adverseelectrical perturbations during tests such as SR 3.8.1.11 (Full-Load Rejection Test) isacceptably low, and that the potential for a grid disturbance causing DG unavailability while aDG is in test is quite low. Further, only one DG will be tested at a time such that OPERABILITYof the redundant train DG and its associated bus and bus loads will be unaffected. Testing willthus continue in a manner that supports redundant train DG OPERABILITY so that both DGs  to AEP-NRC-2014-70Page 10will be available to perform their intended safety function consistent with regulatoryrequirements.In conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public.5.2 No Significant Hazards Consideration DeterminationPursuant to 10 CFR 50.90, I&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend theAppendix A TS to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes amendingSR 3.8.1, "AC Sources". I&M has evaluated whether a significant hazards consideration isinvolved with the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of amendment," as discussed below:1. Does the proposed change involve a significant increase in the probability of occurrence orconsequences of an accident previously evaluated?Response: NoThe design of plant equipment is not being modified by the proposed changes. In addition,the DGs and their associated emergency loads are accident mitigating features. As such,testing of the DGs themselves is not associated with any potential accident-initiatingmechanism. Therefore, there will be no significant impact on any accident probabilities bythe approval of the requested changes.The changes include an increase in the time that a DG under test will be paralleled to thegrid while the unit is in Modes 1 or 2. As such, the ability of the tested DG to respond to aDBA could be minimally adversely impacted by the proposed changes. However, theimpacts are not considered significant based, in part, on the ability of the remaining DG tomitigate a DBA or provide safe shutdown. Experience shows that testing for these SRstypically does not perturb the electrical distribution system. In addition, operatingexperience supports the conclusion that the proposed changes do not involve any significantincreases in the likelihood of a safety-related bus blackout or damage to plant loads.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accident fromany accident previously evaluated?Response: NoThe capability to synchronize a DG to the offsite source (via the associated plant bus) andtest the DG in such a configuration is a design feature of the DGs, including the test modeoverride in response to a safety injection signal. Paralleling the DG for longer periods of  to AEP-NRC-2014-70Page 11time during plant operation may slightly increase the probability of incurring an adverseeffect from the offsite source, but this increase in probability is judged to be still quite smalland such a possibility is not a new or previously unrecognized consideration.The proposed change does not introduce a new mode of plant operation and does notinvolve physical modification to the plant. The change does not introduce new accidentinitiators or impact assumptions made in the safety analysis.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: NoThe proposed changes do not exceed or alter a design basis or safety limit, so there is nosignificant reduction in the margin of safety. The margin of safety is related to theconfidence in the ability of the fission product barriers to perform their design functionsduring and following an accident situation. These barriers include the fuel cladding, thereactor coolant system, and the containment system. The proposed changes do not directlyaffect these barriers, nor do they involve any significantly adverse impact on the DGs whichserve to support these barriers in the event of an accident concurrent with a LOOP. Theproposed changes to the testing requirements for the plant DGs do not affect theOPERABILITY requirements for the DGs, as verification of such OPERABILITY will continueto be performed as required (except during different allowed modes). The changes have aninsignificant impact on DG availability, as the DGs remain available to perform their requiredfunction of providing emergency power to plant equipment that supports or constitutes thefission product barriers. Only one DG is to be tested at a time, so that the remaining DG willbe available to safety shut down the plant if required. Consequently, performance of thefission product barriers will not be impacted by implementation of the proposed amendment.In addition, the proposed changes involve no changes to setpoints or limits established orassumed by the accident analysis.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, I&M concludes that the proposed amendment presents no significanthazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.5.3 ConclusionIn conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public. to AEP-NRC-2014-70Page 1
 
==26.0 ENVIRONMENTAL CONSIDERATION==
A review has determined that the proposed amendment would change a requirement withrespect to installation or use of a facility component located within the restricted area, as definedin 10 CFR 20, or would change an inspection or surveillance requirement. However, theproposed amendment does not involve: (i) a significant hazards consideration, (ii) a significantchange in the types or significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion setforth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with the proposedamendment.7.0 PRECEDENCE1. Amendment 173 to Columbia Generating Station Operating License (
 
==Subject:==
ColumbiaGenerating Station Operating License NPF-21 Request for Technical SpecificationsAmendment to Remove Operating Mode Restrictions for Emergency Diesel GeneratorSurveillance Testing, dated May 18, 2001.)2. Amendment 154 to Wolf Creek Generating Station Operating License (
 
==Subject:==
Wolf CreekGenerating Station -Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4-AC and DC Sources, dated July 12, 2004.)3. Amendment 167 to Palo Verde Generating Station Operating License (
 
==Subject:==
Palo VerdeNuclear Generating Station, Units 1, 2, and 3- Issuance of Amendments RE: AC Sources -Operating Surveillance Requirements, dated May 16, 2007.
 
==8.0 REFERENCES==
: 1. 10 CFR 50.90, "Application for amendment of license, or construction permit, or early sitepermit"2. 10 CFR 50.36, "Technical Specifications"3. Indiana and Michigan Power D. C. Cook Nuclear Plant Updated Final Safety AnalysisReport, Revision 25  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.10---------------NOTES ---------------1 Thist Su~eiir aR~i~c shall not nermaivh beanr~r~u~ -I ~.. '~ LI......wvp~;IL;;f !R Mn 60FL ASureilanc ma beperformned to reestablishOPERA.BILITY provided an assessmentA-+-rmi.-p fhe- pfh rf +k- .,nw+ 0&#xfd; m..r-nt'nnippdk~2, +a 4Ln fnrflfv4. 4. L&#xfd; 4-: Ir 4&L-; 0 MHH" RAAA RVAP :R 195.- If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 13.8.1-9Amendment No. 287, 294, 309 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.11--------------NOTES ---------------1. This Surveillance shall not normally beperfoermed in MODE 1 Or 2. However, thisSurveillanGe may be performed to reestablishOPERA\BILITY provided an assessmentdetermines the safety of the unit is maint-ainedor enhanced. Credit may be taken for-i Jl munpiaRneci events that satisry this Si.fI2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-10Amendment No. 27-7, 294, 295 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15------------- NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.I II I II I, ~ ~~~~~ I ue'mglfmI&#xfd;,. 'I n^ nflrn''I n fin I~CW~ ,.. ~ ~ +hiy2Suveilla;nrLe may be nerfOrmed to reestab-lishA I'IP\Ideterl Lmine t fGety of teniimntnine41". .'J .no t1, iai t n i .e v nts that LIthus nR.unclanned e'-ents that satisf'- this SR.If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours at a load> 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-13Amendment No. 287, 291  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.10-------------- NOTES ---------------1 Thic. , cmaI.n~ h',il nr+ nr~n, =11y hoIIf nrnAt ;r RAfll ME ar 1) W-nna#k;hicc.OPERABI LITY provided an assessmentor enhanced. Credit may be taken-forunplanned events that satisfy this SRmE2. If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 23.8.1-9Amendment No. 269, 27-3, 291 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.11-----------------NOTES ---------------I. This Su'p-eillance shall not normally beperformed in MODE 1 or 2. However, thisSurveillance may be performed to reestablishOPERABI LITY provided an assessmentdetemnines the safety of the unit is maintainedor enhan-ed. Cred-it ma" be taken Gfounplanned events that satisfy this SR.IE2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-10Amendment No. 2-6-, 2-7-3, 276 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15--------------- -NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.perfo)rmed inMODE 1 Or 2. However, this-Survillncemay be performed to reestablishOPEIR-ABILITY provided an assessmentdetermnines the safety of the un~it is maintained^r anOr~AfraA.+t M-, him +nLkat3 (p)e4m +.'na +~a~ 4k +~ e#+ M f&#xfd; +hk e Q DIurip Or1riv vvvri CY Ct VC1 0 0E3-. If performed with DG synchronized with offsitepower, it shall be performed at a power factor5 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours at a load> 3150 kW and <3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-13Amendment No. 2-69, 273  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)
AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)b. Tripping its associated single largest post-accident load with the DGsolely supplying the bus.Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test isacceptable if the increase in diesel speed does not exceed 75% of thedifference between synchronous speed and the overspeed trip setpoint,or 15% above nominal speed, whichever is lower. This corresponds to64.4 Hz, which is the nominal speed plus 75% of the difference betweennominal speed and the overspeed trip setpoint.The time, voltage, and frequency tolerances specified in this SR arederived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.1O.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.This SR is modified by two Notes. The reason for Note 1 is that duringoperation with the reactor critical, performnance of this SR could causeperturbations to the electrical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems.This f rm Rormally performing the Surveillance in MODE 1 or 2is fu'e amplified to allow the Surveillance to be performned for thepurpose Of reestablishing OPERABILITY (e.g., post work testing fooIwInIgcorrective mnaintenance, correctiVe modification, deficient Or incompletesur-ve*ilance testing, and other un;anipae 0-PEABILITY concerns)provided an assessm.en unit saft is maintained G.enhanced. This assessm~ent shall, as a minimum, consider the potentialoutcom~es and transients associated with a failed Surveillance_,asuccessful SuIveillance, and a perturbation of the offsite Or onsite systemwhen they are tied together or operated idpnetyfor theas well as the peratoFr prroedures available to cope Withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to det6rMinP that uIt IRsafety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Cook Nuclear Plant Unit 1 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Credit may be taken foar unplanned events that satisfy this SR. Creditmnay be taken for unplanned events that satisfy this SR.Note 2-]N ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of S 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note 2N allows the Surveillance to be conducted ata power factor other than < 0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfactor to < 0.86 results in voltages on the emergency busses that are toohigh. Under these conditions, the power factor should be maintained asclose as practicable to 0.86 while still maintaining acceptable voltagelimits on the emergency busses. In other circumstances, the grid voltagemay be such that the DG excitation levels needed to obtain a powerfactor of 0.86 may not cause unacceptable voltages on the emergencybusses, but the excitation levels are in excess of those recommended forthe DG. In such cases, the power factor shall be maintained as close aspracticable to 0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forCook Nuclear Plant Unit 1 B 3.8.1-22 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1future application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has been modified by two Notes. The reason Note 1 is thatduring operation with the reactor critical, performance of this SR couldCook Nuclear Plant Unit I B 3.8.1-23 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)challenge continued steady ,tate operation and, as a result, unit safetsystems. This restriction from normally performing the Sur'veillance iv,,-,,-Ifor the pur.poe Of PER.BI LITY (e.g., post work testingfollowing corrective maintenance, corrective mmdification, deficient o ninGomplete surhvn IeillaesiRg, and othe runRantficipated OPERABILITYconcerns) provided an assessment determines unit safety is maintainedor enrhaned. This assessmenrt shall, as a minimumo, conider thepotertial outonmes and transierts assciated with a failed Surveillance, asuccessful Suveillance, and a perturbeation of the offsite or onsite systemowhen they are tied together oe operated independertly for theSuhveillaNce; as well as the operator procedures available to cope withthese outconmes. These shall be measured against the avoided risk of aunit shutdown and startup to determnine that unit safety is mnaintained orenhanced when the Surveillance is perftorned in MODE 1 or 2. RiskinRsights OrFeemnsi methods mnay be used for this assessment.redit may bee taken forg unplanned events that satisfy this SR. Note 2Fihensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of 5 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note ORj allows the Surveillance to be conducted at a powerfactor other than 5 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to<ay0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.Cook Nuclear Plant Unit 1 B 3.8.1-24 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-24Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)restriction from normally performing the Surveillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purposeof reestablishing OPERABILITY (e.g., post work testing followingcorrective maintenance, corrective modification, deficient or incompletesurveillance testing, and other unanticipated OPERABILITY concerns)provided an assessment determines unit safety is maintained orenhanced. This assessment shall, as a minimum, consider the potentialoutcomes and transients associated with a failed Surveillance, asuccessful Surveillance, and a perturbation of the offsite or onsite systemwhen they are tied together or operated independently for theSurveillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours. The run duration of 8 hours is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by Frh Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate thistest. Similarly, momentary power factor transients above the power factorlimit will not invalidate the test. The reason for Note 2 is that duringoperation with the reactor critical, perfrmance of this Sue..illance could.,cause perturbations to the electrical distribution systems that couldchallenge conAtinlued steady 6tate operation and, as a result, unit safetysystemns. This restriction fromn noarmally performing the Surveillancc inCook Nuclear Plant Unit 1B 3.8.1-29Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)hA DF= I Cjr ') ffig fiir+kpr p lofipt4 +^ pllpjAg thp S;i impmIlpriga +a him niarfnpmadII ,,,,.,.." .... ........l r hfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing corrective mnaintenance, corrective modification, deficient orincomplete sun eillanTe testing, and other unaRticipated OPERABILITYconcerns) provided an assessment determines unit safety is maiintainA.edaor enhanced. This assessment shall, as a mnimumn, consider thepotential outcomes and transients associated with failed SRmveillane, -asuccesfulSurveillance, and a perturbaptine of the offfsite or onsite systemwhen they are tied together or operated idpnetyfor theSurveillance; as well as the operator procedures available to cope withthese outcomnes. These shall be mneasured against the -avofided risk of aunit shutdown and startup to determnine that unit safety is mnaintained OFenhanced when the Surveillance is performned in MODE 1 or 2. Riska R~ioht5 or dteF in~tir- Mothnir;Fnay be h used for thus assesmentCredit may be taken for unplanned that satisfy this SR.. Note.. 12ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note P21233 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.16Cook Nuclear Plant Unit 1 B 3.8.1-30 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-30Revision No. 41  to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)
AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)derived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.10.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.Thir SR is modified by two .ntes. The reason for Note 1 is that duringoperation with the reac.to critical, peFor.mance of this SR could causeperturbations to the e ical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems. This,restriction from normally perfo~rming the Survefillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purpose-of reestablishing OPERA~BILITY (e'g., post work testing followingcorrective main~tenance, corri-rectivemoifiaton deficient Or incompletesurveillance testfing, and Other u-nanticipated OPERABILITY concerns)enhanced. This assessment shall, astadminimum, consider the potentialoutcomes and transients associated ith a fpaile.d SuWh eilnchronzed, a-successful Supreillanre, anda perti ation of the onduite onsite systemwhen they aro tied together or operated inenddetntl for theSurveillance; as well as the operator procedures avalilableA to- cope withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to determ~ine that unit safety is mnaintained orenhadned wher the Surveillance is performed in MODE 1 or 2. Riski nsights or determfinistic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Creditma" be taken for unplanned eventS that satisfy this SR.Note F1j2 ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of 5 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note rlj!2 allows the Surveillance to be conducted ata power factor other than -0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfertfnr < n RR raci nlfQ in \,nlri n nn thp Pmmsrnr-nr% hi nQ=P thnt nrm fnnCook Nuclear Plant Unit 2 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 2B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forfuture application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has, been Modified by two Notes. The resn for Note 1 is thatduring operation with the reactor critical, performance of this SR couldcause perturbation to the electrical distribu1tion systems6 that colGhallenqe continued- steady state opeation and, as a result, unit safetyCook Nuclear Plant Unit 2B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1systems. T-his restriction fromn normally pedorm~ing the Surveillance inMODE 1 Or 2 is fudther amplified to allow the Surveillance to be perfrmedfor the purpose of reestablishing OPERABILITY (e.g., post work testiRgfollowing corrective mnaintenance, co~rrective moedification, deficient orincGomplete surveillance testing, and other unanticipated OPERABILITYconcerns) provided an assessment d~eterm~ines unit safety is Maintainedo-r enhanc~ed. This assess6ment shall, as a minimum, consider thepotential ou1tcomes and transients associated with a failed Surveillance, asuccessfiul and a pedIurbationof the offsite or onsito systemvR ter irey aIr Lieu tn!eTrlIC at U-JCILC irnuependuenrtly i9 te-Cook Nuclear Plant Unit 2B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Survleillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown andstartup to deter;ine that unit safety is maintained erenhan-edd When the Suirveillance is performned On MODE 1 or 2. Riskins~ights or determn~iistic methods m;ay be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Note F120ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note N allows the Surveillance to be conducted at a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to< 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86 maynot cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8*1.12Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.4, thisSurveillance demonstrates the as designed operation of the standbypower sources during loss of the offsite source. This test verifies allactions encountered from the loss of offsite power, including shedding ofthe nonessential loads and energization of the emergency buses andrespective loads from the DG. It further demonstrates the capability ofthe DG to automatically achieve the required voltag'e and frequency withinthe specified time.The DG autostart time of 10 seconds is derived from requirements of theenI aaly58 W rOesp1 Mo a *laeSgll I2 1asi 1a-I e I reaK t, U ,. I MeCook Nuclear Plant Unit 2 B 3.8.1-24 Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)as well as the operator procedures available to cope with these outcomes.These shall be measured against the avoided risk of a unit shutdown andstartup to determine that unit safety is maintained or enhanced when theSurveillance is performed in MODE 1 or 2. Risk insights or deterministicmethods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours. The run duration of 8 hours is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by e Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate this test.Similarly, momentary power factor transients above the power factor limitwill not invalidate the test. The reason for Note 2 is that during operationwith the reactor critical, performance of this Surveillance couild causeperturbationS to the electrical distribution systems that ceuld challengecontinued steady state operation and, as a result, unit safety systems.This restriction from normally performing the Surveillance inMODE 1 or 2 is further amplified to alloW the Su1,rveillaRne to be performedfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing correctiVe maintenance, corrective modification, deficient orincomplete surveillancGe testing, and other unanticipated OPERABI LITYconcerns) provided an assessment determines unit safety is maintainedor enhanced. This assessment shall a a miniMum, consider thepotential ouGtmres ad ets s;oqcSated with a failed SureillaRe, aSuccessful Su.veillance, and a perturbation of the offs.te Or olsite systemwhen they are tied together Or operated independently for the-Sureilane;as well as the operator procedures available to cope withCook Nuclear Plant Unit 2B 3.8.1-27Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)these outcomes. These shall be measured against the aoddrisk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when. the Sur....eil.an.e is performed in MODE 1 or 2. Risk4nsgnis or eRIne!noaS may Be used TOF Mis asses .Credit may be taken for unplanned events that satisfy this SR-. Note M3ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note M3 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.16This Surveillance demonstrates that the diesel engine can restart from ahot condition, such as subsequent to shutdown from normalSurveillances, and achieve the required voltage and frequency within10 seconds. The 10 second time is derived from the requirements of theaccident analysis to respond to a design basis large break LOCA. The24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR is modified by two Notes. Note 1 ensures that the test isperformed with the diesel sufficiently hot. The load ban isprvded toCook Nuclear Plant Unit 2 B 3.8.1-28 Re Nvision No. 41}}

Revision as of 06:47, 26 June 2018

Donald C. Cook, Units 1 & 2, License Amendment Request Regarding Technical Specification Section 3.8.1, AC Sources - Operating, Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15
ML14356A022
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/17/2014
From: Lies Q S
American Electric Power, Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2014-70
Download: ML14356A022 (37)
v • d • e


Text

zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPIPM R One Cook PlaceBridgman, Ml 49106A unit ofAmerican Electric Power IndianaMichiganPower.comDecember 17, 2014 AEP-NRC-2014-7010 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Donald C. Cook Nuclear Plant Unit 1 and Unit 2Docket Nos. 50-315 and 50-316License Amendment Request Regarding Technical Specification Section 3.8.1, "ACSources -Operating," Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook NuclearPlant Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to FacilityOperating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify the notesto TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of the onsite standbyemergency diesel generators (DG) during modes in which it is currently prohibited. Specifically,I&M proposes removing the mode restrictions for the following Surveillance Requirements: 3.8.1.10(DG single largest load rejection test), 3.8.1.11 (DG full load rejection test), and 3.8.1.15 (DGendurance run).I&M has evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded thatthey involve no significant hazards consideration.Enclosure 1 to this letter provides an affirmation statement pertaining to the information containedherein. Enclosure 2 provides I&M's evaluation of the proposed TS change. Enclosures 3 and 4provide Unit 1 and Unit 2 TS pages marked to show the proposed changes. Enclosures 5 and 6provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. Bases markupsare included for information only. New clean Unit 1 and Unit 2 TS pages with proposed changesincorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing ProjectManager when requested.I&M requests approval of the proposed change in accordance with the NRC's normal review andapproval schedule. The proposed change will be implemented within 90 days of NRC approval.Copies of this letter and its enclosures are being transmitted to the Michigan Public ServiceCommission and Michigan Department of Environmental Quality, in accordance with therequirements of 10 CFR 50.91.AooI U. S. Nuclear Regulatory CommissionPage 2AEP-NRC-2014-70There are no new regulatory commitments made in this letter. Should you have any questions,please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Q. Shane LiesEngineering Vice PresidentJMT/amp

Enclosures:

1.2.AffirmationProposed License Amendment Request Regarding Revision to Technical Specifications3.8.1, "AC Sources -Operating"3. Donald C. Cook Nuclear Plant UnitProposed Changes4. Donald C. Cook Nuclear Plant UnitProposed Changes.5. Donald C. Cook Nuclear Plant UnitShow Proposed Changes.6. Donald C. Cook Nuclear Plant UnitShow Proposed Changes1 Technical Specification Pages Marked To Show2 Technical Specification Pages Marked To Show1 Technical Specification Bases Pages Marked To2 Technical Specification Bases Pages Marked Toc: M. L. Chawla, NRC Washington, D.C.J. T. King -MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC Region IIIA. J. Williamson, AEP Ft. Wayne, w/o enclosures Enclosure I to AEP-NRC-2014-70AFFIRMATIONI, Q. Shane Lies, being duly sworn, state that I am Engineering Vice President of IndianaMichigan Power (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan PowerQ. Shane LiesEngineering Vice PresidentSWORN TO AND SUBSCRIBED BEFORE METHIS \A-.' DAY OF , 2014My CNotareysblicMy Commission Expires c)'-\)- -DANIELLE BURGOYN6Notary Public, State of MichiganCounty of BerrienMy Commission Expires 04--04-2018Acting In the County of 4 to AEP-NRC-2014-70Proposed License Amendment Request RegardingRevision to Technical Specifications 3.8.1, "AC Sources -Operating"1.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. CookNuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A TechnicalSpecifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revisethe licenses to modify TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of theonsite standby emergency diesel generators (EDG) during modes in which it is currentlyprohibited. Specifically, I&M proposes removing the Note that imposes the mode restrictions forthe following Surveillance Requirements (SR): 3.8.1.10 (diesel generator (DG) single largestload rejection surveillance test), 3.8.1.11 (DG full load rejection surveillance test), and 3.8.1.15(DG endurance surveillance test run).2.0 DETAILED DESCRIPTION2.1 Proposed ChangeI&M proposes the following changes in order to eliminate the Mode 1 and 2 Surveillance testingrestrictions for SRs 3.8.1.10, 3.8.1.11, and 3.8.1.15, as discussed above. The changes wouldbe effected by deleting the applicable Note for each surveillance, as follows:2.1.1 Proposed Change to TS SR 3.8.1.10 (DG single largest load reiection surveillancetest)Note 1 in SR 3.8.1.10 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.10 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.2 Proposed Change to TS SR 3.8.1.11 (DG full load reiection surveillance test)Note 1 in SR 3.8.1.11 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed. to AEP-NRC-2014-70Page 2Additionally, compensatory measures for SR 3.8.1.11 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.3 Proposed Change to TS SR 3.8.1.15 (DG endurance surveillance test run)Note 2 in SR 3.8.1.15 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.15 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.The above changes, if approved, will allow the testing required by these SRs to be performedduring all modes of operation such that the testing will no longer be required to be performedonly during plant outages. This will help to reduce the complexity of coordinating work andtesting activities during refueling outages and allow these activities to be performed online. Thechange will also reduce risk during a refueling outage where the plant is relying on a single trainfor core cooling. This also allows for shorter refueling outage durations which reduces theduration the plant is in an elevated risk condition.The marked-up and revised Unit 1 and Unit 2 TS pages reflecting the above changes areprovided in Enclosures 3 and 4 of this letter, respectively. In addition, the associated Unit 1 andUnit 2 TS Bases will be revised to reflect the changes to these TSs. A marked-up copy of theproposed Unit 1 and Unit 2 TS Bases changes is provided in Enclosures 5 and 6 of this letter,respectively, for information only. The TS Bases changes will be implemented in accordancewith TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of theimplementation of this amendment after NRC approval.3.0 BackgroundDescription of Emergency Power SystemAs stated in Updated Final Safety Analysis Report (UFSAR) Section 8.4, "Emergency PowerSystem," the emergency power sources for the two units, including the DGs, are similar and areelectrically and physically isolated from one another. Each unit has two full capacity DGs eachsupplying power to two safety-related 4160 volt (v) buses. Loss of voltage to the 4160v buses issensed by loss of voltage relays. Upon sensing, master relays automatically start the DGs, tripthe normal feed circuit breakers for the 4160v buses, and trip all motor feeder breakers and480v bus transformer feeder breakers on the buses, the 600v bus tie breaker, non-essential600v feeder breakers, and 480v bus breakers. The DG bus input circuit breakers which connect to AEP-NRC-2014-70Page 3the DG output to the 4160/600v bus system are automatically closed when voltage and speedapproach rated values. The DGs supply power to the 600v buses through the 4160v buses andtransformers, respectively.Each DG comes up to speed and is capable of accepting load within 10 seconds. If either DGfails to start, the remaining one is capable of supplying the required engineered safeguard load.A Safety Injection (SI) signal will also start the DGs. To avoid overloading of the DGs, all loadsare shed when the SI occurs and the safety-related 4160v buses are energized from the DGs.The safety loads are subsequently loaded in a sequential manner as required.The DGs are sized at 3500 kilowatts (KW) each to assure available power to operate one trainof safety equipment assuming a loss-of-offsite-power (LOOP) concurrent with a loss-of-coolantaccident with or without containment spray.UFSAR Section 8.1.2, "Functional Criteria," provides functional requirements employed onelectrical systems to achieve maximum reliability and operating efficiency. One of the criteria isthat motor loading does not exceed its nameplate rating.Each diesel engine is a Worthington Type SWB-12, 12 cylinder, heavy duty turbocharged dieselengine, with a continuous rated output of 4900 brake horsepower at 514 revolutions per minute(RPM).Each generator is a General Electric (GE), 4375 kilo volt amps (a), 3500KW at 0.8 power factor,514 RPM, 3-phase, 60-cycle, 4160v, 25 percent (%) voltage regulation, direct engine-drivensynchronous type generator. Each generator is equipped with a GE brushless exciter type 5ARwith a field rated 5.8a and 100v direct current (DC) and, a static voltage regulator with itsassociated potential and sensing transformers.The alternating current (AC) sources are designed to permit inspection and testing of allimportant areas and features, especially those that have a standby function, in accordance withPlant Specific Design Criterion (PSDC) 39. Periodic component tests are supplemented byextensive functional tests during refueling outages (under simulated accident conditions). TheSRs for demonstrating the OPERABILITY of the DGs are in accordance with therecommendations of U. S. Nuclear Regulatory Commission (NRC) Regulatory Guide 1.9,"Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants", andInstitute of Electrical and Electronics Engineers (IEEE) Standard 387-1995 IEEE StandardCriteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear PowerGenerating Stations. to AEP-NRC-2014-70Page

44.0 TECHNICAL EVALUATION

4.1 Changes to SR 3.8.1.10 (DG single largest load rejection surveillance test)4.1.1 Deletion of mode restriction note from SR 3.8.1.10 DG single largest load rejectiontest.The current approach for performance of the load rejection test in SR 3.8.1.10 has been toparallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG tothe required load, and then open the DG output breaker. Opening of the DG output breakerseparates the DG from its associated safety-related 4160v bus and allows the offsite circuit tocontinue to supply that bus.The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. During testing the diesel being tested isinoperable, but available. This license amendment request (LAR) is proposing that this testingalso be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.The concerns associated with performing the single largest load rejection surveillance test inMode 1 or 2 are that the DG being tested is susceptible to damage caused by grid disturbances,disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated loadmight cause electrical system perturbations, and the DG in test mode is more susceptible totripping due to the extra protective trip relays that are in effect during test mode operations.4.1.1.1 Grid DisturbancesThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2,while connected to offsite power or generator output, is that the DG is. susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based-on the fact that the remaining DG would remainoperable and is capable of mitigating a Design Based Accident (DBA). The redundant train ofonsite AC power is fully capable of mitigating a DBA or providing for safe shutdown of theassociated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As a common practice at CNP, risk management considerations ensure that this and other SRsare not scheduled during periods where there is increased potential for grid or bus disturbance to AEP-NRC-2014-70Page 5(storms, grid emergencies, etc.). Performance of the single largest load rejection surveillancetest per SR 3.8.1.10, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently testsits DGs paralleled to offsite power or generator output during required monthly surveillancetesting, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.4.1.1.2 Electrical PerturbationsThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2 isthat suddenly disconnecting a DG from the associated bus on a single largest load rejectionsurveillance test could cause a voltage fluctuation on that bus which could potentially perturbthe onsite AC electrical system. However, industry experience shows that there is no significantelectrical distribution system effect on the associated bus during a single largest load rejectionsurveillance test. Furthermore, at CNP when the single largest load rejection surveillance test isperformed at shutdown, the voltage recovery is within 2 seconds. During this testing there wereno recorded voltage oscillations and the voltage change was a smooth step change, whichwould have no adverse impact on equipment performance. Therefore, performing load rejecttests in accordance with SR 3.8.1.10 in any modes would not cause a significant perturbationthat would adversely affect the onsite AC electrical system.4.1.1.3 Protective Trip RelaysDuring single largest load rejection surveillance testing of DGs while in test mode,non-emergency trip features are in effect to protect the DG from equipment damage due toequipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demandoccurs with these non-emergency trips in effect, the affected DG will automatically revert to theemergency mode and bypass these trips. No operator action is required. Upon detection ofunder voltage on the safety-related 4160v bus, load shedding for all vital loads andnon-permanently connected loads from the 4160v bus would occur followed by re-sequencing ofthe vital loads back onto the affected 4160v bus. The operators receive indication and alarms inthe control room that the preferred power source is lost. In addition, the proposed change doesnot impact voltage regulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the single largest load rejection surveillance test issimilar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DGmonthly surveillance test run), which is performed while in Mode 1.4.2 Changes to SR 3.8.1.11 (DG full load rejection surveillance test)4.2.1 Deletion of mode restriction note from SR 3.8.1.11The current approach for performance of the full load rejection surveillance test in SR 3.8.1.11has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raisethe DG to the required 100% load, and then open the DG output breaker. Opening of the DGoutput breaker separates the DG from its associated safety-related 4160v bus and allows theoffsite circuit to continue to supply that bus. to AEP-NRC-2014-70Page 6The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. Therefore, the current testing processdoes not require the DG and 4160v bus being tested to remain operable. This change requestis proposing that testing also be allowed in Mode 1 or 2, when both DGs are required to beoperable per TS 3.8.1.There are three concerns associated with performing the full load rejection surveillance test inMode 1 or 2. The first concern is that the DG being tested is more susceptible to damagecaused by grid disturbances. Secondly, disconnecting the DG while paralleled to thesafety-related 4160v buses at 100% rated load could cause electrical system perturbations.Finally, the DG in test mode is more susceptible to tripping due to the extra protective trip relaysthat are in effect during test mode operations.4.2.1.1 Grid DisturbancesThe concern of performing the full load rejection surveillance test in Mode 1 or 2, whileconnected to offsite power or generator output, is that the DG is susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based on the fact that the remaining DG would remainoperable and is capable of mitigating a DBA. The onsite AC power system is fully capable ofmitigating a DBA or providing for safe shutdown of the associated unit with the remaining DGoperable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the full load rejectionsurveillance test per SR 3.8.1.11, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with noadverse effect.4.2.1.2 Electrical PerturbationsThe concern during this testing is that suddenly disconnecting a DG from the associated bus ona full load rejection surveillance test could cause a voltage fluctuation on that bus that couldpotentially perturb the onsite AC electrical system. However, industry experience shows that to AEP-NRC-2014-70Page 7there is no significant electrical distribution system effect on the associated bus during a full loadrejection surveillance test. Therefore, performing full load rejection surveillance tests inaccordance with SR 3.8.1.11 in any modes would not cause a significant perturbation that wouldadversely affect the onsite AC electrical system.4.2.1.3 Protective Trip RelaysDuring full load rejection surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. In addition, the proposed change does not impact voltageregulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the full load rejection surveillance test is similar to theelectrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed during Mode 1.4.3 Changes to SR 3.8.1.15 (DG endurance surveillance test run)4.3.1 Deletion of mode restriction note from SR 3.8.1.15The concerns of performing the DG endurance surveillance test run (8-hour load run) requiredby SR 3.8.1.15 in Mode 1 or 2 are the DG being tested is susceptible to grid disturbances andthe additional protective trip features would be in place making the DG more vulnerable to apossible trip while being parallel with the offsite power or generator output source.4.3.1.1 Grid DisturbancesThe concern with performing the endurance run in Mode 1 or 2, while connected to offsite poweror generator output, is that the DG is susceptible to grid disturbances. Only one DG per unit isparalleled to offsite power or generator output at any one time and any grid disturbances wouldonly possibly affect one DG. Therefore, the justification for this proposed change is based onthe fact that the redundant train DG would remain operable and is capable of mitigating a DBA.The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdownof the associated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action. to AEP-NRC-2014-70Page 8As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the endurance runsurveillance test per SR 3.8.1.15, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while in Mode 1 or 2.4.3.1.2 Trip RelaysDuring endurance run surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. Therefore, these additional trip functions are not a significantconcern during performance of the DG endurance surveillance test runs while in Mode 1 or 2.In addition, the remaining DG will be available to respond and mitigate a DBA or provide safeshutdown capability.Finally, the proposed test configuration for the DG endurance surveillance test run is similar tothe electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed while in Mode 1.4.4 Risk assessment for performing DG single largest load rejection surveillance test(SR 3.8.1.10), DG full load reiection surveillance test (SR 3.8.1.11). and DGendurance surveillance test run (3.8.1.15) in Mode I or 2.Currently, when the DG single largest load rejection surveillance test, the DG full load rejectionsurveillance test, and the DG endurance surveillance test run are performed they may beperformed in Mode 5 or 6. When a DG is undergoing any of these three tests it is consideredinoperable but available to respond to design based accidents.Performing these tests in Mode 1 or 2 does not change the potential level of risk during thesetests. As in Modes 5 and 6, the DG is available and capable of performing its safety functions.The determination of availability of the DG in test is consistent with the definition of unavailablein NUMARC 93-01, Revision 4A, Appendix B, which states: "SSCs out of service for testing areconsidered unavailable, unless the test configuration is automatically- overridden by a validstarting signal, or the function can be promptly restored either by an operator in the control roomor by a dedicated operator stationed locally for that purpose. Restoration actions must becontained in a written procedure, must be uncomplicated (a single action or a few simpleactions), and must not require diagnosis or repair...." Per the above discussion, for these teststhe DG in test will remain available per these guidelines. As a result, there is no increase inunavailability of the DG and there is a minimal increase in the risk. to AEP-NRC-2014-70Page 9Also, a review was conducted of DG starts at CNP for the last 10 years (DG starts sinceJanuary 1, 2004) as well as a search of the CNP Corrective Action Program for that same timeperiod. This search included all four DGs (two DGs in Unit 1 and two DGs in Unit 2) and noresults were found of an instance where any starts have caused additional problems to the DGsthemselves, other CNP equipment, or the electrical grid any different regardless of the mode inwhich the DG was actually started.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Reguirements/CriteriaRegulatory RequirementsUFSAR Section 1.4, "Plant Specific Design Criteria (PSDC)", defines the principal criteria andsafety objectives for the CNP design. The following PSDC is relevant to the proposedamendment:"CRITERION 39 Emergency PowerAn emergency power source shall be provided and designed with adequateindependency, redundancy, capacity, and testability to permit the functioning of the ESFand protection systems required to avoid undue risk to the health and safety of thepublic. This power source shall provide this capacity assuming a failure of a single activecomponent."The design of the AC electrical power system provides independence and redundancy toensure an available source of power to the ESF systems. The onsite Class 1 E AC distributionsystem for I&M is divided into two load groups. A safety-related 4160v bus is associated witheach load group. The two load groups are 100% redundant and are electrically and physicallyseparated such that the loss of either group does not prevent the minimum safety functions frombeing performed. Each load group has connections to either of two offsite power sources fromthe switchyard, and a single DG. Offsite power is supplied to the switchyard from thetransmission network via two rights of way approaching the site from two different directions.The proposed changes modify plant condition requirements for the test of the DGs whichprovide emergency power to the safety-related 4160v buses in the event of a LOOP. The testrequirements are intended to verify and/or ensure continued OPERABILITY of the DGs. Theproposed changes involve no changes to the required tests themselves except to allow certaintests to be performed during modes for which performance of the affected tests is currentlyprohibited. Evaluation of the proposed changes has determined that DG availability is notsignificantly affected by the proposed changes, that the potential for significantly adverseelectrical perturbations during tests such as SR 3.8.1.11 (Full-Load Rejection Test) isacceptably low, and that the potential for a grid disturbance causing DG unavailability while aDG is in test is quite low. Further, only one DG will be tested at a time such that OPERABILITYof the redundant train DG and its associated bus and bus loads will be unaffected. Testing willthus continue in a manner that supports redundant train DG OPERABILITY so that both DGs to AEP-NRC-2014-70Page 10will be available to perform their intended safety function consistent with regulatoryrequirements.In conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public.5.2 No Significant Hazards Consideration DeterminationPursuant to 10 CFR 50.90, I&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend theAppendix A TS to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes amendingSR 3.8.1, "AC Sources". I&M has evaluated whether a significant hazards consideration isinvolved with the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of amendment," as discussed below:1. Does the proposed change involve a significant increase in the probability of occurrence orconsequences of an accident previously evaluated?Response: NoThe design of plant equipment is not being modified by the proposed changes. In addition,the DGs and their associated emergency loads are accident mitigating features. As such,testing of the DGs themselves is not associated with any potential accident-initiatingmechanism. Therefore, there will be no significant impact on any accident probabilities bythe approval of the requested changes.The changes include an increase in the time that a DG under test will be paralleled to thegrid while the unit is in Modes 1 or 2. As such, the ability of the tested DG to respond to aDBA could be minimally adversely impacted by the proposed changes. However, theimpacts are not considered significant based, in part, on the ability of the remaining DG tomitigate a DBA or provide safe shutdown. Experience shows that testing for these SRstypically does not perturb the electrical distribution system. In addition, operatingexperience supports the conclusion that the proposed changes do not involve any significantincreases in the likelihood of a safety-related bus blackout or damage to plant loads.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accident fromany accident previously evaluated?Response: NoThe capability to synchronize a DG to the offsite source (via the associated plant bus) andtest the DG in such a configuration is a design feature of the DGs, including the test modeoverride in response to a safety injection signal. Paralleling the DG for longer periods of to AEP-NRC-2014-70Page 11time during plant operation may slightly increase the probability of incurring an adverseeffect from the offsite source, but this increase in probability is judged to be still quite smalland such a possibility is not a new or previously unrecognized consideration.The proposed change does not introduce a new mode of plant operation and does notinvolve physical modification to the plant. The change does not introduce new accidentinitiators or impact assumptions made in the safety analysis.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: NoThe proposed changes do not exceed or alter a design basis or safety limit, so there is nosignificant reduction in the margin of safety. The margin of safety is related to theconfidence in the ability of the fission product barriers to perform their design functionsduring and following an accident situation. These barriers include the fuel cladding, thereactor coolant system, and the containment system. The proposed changes do not directlyaffect these barriers, nor do they involve any significantly adverse impact on the DGs whichserve to support these barriers in the event of an accident concurrent with a LOOP. Theproposed changes to the testing requirements for the plant DGs do not affect theOPERABILITY requirements for the DGs, as verification of such OPERABILITY will continueto be performed as required (except during different allowed modes). The changes have aninsignificant impact on DG availability, as the DGs remain available to perform their requiredfunction of providing emergency power to plant equipment that supports or constitutes thefission product barriers. Only one DG is to be tested at a time, so that the remaining DG willbe available to safety shut down the plant if required. Consequently, performance of thefission product barriers will not be impacted by implementation of the proposed amendment.In addition, the proposed changes involve no changes to setpoints or limits established orassumed by the accident analysis.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, I&M concludes that the proposed amendment presents no significanthazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.5.3 ConclusionIn conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public. to AEP-NRC-2014-70Page 1

26.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement withrespect to installation or use of a facility component located within the restricted area, as definedin 10 CFR 20, or would change an inspection or surveillance requirement. However, theproposed amendment does not involve: (i) a significant hazards consideration, (ii) a significantchange in the types or significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion setforth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with the proposedamendment.7.0 PRECEDENCE1. Amendment 173 to Columbia Generating Station Operating License (

Subject:

ColumbiaGenerating Station Operating License NPF-21 Request for Technical SpecificationsAmendment to Remove Operating Mode Restrictions for Emergency Diesel GeneratorSurveillance Testing, dated May 18, 2001.)2. Amendment 154 to Wolf Creek Generating Station Operating License (

Subject:

Wolf CreekGenerating Station -Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4-AC and DC Sources, dated July 12, 2004.)3. Amendment 167 to Palo Verde Generating Station Operating License (

Subject:

Palo VerdeNuclear Generating Station, Units 1, 2, and 3- Issuance of Amendments RE: AC Sources -Operating Surveillance Requirements, dated May 16, 2007.

8.0 REFERENCES

1. 10 CFR 50.90, "Application for amendment of license, or construction permit, or early sitepermit"2. 10 CFR 50.36, "Technical Specifications"3. Indiana and Michigan Power D. C. Cook Nuclear Plant Updated Final Safety AnalysisReport, Revision 25 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.10---------------NOTES ---------------1 Thist Su~eiir aR~i~c shall not nermaivh beanr~r~u~ -I ~.. '~ LI......wvp~;IL;;f !R Mn 60FL ASureilanc ma beperformned to reestablishOPERA.BILITY provided an assessmentA-+-rmi.-p fhe- pfh rf +k- .,nw+ 0ý m..r-nt'nnippdk~2, +a 4Ln fnrflfv4. 4. Lý 4-: Ir 4&L-; 0 MHH" RAAA RVAP :R 195.- If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 13.8.1-9Amendment No. 287, 294, 309 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.11--------------NOTES ---------------1. This Surveillance shall not normally beperfoermed in MODE 1 Or 2. However, thisSurveillanGe may be performed to reestablishOPERA\BILITY provided an assessmentdetermines the safety of the unit is maint-ainedor enhanced. Credit may be taken for-i Jl munpiaRneci events that satisry this Si.fI2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-10Amendment No. 27-7, 294, 295 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15------------- NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.I II I II I, ~ ~~~~~ I ue'mglfmIý,. 'I n^ nflrnI n fin I~CW~ ,.. ~ ~ +hiy2Suveilla;nrLe may be nerfOrmed to reestab-lishA I'IP\Ideterl Lmine t fGety of teniimntnine41". .'J .no t1, iai t n i .e v nts that LIthus nR.unclanned e'-ents that satisf'- this SR.If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a load> 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-13Amendment No. 287, 291 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.10-------------- NOTES ---------------1 Thic. , cmaI.n~ h',il nr+ nr~n, =11y hoIIf nrnAt ;r RAfll ME ar 1) W-nna#k;hicc.OPERABI LITY provided an assessmentor enhanced. Credit may be taken-forunplanned events that satisfy this SRmE2. If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 23.8.1-9Amendment No. 269, 27-3, 291 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.11-----------------NOTES ---------------I. This Su'p-eillance shall not normally beperformed in MODE 1 or 2. However, thisSurveillance may be performed to reestablishOPERABI LITY provided an assessmentdetemnines the safety of the unit is maintainedor enhan-ed. Cred-it ma" be taken Gfounplanned events that satisfy this SR.IE2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-10Amendment No. 2-6-, 2-7-3, 276 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15--------------- -NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.perfo)rmed inMODE 1 Or 2. However, this-Survillncemay be performed to reestablishOPEIR-ABILITY provided an assessmentdetermnines the safety of the un~it is maintained^r anOr~AfraA.+t M-, him +nLkat3 (p)e4m +.'na +~a~ 4k +~ e#+ M fý +hk e Q DIurip Or1riv vvvri CY Ct VC1 0 0E3-. If performed with DG synchronized with offsitepower, it shall be performed at a power factor5 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a load> 3150 kW and <3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-13Amendment No. 2-69, 273 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)

AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)b. Tripping its associated single largest post-accident load with the DGsolely supplying the bus.Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test isacceptable if the increase in diesel speed does not exceed 75% of thedifference between synchronous speed and the overspeed trip setpoint,or 15% above nominal speed, whichever is lower. This corresponds to64.4 Hz, which is the nominal speed plus 75% of the difference betweennominal speed and the overspeed trip setpoint.The time, voltage, and frequency tolerances specified in this SR arederived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.1O.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.This SR is modified by two Notes. The reason for Note 1 is that duringoperation with the reactor critical, performnance of this SR could causeperturbations to the electrical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems.This f rm Rormally performing the Surveillance in MODE 1 or 2is fu'e amplified to allow the Surveillance to be performned for thepurpose Of reestablishing OPERABILITY (e.g., post work testing fooIwInIgcorrective mnaintenance, correctiVe modification, deficient Or incompletesur-ve*ilance testing, and other un;anipae 0-PEABILITY concerns)provided an assessm.en unit saft is maintained G.enhanced. This assessm~ent shall, as a minimum, consider the potentialoutcom~es and transients associated with a failed Surveillance_,asuccessful SuIveillance, and a perturbation of the offsite Or onsite systemwhen they are tied together or operated idpnetyfor theas well as the peratoFr prroedures available to cope Withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to det6rMinP that uIt IRsafety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Cook Nuclear Plant Unit 1 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Credit may be taken foar unplanned events that satisfy this SR. Creditmnay be taken for unplanned events that satisfy this SR.Note 2-]N ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of S 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note 2N allows the Surveillance to be conducted ata power factor other than < 0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfactor to < 0.86 results in voltages on the emergency busses that are toohigh. Under these conditions, the power factor should be maintained asclose as practicable to 0.86 while still maintaining acceptable voltagelimits on the emergency busses. In other circumstances, the grid voltagemay be such that the DG excitation levels needed to obtain a powerfactor of 0.86 may not cause unacceptable voltages on the emergencybusses, but the excitation levels are in excess of those recommended forthe DG. In such cases, the power factor shall be maintained as close aspracticable to 0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forCook Nuclear Plant Unit 1 B 3.8.1-22 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1future application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has been modified by two Notes. The reason Note 1 is thatduring operation with the reactor critical, performance of this SR couldCook Nuclear Plant Unit I B 3.8.1-23 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)challenge continued steady ,tate operation and, as a result, unit safetsystems. This restriction from normally performing the Sur'veillance iv,,-,,-Ifor the pur.poe Of PER.BI LITY (e.g., post work testingfollowing corrective maintenance, corrective mmdification, deficient o ninGomplete surhvn IeillaesiRg, and othe runRantficipated OPERABILITYconcerns) provided an assessment determines unit safety is maintainedor enrhaned. This assessmenrt shall, as a minimumo, conider thepotertial outonmes and transierts assciated with a failed Surveillance, asuccessful Suveillance, and a perturbeation of the offsite or onsite systemowhen they are tied together oe operated independertly for theSuhveillaNce; as well as the operator procedures available to cope withthese outconmes. These shall be measured against the avoided risk of aunit shutdown and startup to determnine that unit safety is mnaintained orenhanced when the Surveillance is perftorned in MODE 1 or 2. RiskinRsights OrFeemnsi methods mnay be used for this assessment.redit may bee taken forg unplanned events that satisfy this SR. Note 2Fihensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of 5 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note ORj allows the Surveillance to be conducted at a powerfactor other than 5 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to<ay0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.Cook Nuclear Plant Unit 1 B 3.8.1-24 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-24Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)restriction from normally performing the Surveillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purposeof reestablishing OPERABILITY (e.g., post work testing followingcorrective maintenance, corrective modification, deficient or incompletesurveillance testing, and other unanticipated OPERABILITY concerns)provided an assessment determines unit safety is maintained orenhanced. This assessment shall, as a minimum, consider the potentialoutcomes and transients associated with a failed Surveillance, asuccessful Surveillance, and a perturbation of the offsite or onsite systemwhen they are tied together or operated independently for theSurveillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The run duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by Frh Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate thistest. Similarly, momentary power factor transients above the power factorlimit will not invalidate the test. The reason for Note 2 is that duringoperation with the reactor critical, perfrmance of this Sue..illance could.,cause perturbations to the electrical distribution systems that couldchallenge conAtinlued steady 6tate operation and, as a result, unit safetysystemns. This restriction fromn noarmally performing the Surveillancc inCook Nuclear Plant Unit 1B 3.8.1-29Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)hA DF= I Cjr ') ffig fiir+kpr p lofipt4 +^ pllpjAg thp S;i impmIlpriga +a him niarfnpmadII ,,,,.,.." .... ........l r hfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing corrective mnaintenance, corrective modification, deficient orincomplete sun eillanTe testing, and other unaRticipated OPERABILITYconcerns) provided an assessment determines unit safety is maiintainA.edaor enhanced. This assessment shall, as a mnimumn, consider thepotential outcomes and transients associated with failed SRmveillane, -asuccesfulSurveillance, and a perturbaptine of the offfsite or onsite systemwhen they are tied together or operated idpnetyfor theSurveillance; as well as the operator procedures available to cope withthese outcomnes. These shall be mneasured against the -avofided risk of aunit shutdown and startup to determnine that unit safety is mnaintained OFenhanced when the Surveillance is performned in MODE 1 or 2. Riska R~ioht5 or dteF in~tir- Mothnir;Fnay be h used for thus assesmentCredit may be taken for unplanned that satisfy this SR.. Note.. 12ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note P21233 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.16Cook Nuclear Plant Unit 1 B 3.8.1-30 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-30Revision No. 41 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)

AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)derived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.10.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.Thir SR is modified by two .ntes. The reason for Note 1 is that duringoperation with the reac.to critical, peFor.mance of this SR could causeperturbations to the e ical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems. This,restriction from normally perfo~rming the Survefillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purpose-of reestablishing OPERA~BILITY (e'g., post work testing followingcorrective main~tenance, corri-rectivemoifiaton deficient Or incompletesurveillance testfing, and Other u-nanticipated OPERABILITY concerns)enhanced. This assessment shall, astadminimum, consider the potentialoutcomes and transients associated ith a fpaile.d SuWh eilnchronzed, a-successful Supreillanre, anda perti ation of the onduite onsite systemwhen they aro tied together or operated inenddetntl for theSurveillance; as well as the operator procedures avalilableA to- cope withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to determ~ine that unit safety is mnaintained orenhadned wher the Surveillance is performed in MODE 1 or 2. Riski nsights or determfinistic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Creditma" be taken for unplanned eventS that satisfy this SR.Note F1j2 ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of 5 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note rlj!2 allows the Surveillance to be conducted ata power factor other than -0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfertfnr < n RR raci nlfQ in \,nlri n nn thp Pmmsrnr-nr% hi nQ=P thnt nrm fnnCook Nuclear Plant Unit 2 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 2B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forfuture application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has, been Modified by two Notes. The resn for Note 1 is thatduring operation with the reactor critical, performance of this SR couldcause perturbation to the electrical distribu1tion systems6 that colGhallenqe continued- steady state opeation and, as a result, unit safetyCook Nuclear Plant Unit 2B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1systems. T-his restriction fromn normally pedorm~ing the Surveillance inMODE 1 Or 2 is fudther amplified to allow the Surveillance to be perfrmedfor the purpose of reestablishing OPERABILITY (e.g., post work testiRgfollowing corrective mnaintenance, co~rrective moedification, deficient orincGomplete surveillance testing, and other unanticipated OPERABILITYconcerns) provided an assessment d~eterm~ines unit safety is Maintainedo-r enhanc~ed. This assess6ment shall, as a minimum, consider thepotential ou1tcomes and transients associated with a failed Surveillance, asuccessfiul and a pedIurbationof the offsite or onsito systemvR ter irey aIr Lieu tn!eTrlIC at U-JCILC irnuependuenrtly i9 te-Cook Nuclear Plant Unit 2B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Survleillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown andstartup to deter;ine that unit safety is maintained erenhan-edd When the Suirveillance is performned On MODE 1 or 2. Riskins~ights or determn~iistic methods m;ay be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Note F120ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note N allows the Surveillance to be conducted at a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to< 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86 maynot cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8*1.12Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.4, thisSurveillance demonstrates the as designed operation of the standbypower sources during loss of the offsite source. This test verifies allactions encountered from the loss of offsite power, including shedding ofthe nonessential loads and energization of the emergency buses andrespective loads from the DG. It further demonstrates the capability ofthe DG to automatically achieve the required voltag'e and frequency withinthe specified time.The DG autostart time of 10 seconds is derived from requirements of theenI aaly58 W rOesp1 Mo a *laeSgll I2 1asi 1a-I e I reaK t, U ,. I MeCook Nuclear Plant Unit 2 B 3.8.1-24 Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)as well as the operator procedures available to cope with these outcomes.These shall be measured against the avoided risk of a unit shutdown andstartup to determine that unit safety is maintained or enhanced when theSurveillance is performed in MODE 1 or 2. Risk insights or deterministicmethods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The run duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by e Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate this test.Similarly, momentary power factor transients above the power factor limitwill not invalidate the test. The reason for Note 2 is that during operationwith the reactor critical, performance of this Surveillance couild causeperturbationS to the electrical distribution systems that ceuld challengecontinued steady state operation and, as a result, unit safety systems.This restriction from normally performing the Surveillance inMODE 1 or 2 is further amplified to alloW the Su1,rveillaRne to be performedfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing correctiVe maintenance, corrective modification, deficient orincomplete surveillancGe testing, and other unanticipated OPERABI LITYconcerns) provided an assessment determines unit safety is maintainedor enhanced. This assessment shall a a miniMum, consider thepotential ouGtmres ad ets s;oqcSated with a failed SureillaRe, aSuccessful Su.veillance, and a perturbation of the offs.te Or olsite systemwhen they are tied together Or operated independently for the-Sureilane;as well as the operator procedures available to cope withCook Nuclear Plant Unit 2B 3.8.1-27Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)these outcomes. These shall be measured against the aoddrisk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when. the Sur....eil.an.e is performed in MODE 1 or 2. Risk4nsgnis or eRIne!noaS may Be used TOF Mis asses .Credit may be taken for unplanned events that satisfy this SR-. Note M3ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note M3 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.16This Surveillance demonstrates that the diesel engine can restart from ahot condition, such as subsequent to shutdown from normalSurveillances, and achieve the required voltage and frequency within10 seconds. The 10 second time is derived from the requirements of theaccident analysis to respond to a design basis large break LOCA. The24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR is modified by two Notes. Note 1 ensures that the test isperformed with the diesel sufficiently hot. The load ban isprvded toCook Nuclear Plant Unit 2 B 3.8.1-28 Re Nvision No. 41 zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPIPM R One Cook PlaceBridgman, Ml 49106A unit ofAmerican Electric Power IndianaMichiganPower.comDecember 17, 2014 AEP-NRC-2014-7010 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Donald C. Cook Nuclear Plant Unit 1 and Unit 2Docket Nos. 50-315 and 50-316License Amendment Request Regarding Technical Specification Section 3.8.1, "ACSources -Operating," Surveillance Requirements 3.8.1.10, 3.8.1.11, and 3.8.1.15

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. Cook NuclearPlant Unit 1 and Unit 2, proposes to amend the Appendix A Technical Specifications (TS) to FacilityOperating Licenses DPR-58 and DPR-74. I&M proposes to revise the licenses to modify the notesto TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of the onsite standbyemergency diesel generators (DG) during modes in which it is currently prohibited. Specifically,I&M proposes removing the mode restrictions for the following Surveillance Requirements: 3.8.1.10(DG single largest load rejection test), 3.8.1.11 (DG full load rejection test), and 3.8.1.15 (DGendurance run).I&M has evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded thatthey involve no significant hazards consideration.Enclosure 1 to this letter provides an affirmation statement pertaining to the information containedherein. Enclosure 2 provides I&M's evaluation of the proposed TS change. Enclosures 3 and 4provide Unit 1 and Unit 2 TS pages marked to show the proposed changes. Enclosures 5 and 6provide Unit 1 and Unit 2 TS Bases pages marked to show the proposed changes. Bases markupsare included for information only. New clean Unit 1 and Unit 2 TS pages with proposed changesincorporated will be provided to the U. S. Nuclear Regulatory Commission (NRC) Licensing ProjectManager when requested.I&M requests approval of the proposed change in accordance with the NRC's normal review andapproval schedule. The proposed change will be implemented within 90 days of NRC approval.Copies of this letter and its enclosures are being transmitted to the Michigan Public ServiceCommission and Michigan Department of Environmental Quality, in accordance with therequirements of 10 CFR 50.91.AooI U. S. Nuclear Regulatory CommissionPage 2AEP-NRC-2014-70There are no new regulatory commitments made in this letter. Should you have any questions,please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Q. Shane LiesEngineering Vice PresidentJMT/amp

Enclosures:

1.2.AffirmationProposed License Amendment Request Regarding Revision to Technical Specifications3.8.1, "AC Sources -Operating"3. Donald C. Cook Nuclear Plant UnitProposed Changes4. Donald C. Cook Nuclear Plant UnitProposed Changes.5. Donald C. Cook Nuclear Plant UnitShow Proposed Changes.6. Donald C. Cook Nuclear Plant UnitShow Proposed Changes1 Technical Specification Pages Marked To Show2 Technical Specification Pages Marked To Show1 Technical Specification Bases Pages Marked To2 Technical Specification Bases Pages Marked Toc: M. L. Chawla, NRC Washington, D.C.J. T. King -MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC Region IIIA. J. Williamson, AEP Ft. Wayne, w/o enclosures Enclosure I to AEP-NRC-2014-70AFFIRMATIONI, Q. Shane Lies, being duly sworn, state that I am Engineering Vice President of IndianaMichigan Power (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan PowerQ. Shane LiesEngineering Vice PresidentSWORN TO AND SUBSCRIBED BEFORE METHIS \A-.' DAY OF , 2014My CNotareysblicMy Commission Expires c)'-\)- -DANIELLE BURGOYN6Notary Public, State of MichiganCounty of BerrienMy Commission Expires 04--04-2018Acting In the County of 4 to AEP-NRC-2014-70Proposed License Amendment Request RegardingRevision to Technical Specifications 3.8.1, "AC Sources -Operating"1.0 SUMMARY DESCRIPTIONPursuant to 10 CFR 50.90, Indiana Michigan Power (I&M), the licensee for Donald C. CookNuclear Plant (CNP) Unit 1 and Unit 2, proposes to amend the Appendix A TechnicalSpecifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to revisethe licenses to modify TS 3.8.1, "AC Sources -Operating," to allow surveillance testing of theonsite standby emergency diesel generators (EDG) during modes in which it is currentlyprohibited. Specifically, I&M proposes removing the Note that imposes the mode restrictions forthe following Surveillance Requirements (SR): 3.8.1.10 (diesel generator (DG) single largestload rejection surveillance test), 3.8.1.11 (DG full load rejection surveillance test), and 3.8.1.15(DG endurance surveillance test run).2.0 DETAILED DESCRIPTION2.1 Proposed ChangeI&M proposes the following changes in order to eliminate the Mode 1 and 2 Surveillance testingrestrictions for SRs 3.8.1.10, 3.8.1.11, and 3.8.1.15, as discussed above. The changes wouldbe effected by deleting the applicable Note for each surveillance, as follows:2.1.1 Proposed Change to TS SR 3.8.1.10 (DG single largest load reiection surveillancetest)Note 1 in SR 3.8.1.10 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.10 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.2 Proposed Change to TS SR 3.8.1.11 (DG full load reiection surveillance test)Note 1 in SR 3.8.1.11 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed. to AEP-NRC-2014-70Page 2Additionally, compensatory measures for SR 3.8.1.11 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.2.1.3 Proposed Change to TS SR 3.8.1.15 (DG endurance surveillance test run)Note 2 in SR 3.8.1.15 currently states: "This Surveillance shall not normally be performed inMode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITYprovided an assessment determines the safety of the unit is maintained or enhanced. Creditmay be taken for unplanned events that satisfy this SR."For the proposed change to this SR, this Note would be completely removed.Additionally, compensatory measures for SR 3.8.1.15 would be added to the TS Bases, asshown in the TS Bases markup pages in Enclosures 5 and 6 of this letter. The TS baseschanges are for information only and will be implemented under the CNP TS Bases controlprogram.The above changes, if approved, will allow the testing required by these SRs to be performedduring all modes of operation such that the testing will no longer be required to be performedonly during plant outages. This will help to reduce the complexity of coordinating work andtesting activities during refueling outages and allow these activities to be performed online. Thechange will also reduce risk during a refueling outage where the plant is relying on a single trainfor core cooling. This also allows for shorter refueling outage durations which reduces theduration the plant is in an elevated risk condition.The marked-up and revised Unit 1 and Unit 2 TS pages reflecting the above changes areprovided in Enclosures 3 and 4 of this letter, respectively. In addition, the associated Unit 1 andUnit 2 TS Bases will be revised to reflect the changes to these TSs. A marked-up copy of theproposed Unit 1 and Unit 2 TS Bases changes is provided in Enclosures 5 and 6 of this letter,respectively, for information only. The TS Bases changes will be implemented in accordancewith TS 5.5.12, "Technical Specifications (TS) Bases Control Program," as part of theimplementation of this amendment after NRC approval.3.0 BackgroundDescription of Emergency Power SystemAs stated in Updated Final Safety Analysis Report (UFSAR) Section 8.4, "Emergency PowerSystem," the emergency power sources for the two units, including the DGs, are similar and areelectrically and physically isolated from one another. Each unit has two full capacity DGs eachsupplying power to two safety-related 4160 volt (v) buses. Loss of voltage to the 4160v buses issensed by loss of voltage relays. Upon sensing, master relays automatically start the DGs, tripthe normal feed circuit breakers for the 4160v buses, and trip all motor feeder breakers and480v bus transformer feeder breakers on the buses, the 600v bus tie breaker, non-essential600v feeder breakers, and 480v bus breakers. The DG bus input circuit breakers which connect to AEP-NRC-2014-70Page 3the DG output to the 4160/600v bus system are automatically closed when voltage and speedapproach rated values. The DGs supply power to the 600v buses through the 4160v buses andtransformers, respectively.Each DG comes up to speed and is capable of accepting load within 10 seconds. If either DGfails to start, the remaining one is capable of supplying the required engineered safeguard load.A Safety Injection (SI) signal will also start the DGs. To avoid overloading of the DGs, all loadsare shed when the SI occurs and the safety-related 4160v buses are energized from the DGs.The safety loads are subsequently loaded in a sequential manner as required.The DGs are sized at 3500 kilowatts (KW) each to assure available power to operate one trainof safety equipment assuming a loss-of-offsite-power (LOOP) concurrent with a loss-of-coolantaccident with or without containment spray.UFSAR Section 8.1.2, "Functional Criteria," provides functional requirements employed onelectrical systems to achieve maximum reliability and operating efficiency. One of the criteria isthat motor loading does not exceed its nameplate rating.Each diesel engine is a Worthington Type SWB-12, 12 cylinder, heavy duty turbocharged dieselengine, with a continuous rated output of 4900 brake horsepower at 514 revolutions per minute(RPM).Each generator is a General Electric (GE), 4375 kilo volt amps (a), 3500KW at 0.8 power factor,514 RPM, 3-phase, 60-cycle, 4160v, 25 percent (%) voltage regulation, direct engine-drivensynchronous type generator. Each generator is equipped with a GE brushless exciter type 5ARwith a field rated 5.8a and 100v direct current (DC) and, a static voltage regulator with itsassociated potential and sensing transformers.The alternating current (AC) sources are designed to permit inspection and testing of allimportant areas and features, especially those that have a standby function, in accordance withPlant Specific Design Criterion (PSDC) 39. Periodic component tests are supplemented byextensive functional tests during refueling outages (under simulated accident conditions). TheSRs for demonstrating the OPERABILITY of the DGs are in accordance with therecommendations of U. S. Nuclear Regulatory Commission (NRC) Regulatory Guide 1.9,"Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants", andInstitute of Electrical and Electronics Engineers (IEEE) Standard 387-1995 IEEE StandardCriteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear PowerGenerating Stations. to AEP-NRC-2014-70Page

44.0 TECHNICAL EVALUATION

4.1 Changes to SR 3.8.1.10 (DG single largest load rejection surveillance test)4.1.1 Deletion of mode restriction note from SR 3.8.1.10 DG single largest load rejectiontest.The current approach for performance of the load rejection test in SR 3.8.1.10 has been toparallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raise the DG tothe required load, and then open the DG output breaker. Opening of the DG output breakerseparates the DG from its associated safety-related 4160v bus and allows the offsite circuit tocontinue to supply that bus.The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. During testing the diesel being tested isinoperable, but available. This license amendment request (LAR) is proposing that this testingalso be allowed in Mode 1 or 2, when both DGs are required to be operable per TS 3.8.1.The concerns associated with performing the single largest load rejection surveillance test inMode 1 or 2 are that the DG being tested is susceptible to damage caused by grid disturbances,disconnecting the DG while paralleled to the safety-related 4160v buses at 100% rated loadmight cause electrical system perturbations, and the DG in test mode is more susceptible totripping due to the extra protective trip relays that are in effect during test mode operations.4.1.1.1 Grid DisturbancesThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2,while connected to offsite power or generator output, is that the DG is. susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based-on the fact that the remaining DG would remainoperable and is capable of mitigating a Design Based Accident (DBA). The redundant train ofonsite AC power is fully capable of mitigating a DBA or providing for safe shutdown of theassociated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As a common practice at CNP, risk management considerations ensure that this and other SRsare not scheduled during periods where there is increased potential for grid or bus disturbance to AEP-NRC-2014-70Page 5(storms, grid emergencies, etc.). Performance of the single largest load rejection surveillancetest per SR 3.8.1.10, in Mode 1 or 2 is also justified, in part, by the fact that CNP currently testsits DGs paralleled to offsite power or generator output during required monthly surveillancetesting, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with no adverse effect.4.1.1.2 Electrical PerturbationsThe concern of performing the single largest load rejection surveillance test in Mode 1 or 2 isthat suddenly disconnecting a DG from the associated bus on a single largest load rejectionsurveillance test could cause a voltage fluctuation on that bus which could potentially perturbthe onsite AC electrical system. However, industry experience shows that there is no significantelectrical distribution system effect on the associated bus during a single largest load rejectionsurveillance test. Furthermore, at CNP when the single largest load rejection surveillance test isperformed at shutdown, the voltage recovery is within 2 seconds. During this testing there wereno recorded voltage oscillations and the voltage change was a smooth step change, whichwould have no adverse impact on equipment performance. Therefore, performing load rejecttests in accordance with SR 3.8.1.10 in any modes would not cause a significant perturbationthat would adversely affect the onsite AC electrical system.4.1.1.3 Protective Trip RelaysDuring single largest load rejection surveillance testing of DGs while in test mode,non-emergency trip features are in effect to protect the DG from equipment damage due toequipment malfunctions or grid perturbations. If an emergency (ESF and/or LOOP) demandoccurs with these non-emergency trips in effect, the affected DG will automatically revert to theemergency mode and bypass these trips. No operator action is required. Upon detection ofunder voltage on the safety-related 4160v bus, load shedding for all vital loads andnon-permanently connected loads from the 4160v bus would occur followed by re-sequencing ofthe vital loads back onto the affected 4160v bus. The operators receive indication and alarms inthe control room that the preferred power source is lost. In addition, the proposed change doesnot impact voltage regulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the single largest load rejection surveillance test issimilar to the electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DGmonthly surveillance test run), which is performed while in Mode 1.4.2 Changes to SR 3.8.1.11 (DG full load rejection surveillance test)4.2.1 Deletion of mode restriction note from SR 3.8.1.11The current approach for performance of the full load rejection surveillance test in SR 3.8.1.11has been to parallel the DG with offsite power while the reactor is in Mode 5 or 6, manually raisethe DG to the required 100% load, and then open the DG output breaker. Opening of the DGoutput breaker separates the DG from its associated safety-related 4160v bus and allows theoffsite circuit to continue to supply that bus. to AEP-NRC-2014-70Page 6The current surveillance tests are performed in Mode 5 or 6, when only one of the two DGs andsafety-related 4160v buses is required to be operable. Therefore, the current testing processdoes not require the DG and 4160v bus being tested to remain operable. This change requestis proposing that testing also be allowed in Mode 1 or 2, when both DGs are required to beoperable per TS 3.8.1.There are three concerns associated with performing the full load rejection surveillance test inMode 1 or 2. The first concern is that the DG being tested is more susceptible to damagecaused by grid disturbances. Secondly, disconnecting the DG while paralleled to thesafety-related 4160v buses at 100% rated load could cause electrical system perturbations.Finally, the DG in test mode is more susceptible to tripping due to the extra protective trip relaysthat are in effect during test mode operations.4.2.1.1 Grid DisturbancesThe concern of performing the full load rejection surveillance test in Mode 1 or 2, whileconnected to offsite power or generator output, is that the DG is susceptible to griddisturbances. If a fault or power disturbance were to occur while a DG is paralleled to the offsitepower system or generator output in the test mode of operation, the availability of the DG forsubsequent emergency operation could be adversely affected due to the potential for commonmode vulnerability. However, only one DG per unit is paralleled to offsite power or generatoroutput at any one time and any grid disturbances would only possibly affect one DG.Additionally, the TS Bases will be changed as described in Enclosures 5 and 6 to this letter, toprohibit switchyard work during performance of this surveillance. This will minimize thelikelihood of a power disturbance or fault related to switchyard activities. Therefore, thejustification for this proposed change is based on the fact that the remaining DG would remainoperable and is capable of mitigating a DBA. The onsite AC power system is fully capable ofmitigating a DBA or providing for safe shutdown of the associated unit with the remaining DGoperable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action.As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the full load rejectionsurveillance test per SR 3.8.1.11, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while at power, with noadverse effect.4.2.1.2 Electrical PerturbationsThe concern during this testing is that suddenly disconnecting a DG from the associated bus ona full load rejection surveillance test could cause a voltage fluctuation on that bus that couldpotentially perturb the onsite AC electrical system. However, industry experience shows that to AEP-NRC-2014-70Page 7there is no significant electrical distribution system effect on the associated bus during a full loadrejection surveillance test. Therefore, performing full load rejection surveillance tests inaccordance with SR 3.8.1.11 in any modes would not cause a significant perturbation that wouldadversely affect the onsite AC electrical system.4.2.1.3 Protective Trip RelaysDuring full load rejection surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. In addition, the proposed change does not impact voltageregulation and DG governor system operation during surveillance testing.Finally, the proposed test configuration for the full load rejection surveillance test is similar to theelectrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed during Mode 1.4.3 Changes to SR 3.8.1.15 (DG endurance surveillance test run)4.3.1 Deletion of mode restriction note from SR 3.8.1.15The concerns of performing the DG endurance surveillance test run (8-hour load run) requiredby SR 3.8.1.15 in Mode 1 or 2 are the DG being tested is susceptible to grid disturbances andthe additional protective trip features would be in place making the DG more vulnerable to apossible trip while being parallel with the offsite power or generator output source.4.3.1.1 Grid DisturbancesThe concern with performing the endurance run in Mode 1 or 2, while connected to offsite poweror generator output, is that the DG is susceptible to grid disturbances. Only one DG per unit isparalleled to offsite power or generator output at any one time and any grid disturbances wouldonly possibly affect one DG. Therefore, the justification for this proposed change is based onthe fact that the redundant train DG would remain operable and is capable of mitigating a DBA.The onsite AC power system is fully capable of mitigating a DBA or providing for safe shutdownof the associated unit with the remaining DG operable.In the case where a disturbance affects the DG being tested, protective relaying protects the DGfrom equipment damage. This feature causes the DG output breaker to trip, separating the DGfrom its associated safety-related 4160v bus. In the event of a DG protective device trip, the DGcould be restored via operator action. to AEP-NRC-2014-70Page 8As part of the online risk management process at CNP, risk management considerations ensurethat this and other SRs are not scheduled during periods where there is increased potential forgrid or bus disturbance (storms, grid emergencies, etc.). Performance of the endurance runsurveillance test per SR 3.8.1.15, in Mode 1 or 2 is also justified, in part, by the fact that CNPcurrently tests its DGs paralleled to offsite power or generator output during required monthlysurveillance testing, SR 3.8.1.3 (DG monthly surveillance test run), while in Mode 1 or 2.4.3.1.2 Trip RelaysDuring endurance run surveillance testing of DGs while in test mode, non-emergency tripfeatures are in effect to protect the DG from equipment damage due to equipment malfunctionsor grid perturbations. If an emergency (ESF and/or LOOP) demand occurs with thesenon-emergency trips in effect, the affected DG will automatically revert to the emergency modeand bypass these trips. No operator action is required. Upon detection of under voltage on thesafety-related 4160v bus, load shedding for all vital loads and non-permanently connected loadsfrom the 4160v bus would occur followed by re-sequencing of the vital loads back onto theaffected 4160v bus. The operators receive indication and alarms in the control room that thepreferred power source is lost. Therefore, these additional trip functions are not a significantconcern during performance of the DG endurance surveillance test runs while in Mode 1 or 2.In addition, the remaining DG will be available to respond and mitigate a DBA or provide safeshutdown capability.Finally, the proposed test configuration for the DG endurance surveillance test run is similar tothe electrical alignment in the existing monthly run of the EDG per SR 3.8.1.3 (DG monthlysurveillance test run), which is performed while in Mode 1.4.4 Risk assessment for performing DG single largest load rejection surveillance test(SR 3.8.1.10), DG full load reiection surveillance test (SR 3.8.1.11). and DGendurance surveillance test run (3.8.1.15) in Mode I or 2.Currently, when the DG single largest load rejection surveillance test, the DG full load rejectionsurveillance test, and the DG endurance surveillance test run are performed they may beperformed in Mode 5 or 6. When a DG is undergoing any of these three tests it is consideredinoperable but available to respond to design based accidents.Performing these tests in Mode 1 or 2 does not change the potential level of risk during thesetests. As in Modes 5 and 6, the DG is available and capable of performing its safety functions.The determination of availability of the DG in test is consistent with the definition of unavailablein NUMARC 93-01, Revision 4A, Appendix B, which states: "SSCs out of service for testing areconsidered unavailable, unless the test configuration is automatically- overridden by a validstarting signal, or the function can be promptly restored either by an operator in the control roomor by a dedicated operator stationed locally for that purpose. Restoration actions must becontained in a written procedure, must be uncomplicated (a single action or a few simpleactions), and must not require diagnosis or repair...." Per the above discussion, for these teststhe DG in test will remain available per these guidelines. As a result, there is no increase inunavailability of the DG and there is a minimal increase in the risk. to AEP-NRC-2014-70Page 9Also, a review was conducted of DG starts at CNP for the last 10 years (DG starts sinceJanuary 1, 2004) as well as a search of the CNP Corrective Action Program for that same timeperiod. This search included all four DGs (two DGs in Unit 1 and two DGs in Unit 2) and noresults were found of an instance where any starts have caused additional problems to the DGsthemselves, other CNP equipment, or the electrical grid any different regardless of the mode inwhich the DG was actually started.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Reguirements/CriteriaRegulatory RequirementsUFSAR Section 1.4, "Plant Specific Design Criteria (PSDC)", defines the principal criteria andsafety objectives for the CNP design. The following PSDC is relevant to the proposedamendment:"CRITERION 39 Emergency PowerAn emergency power source shall be provided and designed with adequateindependency, redundancy, capacity, and testability to permit the functioning of the ESFand protection systems required to avoid undue risk to the health and safety of thepublic. This power source shall provide this capacity assuming a failure of a single activecomponent."The design of the AC electrical power system provides independence and redundancy toensure an available source of power to the ESF systems. The onsite Class 1 E AC distributionsystem for I&M is divided into two load groups. A safety-related 4160v bus is associated witheach load group. The two load groups are 100% redundant and are electrically and physicallyseparated such that the loss of either group does not prevent the minimum safety functions frombeing performed. Each load group has connections to either of two offsite power sources fromthe switchyard, and a single DG. Offsite power is supplied to the switchyard from thetransmission network via two rights of way approaching the site from two different directions.The proposed changes modify plant condition requirements for the test of the DGs whichprovide emergency power to the safety-related 4160v buses in the event of a LOOP. The testrequirements are intended to verify and/or ensure continued OPERABILITY of the DGs. Theproposed changes involve no changes to the required tests themselves except to allow certaintests to be performed during modes for which performance of the affected tests is currentlyprohibited. Evaluation of the proposed changes has determined that DG availability is notsignificantly affected by the proposed changes, that the potential for significantly adverseelectrical perturbations during tests such as SR 3.8.1.11 (Full-Load Rejection Test) isacceptably low, and that the potential for a grid disturbance causing DG unavailability while aDG is in test is quite low. Further, only one DG will be tested at a time such that OPERABILITYof the redundant train DG and its associated bus and bus loads will be unaffected. Testing willthus continue in a manner that supports redundant train DG OPERABILITY so that both DGs to AEP-NRC-2014-70Page 10will be available to perform their intended safety function consistent with regulatoryrequirements.In conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public.5.2 No Significant Hazards Consideration DeterminationPursuant to 10 CFR 50.90, I&M, the licensee for CNP Unit 1 and Unit 2, proposes to amend theAppendix A TS to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes amendingSR 3.8.1, "AC Sources". I&M has evaluated whether a significant hazards consideration isinvolved with the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of amendment," as discussed below:1. Does the proposed change involve a significant increase in the probability of occurrence orconsequences of an accident previously evaluated?Response: NoThe design of plant equipment is not being modified by the proposed changes. In addition,the DGs and their associated emergency loads are accident mitigating features. As such,testing of the DGs themselves is not associated with any potential accident-initiatingmechanism. Therefore, there will be no significant impact on any accident probabilities bythe approval of the requested changes.The changes include an increase in the time that a DG under test will be paralleled to thegrid while the unit is in Modes 1 or 2. As such, the ability of the tested DG to respond to aDBA could be minimally adversely impacted by the proposed changes. However, theimpacts are not considered significant based, in part, on the ability of the remaining DG tomitigate a DBA or provide safe shutdown. Experience shows that testing for these SRstypically does not perturb the electrical distribution system. In addition, operatingexperience supports the conclusion that the proposed changes do not involve any significantincreases in the likelihood of a safety-related bus blackout or damage to plant loads.Therefore, the proposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.2. Does the proposed change create the possibility of a new or different kind of accident fromany accident previously evaluated?Response: NoThe capability to synchronize a DG to the offsite source (via the associated plant bus) andtest the DG in such a configuration is a design feature of the DGs, including the test modeoverride in response to a safety injection signal. Paralleling the DG for longer periods of to AEP-NRC-2014-70Page 11time during plant operation may slightly increase the probability of incurring an adverseeffect from the offsite source, but this increase in probability is judged to be still quite smalland such a possibility is not a new or previously unrecognized consideration.The proposed change does not introduce a new mode of plant operation and does notinvolve physical modification to the plant. The change does not introduce new accidentinitiators or impact assumptions made in the safety analysis.Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any previously evaluated.3. Does the proposed change involve a significant reduction in a margin of safety?Response: NoThe proposed changes do not exceed or alter a design basis or safety limit, so there is nosignificant reduction in the margin of safety. The margin of safety is related to theconfidence in the ability of the fission product barriers to perform their design functionsduring and following an accident situation. These barriers include the fuel cladding, thereactor coolant system, and the containment system. The proposed changes do not directlyaffect these barriers, nor do they involve any significantly adverse impact on the DGs whichserve to support these barriers in the event of an accident concurrent with a LOOP. Theproposed changes to the testing requirements for the plant DGs do not affect theOPERABILITY requirements for the DGs, as verification of such OPERABILITY will continueto be performed as required (except during different allowed modes). The changes have aninsignificant impact on DG availability, as the DGs remain available to perform their requiredfunction of providing emergency power to plant equipment that supports or constitutes thefission product barriers. Only one DG is to be tested at a time, so that the remaining DG willbe available to safety shut down the plant if required. Consequently, performance of thefission product barriers will not be impacted by implementation of the proposed amendment.In addition, the proposed changes involve no changes to setpoints or limits established orassumed by the accident analysis.Therefore, the proposed change does not involve a significant reduction in a margin ofsafety.Based on the above, I&M concludes that the proposed amendment presents no significanthazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified.5.3 ConclusionIn conclusion, based on the considerations discussed above: (1) there is reasonable assurancethat the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the NRC's regulations, and(3) the issuance of the amendment will not be inimical to the common defense and security or tothe health and safety of the public. to AEP-NRC-2014-70Page 1

26.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement withrespect to installation or use of a facility component located within the restricted area, as definedin 10 CFR 20, or would change an inspection or surveillance requirement. However, theproposed amendment does not involve: (i) a significant hazards consideration, (ii) a significantchange in the types or significant increase in the amounts of any effluent that may be releasedoffsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion setforth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with the proposedamendment.7.0 PRECEDENCE1. Amendment 173 to Columbia Generating Station Operating License (

Subject:

ColumbiaGenerating Station Operating License NPF-21 Request for Technical SpecificationsAmendment to Remove Operating Mode Restrictions for Emergency Diesel GeneratorSurveillance Testing, dated May 18, 2001.)2. Amendment 154 to Wolf Creek Generating Station Operating License (

Subject:

Wolf CreekGenerating Station -Issuance of Amendment RE: Technical Specifications 3.8.1 and 3.8.4-AC and DC Sources, dated July 12, 2004.)3. Amendment 167 to Palo Verde Generating Station Operating License (

Subject:

Palo VerdeNuclear Generating Station, Units 1, 2, and 3- Issuance of Amendments RE: AC Sources -Operating Surveillance Requirements, dated May 16, 2007.

8.0 REFERENCES

1. 10 CFR 50.90, "Application for amendment of license, or construction permit, or early sitepermit"2. 10 CFR 50.36, "Technical Specifications"3. Indiana and Michigan Power D. C. Cook Nuclear Plant Updated Final Safety AnalysisReport, Revision 25 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.10---------------NOTES ---------------1 Thist Su~eiir aR~i~c shall not nermaivh beanr~r~u~ -I ~.. '~ LI......wvp~;IL;;f !R Mn 60FL ASureilanc ma beperformned to reestablishOPERA.BILITY provided an assessmentA-+-rmi.-p fhe- pfh rf +k- .,nw+ 0ý m..r-nt'nnippdk~2, +a 4Ln fnrflfv4. 4. Lý 4-: Ir 4&L-; 0 MHH" RAAA RVAP :R 195.- If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 13.8.1-9Amendment No. 287, 294, 309 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.11--------------NOTES ---------------1. This Surveillance shall not normally beperfoermed in MODE 1 Or 2. However, thisSurveillanGe may be performed to reestablishOPERA\BILITY provided an assessmentdetermines the safety of the unit is maint-ainedor enhanced. Credit may be taken for-i Jl munpiaRneci events that satisry this Si.fI2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-10Amendment No. 27-7, 294, 295 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15------------- NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.I II I II I, ~ ~~~~~ I ue'mglfmIý,. 'I n^ nflrnI n fin I~CW~ ,.. ~ ~ +hiy2Suveilla;nrLe may be nerfOrmed to reestab-lishA I'IP\Ideterl Lmine t fGety of teniimntnine41". .'J .no t1, iai t n i .e v nts that LIthus nR.unclanned e'-ents that satisf'- this SR.If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a load> 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 13.8.1-13Amendment No. 287, 291 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION PAGESMARKED TO SHOW CHANGES AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.8.1.10-------------- NOTES ---------------1 Thic. , cmaI.n~ h',il nr+ nr~n, =11y hoIIf nrnAt ;r RAfll ME ar 1) W-nna#k;hicc.OPERABI LITY provided an assessmentor enhanced. Credit may be taken-forunplanned events that satisfy this SRmE2. If performed with the DG synchronized withoffsite power, it shall be performed at a powerfactor < 0.86. However, if grid conditions donot permit, the power factor limit is not requiredto be met. Under this condition the powerfactor shall be maintained as close to the limitas practicable.Verify each DG rejects a load greater than or equalto its associated single largest post-accident load,and:a. Following load rejection, the frequency is< 64.4 Hz;b. Within 2 seconds following load rejection, thevoltage is > 3910 V and < 4400 V; andc. Within 2 seconds following load rejection, thefrequency is > 59.4 Hz and < 60.5 Hz.24 monthsCook Nuclear Plant Unit 23.8.1-9Amendment No. 269, 27-3, 291 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYSR 3.8.1.11-----------------NOTES ---------------I. This Su'p-eillance shall not normally beperformed in MODE 1 or 2. However, thisSurveillance may be performed to reestablishOPERABI LITY provided an assessmentdetemnines the safety of the unit is maintainedor enhan-ed. Cred-it ma" be taken Gfounplanned events that satisfy this SR.IE2. If performed with DG synchronized with offsitepower, it shall be performed at a power factor< 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG does not trip and voltage ismaintained < 5350 V during and following a loadrejection of > 3150 kW and < 3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-10Amendment No. 2-6-, 2-7-3, 276 AC Sources -Operating3.8.1SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCEFREQUENCYiSR 3.8.1.14---------------NOTE ----------------This Surveillance shall not normally be performed inMODE 1 or 2. However, this Surveillance may beperformed to reestablish OPERABILITY provided anassessment determines the safety of the unit ismaintained or enhanced. Credit may be taken forunplanned events that satisfy this SR.Verify each DG's automatic trips are bypassed onan actual or simulated loss of voltage signal on theemergency bus or an actual or simulated ESFactuation signal except:a. Engine overspeed; andb. Generator differential current.24 monthsSR 3.8.1.15--------------- -NOTES ---------------1. Momentary transients outside the load andpower factor ranges do not invalidate this test.perfo)rmed inMODE 1 Or 2. However, this-Survillncemay be performed to reestablishOPEIR-ABILITY provided an assessmentdetermnines the safety of the un~it is maintained^r anOr~AfraA.+t M-, him +nLkat3 (p)e4m +.'na +~a~ 4k +~ e#+ M fý +hk e Q DIurip Or1riv vvvri CY Ct VC1 0 0E3-. If performed with DG synchronized with offsitepower, it shall be performed at a power factor5 0.86. However, if grid conditions do notpermit, the power factor limit is not required tobe met. Under this condition the power factorshall be maintained as close to the limit aspracticable.Verify each DG operates for > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at a load> 3150 kW and <3500 kW.24 monthsCook Nuclear Plant Unit 23.8.1-13Amendment No. 2-69, 273 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 1 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)

AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)b. Tripping its associated single largest post-accident load with the DGsolely supplying the bus.Consistent with Regulatory Guide 1.9 (Ref. 3), the load rejection test isacceptable if the increase in diesel speed does not exceed 75% of thedifference between synchronous speed and the overspeed trip setpoint,or 15% above nominal speed, whichever is lower. This corresponds to64.4 Hz, which is the nominal speed plus 75% of the difference betweennominal speed and the overspeed trip setpoint.The time, voltage, and frequency tolerances specified in this SR arederived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.1O.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.This SR is modified by two Notes. The reason for Note 1 is that duringoperation with the reactor critical, performnance of this SR could causeperturbations to the electrical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems.This f rm Rormally performing the Surveillance in MODE 1 or 2is fu'e amplified to allow the Surveillance to be performned for thepurpose Of reestablishing OPERABILITY (e.g., post work testing fooIwInIgcorrective mnaintenance, correctiVe modification, deficient Or incompletesur-ve*ilance testing, and other un;anipae 0-PEABILITY concerns)provided an assessm.en unit saft is maintained G.enhanced. This assessm~ent shall, as a minimum, consider the potentialoutcom~es and transients associated with a failed Surveillance_,asuccessful SuIveillance, and a perturbation of the offsite Or onsite systemwhen they are tied together or operated idpnetyfor theas well as the peratoFr prroedures available to cope Withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to det6rMinP that uIt IRsafety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Cook Nuclear Plant Unit 1 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Credit may be taken foar unplanned events that satisfy this SR. Creditmnay be taken for unplanned events that satisfy this SR.Note 2-]N ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of S 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note 2N allows the Surveillance to be conducted ata power factor other than < 0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfactor to < 0.86 results in voltages on the emergency busses that are toohigh. Under these conditions, the power factor should be maintained asclose as practicable to 0.86 while still maintaining acceptable voltagelimits on the emergency busses. In other circumstances, the grid voltagemay be such that the DG excitation levels needed to obtain a powerfactor of 0.86 may not cause unacceptable voltages on the emergencybusses, but the excitation levels are in excess of those recommended forthe DG. In such cases, the power factor shall be maintained as close aspracticable to 0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forCook Nuclear Plant Unit 1 B 3.8.1-22 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1future application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has been modified by two Notes. The reason Note 1 is thatduring operation with the reactor critical, performance of this SR couldCook Nuclear Plant Unit I B 3.8.1-23 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)challenge continued steady ,tate operation and, as a result, unit safetsystems. This restriction from normally performing the Sur'veillance iv,,-,,-Ifor the pur.poe Of PER.BI LITY (e.g., post work testingfollowing corrective maintenance, corrective mmdification, deficient o ninGomplete surhvn IeillaesiRg, and othe runRantficipated OPERABILITYconcerns) provided an assessment determines unit safety is maintainedor enrhaned. This assessmenrt shall, as a minimumo, conider thepotertial outonmes and transierts assciated with a failed Surveillance, asuccessful Suveillance, and a perturbeation of the offsite or onsite systemowhen they are tied together oe operated independertly for theSuhveillaNce; as well as the operator procedures available to cope withthese outconmes. These shall be measured against the avoided risk of aunit shutdown and startup to determnine that unit safety is mnaintained orenhanced when the Surveillance is perftorned in MODE 1 or 2. RiskinRsights OrFeemnsi methods mnay be used for this assessment.redit may bee taken forg unplanned events that satisfy this SR. Note 2Fihensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of 5 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note ORj allows the Surveillance to be conducted at a powerfactor other than 5 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to<ay0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.Cook Nuclear Plant Unit 1 B 3.8.1-24 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-24Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)restriction from normally performing the Surveillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purposeof reestablishing OPERABILITY (e.g., post work testing followingcorrective maintenance, corrective modification, deficient or incompletesurveillance testing, and other unanticipated OPERABILITY concerns)provided an assessment determines unit safety is maintained orenhanced. This assessment shall, as a minimum, consider the potentialoutcomes and transients associated with a failed Surveillance, asuccessful Surveillance, and a perturbation of the offsite or onsite systemwhen they are tied together or operated independently for theSurveillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when the Surveillance is performed in MODE 1 or 2. Riskinsights or deterministic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The run duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by Frh Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate thistest. Similarly, momentary power factor transients above the power factorlimit will not invalidate the test. The reason for Note 2 is that duringoperation with the reactor critical, perfrmance of this Sue..illance could.,cause perturbations to the electrical distribution systems that couldchallenge conAtinlued steady 6tate operation and, as a result, unit safetysystemns. This restriction fromn noarmally performing the Surveillancc inCook Nuclear Plant Unit 1B 3.8.1-29Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)hA DF= I Cjr ') ffig fiir+kpr p lofipt4 +^ pllpjAg thp S;i impmIlpriga +a him niarfnpmadII ,,,,.,.." .... ........l r hfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing corrective mnaintenance, corrective modification, deficient orincomplete sun eillanTe testing, and other unaRticipated OPERABILITYconcerns) provided an assessment determines unit safety is maiintainA.edaor enhanced. This assessment shall, as a mnimumn, consider thepotential outcomes and transients associated with failed SRmveillane, -asuccesfulSurveillance, and a perturbaptine of the offfsite or onsite systemwhen they are tied together or operated idpnetyfor theSurveillance; as well as the operator procedures available to cope withthese outcomnes. These shall be mneasured against the -avofided risk of aunit shutdown and startup to determnine that unit safety is mnaintained OFenhanced when the Surveillance is performned in MODE 1 or 2. Riska R~ioht5 or dteF in~tir- Mothnir;Fnay be h used for thus assesmentCredit may be taken for unplanned that satisfy this SR.. Note.. 12ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note P21233 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as closeas practicable to 0.86 while still maintaining acceptable voltage limits onthe emergency busses. In other circumstances, the grid voltage may besuch that the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a riskassessment shall be performed to determine that plant safety ismaintained. As part of this assessment weather conditions will beassessed, and the SR will not be scheduled when severe weatherconditions and/or unstable grid conditions are predicted or present. Also,no discretionary maintenance activities will be scheduled which couldcause a line outage or challenge offsite power availability. Additionally,no switchyard activities will be allowed during the performance of thissurveillance.SR 3.8.1.16Cook Nuclear Plant Unit 1 B 3.8.1-30 Revision No. 41Cook Nuclear Plant Unit 1B 3.8.1-30Revision No. 41 to AEP-NRC-2014-70DONALD C. COOK NUCLEAR PLANT UNIT 2 TECHNICAL SPECIFICATION BASES PAGESMARKED TO SHOW CHANGES(INFORMATIONAL)

AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)derived from Regulatory Guide 1.9 (Ref. 3) recommendations forresponse during load sequence intervals. The 2 seconds specified isequal to approximately 60% of the 3.49 second load sequence intervalassociated with sequencing of the largest load. The voltage andfrequency specified are consistent with the design range of the equipmentpowered by the DG. SR 3.8.1.10.a corresponds to the maximumfrequency excursion, while SR 3.8.1.10.b and SR 3.8.1.10.c are steadystate voltage and frequency values to which the system must recoverfollowing load rejection. The 24 month Frequency is based onengineering judgement, taking into consideration unit conditions requiredto perform the Surveillance. Operating experience has shown that thesecomponents usually pass the SR when performed at the 24 monthFrequency. Therefore, the Frequency was concluded to be acceptablefrom a reliability standpoint.Thir SR is modified by two .ntes. The reason for Note 1 is that duringoperation with the reac.to critical, peFor.mance of this SR could causeperturbations to the e ical distribution systems that could challengecontinued steady state operation and, as a result, unit safety systems. This,restriction from normally perfo~rming the Survefillance in MODE 1 or 2 isfurther amplified to allow the Surveillance to be performed for the purpose-of reestablishing OPERA~BILITY (e'g., post work testing followingcorrective main~tenance, corri-rectivemoifiaton deficient Or incompletesurveillance testfing, and Other u-nanticipated OPERABILITY concerns)enhanced. This assessment shall, astadminimum, consider the potentialoutcomes and transients associated ith a fpaile.d SuWh eilnchronzed, a-successful Supreillanre, anda perti ation of the onduite onsite systemwhen they aro tied together or operated inenddetntl for theSurveillance; as well as the operator procedures avalilableA to- cope withthese outcomnes. These shall be measured against the avoided risk of aunit shutdown and startup to determ~ine that unit safety is mnaintained orenhadned wher the Surveillance is performed in MODE 1 or 2. Riski nsights or determfinistic methods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Creditma" be taken for unplanned eventS that satisfy this SR.Note F1j2 ensures that the DG is tested under load conditions that are asclose to design basis conditions as possible. When synchronized withoffsite power, testing should be performed at a power factor of 5 0.86.This power factor is representative of the actual inductive loading a DGwould see under design basis accident conditions. Under certainconditions, however, Note rlj!2 allows the Surveillance to be conducted ata power factor other than -0.86. These conditions occur when gridvoltage is high, and the additional field excitation needed to get the powerfertfnr < n RR raci nlfQ in \,nlri n nn thp Pmmsrnr-nr% hi nQ=P thnt nrm fnnCook Nuclear Plant Unit 2 B 3.8.1-21 Revision No. 41Cook Nuclear Plant Unit 2B 3.8.1-21Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.11Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.8, thisSurveillance demonstrates the DG capability to reject a full load (90% to100% of the DG continuous rating) without overspeed tripping orexceeding the predetermined voltage limits. The DG full load rejectionmay occur because of a system fault or inadvertent breaker tripping. ThisSurveillance ensures proper engine generator load response under thesimulated test conditions. This test simulates the loss of the totalconnected load that the DG experiences following a full load rejection andverifies that the DG does not trip upon loss of the load. Theseacceptance criteria provide for DG damage protection. While the DG isnot expected to experience this transient during an event and continuesto be available, this response ensures that the DG is not degraded forfuture application, including reconnection to the bus if the trip initiator canbe corrected or isolated.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR has, been Modified by two Notes. The resn for Note 1 is thatduring operation with the reactor critical, performance of this SR couldcause perturbation to the electrical distribu1tion systems6 that colGhallenqe continued- steady state opeation and, as a result, unit safetyCook Nuclear Plant Unit 2B 3.8.1-22Revision No. 41 AC Sources -OperatingB 3.8.1systems. T-his restriction fromn normally pedorm~ing the Surveillance inMODE 1 Or 2 is fudther amplified to allow the Surveillance to be perfrmedfor the purpose of reestablishing OPERABILITY (e.g., post work testiRgfollowing corrective mnaintenance, co~rrective moedification, deficient orincGomplete surveillance testing, and other unanticipated OPERABILITYconcerns) provided an assessment d~eterm~ines unit safety is Maintainedo-r enhanc~ed. This assess6ment shall, as a minimum, consider thepotential ou1tcomes and transients associated with a failed Surveillance, asuccessfiul and a pedIurbationof the offsite or onsito systemvR ter irey aIr Lieu tn!eTrlIC at U-JCILC irnuependuenrtly i9 te-Cook Nuclear Plant Unit 2B 3.8.1-23Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)Survleillance; as well as the operator procedures available to cope withthese outcomes. These shall be measured against the avoided risk of aunit shutdown andstartup to deter;ine that unit safety is maintained erenhan-edd When the Suirveillance is performned On MODE 1 or 2. Riskins~ights or determn~iistic methods m;ay be used for this assessment.Credit may be taken for unplanned events that satisfy this SR. Note F120ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note N allows the Surveillance to be conducted at a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factor to< 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86 maynot cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained as close as practicable to0.86 without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8*1.12Consistent with Regulatory Guide 1.9 (Ref. 3), paragraph C.2.2.4, thisSurveillance demonstrates the as designed operation of the standbypower sources during loss of the offsite source. This test verifies allactions encountered from the loss of offsite power, including shedding ofthe nonessential loads and energization of the emergency buses andrespective loads from the DG. It further demonstrates the capability ofthe DG to automatically achieve the required voltag'e and frequency withinthe specified time.The DG autostart time of 10 seconds is derived from requirements of theenI aaly58 W rOesp1 Mo a *laeSgll I2 1asi 1a-I e I reaK t, U ,. I MeCook Nuclear Plant Unit 2 B 3.8.1-24 Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)as well as the operator procedures available to cope with these outcomes.These shall be measured against the avoided risk of a unit shutdown andstartup to determine that unit safety is maintained or enhanced when theSurveillance is performed in MODE 1 or 2. Risk insights or deterministicmethods may be used for this assessment.Credit may be taken for unplanned events that satisfy this SR.SR 3.8.1.15This Surveillance demonstrates the DGs can start and run continuously atfull load capability (90% to 100% of the DG continuous rating) for aninterval of not less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The run duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is consistentwith IEEE Standard 387-1995 (Ref. 11). The DG starts for thisSurveillance can be performed either from standby or hot conditions. Theprovisions for prelubricating and warmup, discussed in SR 3.8.1.2, andfor gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.The load band is provided to avoid routine overloading of the DG.Routine overloading may result in more frequent teardown inspectionsbeing required in order to maintain DG reliability.The 24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This Surveillance is modified by e Notes. Note 1 states thatmomentary transients due to changing bus loads do not invalidate this test.Similarly, momentary power factor transients above the power factor limitwill not invalidate the test. The reason for Note 2 is that during operationwith the reactor critical, performance of this Surveillance couild causeperturbationS to the electrical distribution systems that ceuld challengecontinued steady state operation and, as a result, unit safety systems.This restriction from normally performing the Surveillance inMODE 1 or 2 is further amplified to alloW the Su1,rveillaRne to be performedfor the purpose of reestablishing OPERA.BILITY (e.g., post work testingfollowing correctiVe maintenance, corrective modification, deficient orincomplete surveillancGe testing, and other unanticipated OPERABI LITYconcerns) provided an assessment determines unit safety is maintainedor enhanced. This assessment shall a a miniMum, consider thepotential ouGtmres ad ets s;oqcSated with a failed SureillaRe, aSuccessful Su.veillance, and a perturbation of the offs.te Or olsite systemwhen they are tied together Or operated independently for the-Sureilane;as well as the operator procedures available to cope withCook Nuclear Plant Unit 2B 3.8.1-27Revision No. 41 AC Sources -OperatingB 3.8.1BASESSURVEILLANCE REQUIREMENTS (continued)these outcomes. These shall be measured against the aoddrisk of aunit shutdown and startup to determine that unit safety is maintained orenhanced when. the Sur....eil.an.e is performed in MODE 1 or 2. Risk4nsgnis or eRIne!noaS may Be used TOF Mis asses .Credit may be taken for unplanned events that satisfy this SR-. Note M3ensures that the DG is tested under load conditions that are as close todesign basis conditions as possible. When synchronized with offsitepower, testing should be performed at a power factor of < 0.86. Thispower factor is representative of the actual inductive loading a DG wouldsee under design basis accident conditions. Under certain conditions,however, Note M3 allows the Surveillance to be conducted as a powerfactor other than < 0.86. These conditions occur when grid voltage ishigh, and the additional field excitation needed to get the power factorto < 0.86 results in voltages on the emergency busses that are too high.Under these conditions, the power factor should be maintained as close aspracticable to 0.86 while still maintaining acceptable voltage limits on theemergency busses. In other circumstances, the grid voltage may be suchthat the DG excitation levels needed to obtain a power factor of 0.86may not cause unacceptable voltages on the emergency busses, but theexcitation levels are in excess of those recommended for the DG. In suchcases, the power factor shall be maintained close as practicable to 0.86without exceeding the DG excitation limits.Prior to the performance of this Surveillance in MODE 1 or 2 a risk assessmentshall be performed to determine that plant safety is maintained. As part of thisassessment weather conditions will be assessed, and the SR will not be scheduledwhen severe weather conditions and/or unstable grid conditions are predicted orpresent. Also, no discretionary maintenance activities will be scheduled whichcould cause a line outage or challenge offsite power availability. Additionally, noswitchyard activities will be allowed during the performance of this surveillance.SR 3.8.1.16This Surveillance demonstrates that the diesel engine can restart from ahot condition, such as subsequent to shutdown from normalSurveillances, and achieve the required voltage and frequency within10 seconds. The 10 second time is derived from the requirements of theaccident analysis to respond to a design basis large break LOCA. The24 month Frequency is based on engineering judgement, taking intoconsideration unit conditions required to perform the Surveillance.Operating experience has shown that these components usually pass theSR when performed at the 24 month Frequency. Therefore, theFrequency was concluded to be acceptable from a reliability standpoint.This SR is modified by two Notes. Note 1 ensures that the test isperformed with the diesel sufficiently hot. The load ban isprvded toCook Nuclear Plant Unit 2 B 3.8.1-28 Re Nvision No. 41

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