ML19031B966

Issuance of Amendments 344, 326 Regarding Request to Adopt TSTF-529, Revision 4, Clarify Use and Application Rules

ML19031B966
Person / Time
Site:	Cook
Issue date:	04/10/2019
From:	Sujata Goetz Plant Licensing Branch III
To:	Gebbie J P Indiana Michigan Power Co
S. Goetz, NRR/DORL/LPL3, 415-8004
References
EPID L-2018-LLA-0124
Download: ML19031B966 (45)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C. 20555-0001 Mr. Joel P. Gebbie Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106 April 10, 2019

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 -ISSUANCE OF AMENDMENTS 344 AND 326 REGARDING REQUEST TO ADOPT TSTF-529, REVISION 4, "CLARIFY USE AND APPLICATION RULES" (EPID L-2018-LLA-0124)

Dear Mr. Gebbie:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 344 to Renewed Facility Operating License No. DPR-58 and Amendment No. 326 to Renewed Facility Operating License No. DPR-74 for the Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2, respectively.

The amendments are in response to your application dated May 4, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 18129A219).

The amendments revised and clarified the technical specification usage rules for completion times, limiting conditions for operation, and surveillance requirements based on Technical Specification Task Force (TSTF) Traveler TSTF-529, "Clarify Use and Application Rules," Revision 4 (ADAMS Package Accession No. ML 16060A441

). A copy of the related safety evaluation is also enclosed.

A Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Sincerely, oetz, Project ana r icensing Br

• Ill Division of Opera

• g Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosures:

1. Amendment No. 344 to DPR-58 2. Amendment No. 326 to DPR-74 3. Safety Evaluation cc: Listserv UNITED STATES NUCLEAR REGULATORY COMMISSION WASH I NGTON , D.C. 20555-0001 INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-315 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 344 License No. DPR-58 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Indiana Michigan Power Company (the licensee), dated May 4, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations ( 10 CFR), Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

• The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission

's regulations and all applicable requirements have been satisfied.

2. Accordingly, paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-58 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 344, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Enclosure 1 3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

Attachment:

FOR THE NUCLEAR REGULATORY COMMISSION D Q~a.£ie~ '--Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance:

A pril 1 o, 201 9 ATTACHMENT TO LICENSE AMENDMENT NO. 344 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-58 DOCKET NO. 50-315 Replace the following page of the Renewed Facility Operating License DPR-58 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. REMOVE INSERT Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. 1.3-1 1.3-2 1.3-3 1.3-4 1.3-5 1.3-6 1.3-7 1.3-8 1.3-9 1.3-10 3.0-1 3.0-4 1.3-1 1.3-2 1.3-3 1.3-4 1.3-5 1.3-6 1.3-7 1.3-8 1.3-9 1.3-10 3.0-1 3.0-4 ( and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30 , 40 and 70 , to receive, possess and use in amounts as required any byproduct , source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess , but not separate , such byproduct and special nuclear materials as may be produced by the operation of the facility. C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30 , Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3304 megawatts thermal in accordance with the conditions specified herein. (2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B , as revised through Amendment No. 344 , are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Less than Four Loop Operation The licensee shall not operate the reactor at power levels above P-7 (as defined in Table 3.3.1-1 of Specification 3.3.1 of Appendix A to this renewed operating license) with less than four reactor coolant loops in operation until (a) safety analyses for less than four loop operation have been submitted , and (b) approval for less than four loop operation at power levels above P-7 has been granted by the Commission by amendment of this license. (4) Fire Protection Program Indiana Michigan Power Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 1 O CFR 50.48(c), as specified in the licensee's amendment request dated July 1 , 2011 , as supplemented by letters dated September 2 , 2011 , April 27 , 2012 , June 29 , 2012 , August 9, 2012 , October 15 , 2012 , November 9 , 2012 , January 14 , 2013 , February 1, 2013 , Renewed License No. DPR-58 AmendmentNo

~.~.32+.~.~.330.~.~.~.~.33e.~.~.J43., 344 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION The purpose of this section is to establish the Completion Time convention and to provide guidance for its use. Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s). The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources -Operating," Required Action 8.3, requires declaring required features(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable.

The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Cook Nuclear Plant Unit 1 1.3-1 Amendment No. 237, 344 1.3 Completion Times DESCRIPTION (continued)

Completion Times 1.3 Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either: a. The stated Completion Time , as measured from the initial entry into the Condition , plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or b. The stated Completion Time as measured from discovery of the subsequent inoperability. The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry.

These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery

... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

Cook Nuclear Plant Unit 1 1.3-2 Amendment No. 28-7, 344 Completion Times 1.3 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered. The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Cook Nuclear Plant Unit 1 1.3-3 Amendment No. 287 , 344 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION A. One pump inoperable.

B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Restore pump to OPERABLE status. 8.1 Be in MODE3. AND 8.2 Be in MODE 5. Completion Times 1.3 COMPLETION TIME 7 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours When a pump is declared inoperable, Condition A is entered. If the pump is not restored to OPERABLE status within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions 8.1 and 8.2 start. If the inoperable pump is restored to OPERABLE status after Condition Bis entered, Conditions A and Bare exited , and therefore , the Required Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump is still inoperable , Condition A is not re-entered for the second pump. LCO 3.0.3 is entered, since the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered , but continues to be tracked from the time Condition A was initially entered. While in LCO 3.0.3 , if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired , LCO 3.0.3 may be exited and operation continued in accordance with Condition A. While in LCO 3.0.3 , if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired. On restoring one of the pumps to OPERABLE status, the Condition A Completion Time is not reset , but continues from the time the first pump Cook Nuclear Plant Unit 1 1.3-4 Amendment No. 237 , 344 1.3 Completion Times EXAMPLES (continued)

Completion Times 1.3 was declared inoperable.

This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days. EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to OPERABLE train status. AND inoperable.

10 days from discovery of failure to meet the LCO . B. One B.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to OPERABLE train status. AND

• inoperable.

10 days from discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X train to OPERABLE train status. inoperable.

OR AND C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> One train to OPERABLE Function Y status. train inoperable.

Cook Nuclear Plant Unit 1 1.3-5 Amendment No. ~. 344 1.3 Completion Times EXAMPLES (continued)

Completion Times 1.3 When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable.

The Completion Times for Condition A and Condition Bare tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train WpS declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time , Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A). The Completion Times of Conditions A and B are modified by a logical connector with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B , and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered. Cook Nuclear Plant Unit 1 1.3-6 Amendment No. 237, 344 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-4 ACTIONS CONDITION A. One or more valves inoperable.

B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Restore valve(s) to OPERABLE status. 8.1 Be in MODE 3. AND 8.2 Be in MODE 4. Completion Times 1.3 COMPLETION TIME 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 6 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable , while Condition A is still in effect, does not trigger the tracking of separate Completion Times. Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset , but continues from the time the first valve was declared inoperable. The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (including the extension) expires while one or more valves are still inoperable , Condition B is entered. Cook Nuclear Plant Unit 1 1.3-7 Amendment No. 287, 344 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-5 ACTIONS Completion Times 1.3 ---------------. --------NOTE ----. --------------------

Separate Condition entry is allowed for each inoperable valve. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status. inoperable.

B. Required B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition , the Note would appear in that Condition rather than at the top of the ACTIONS Table. The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis. When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve. If the Completion Time associated with a valve in Condition A expires , Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire , Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status , Condition Bis exited for that valve. Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply. Cook Nuclear Plant Unit 1 1.3-8 Amendment No. 237 , 344 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-6 ACTIONS CONDITION A. One channel inoperable.

B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Perform SR 3.x.x.x. OR A.2 Reduce THERMAL POWER to s 50% RTP. 8.1 Be in MODE 3. Completion Times 1.3 COMPLETION TIME Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance.

The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval.

If Required Action A.1 is followed, and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2), Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met, Condition B is entered. If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A. Cook Nuclear Plant Unit 1 1.3-9 Amendment No. 237, 344 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-7 ACTIONS CONDITION A. One subsystem inoperable. B. Required Action and associated Completion Time not met. . REQUIRED ACTION A.1 Verify affected subsystem isolated.

AND A.2 Restore subsystem to OPERABLE status. B.1 Be in MODE 3. AND B.2 Be in MODE 5. Completion Times 1.3 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" interval begins upon performance of Required Action A.1. If after Condition A is entered , Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A , provided the Completion Time for Required Action A.2 has not expired. IMMEDIATE When "Immediately" is used as a Completion Time, The Required Action COMPLETION TIME should be pursued without delay and in a controlled manner. Cook Nuclear Plant Unit 1 1.3-10 Amendment No. 2:37 , 344 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 LCOs shall be met during the MODES or other specified conditions in the Applicability , except as provided in LCO 3.0.2 , LCO 3.0.7 , and LCO 3.0.8. Upon discovery of a failure to meet an LCO , the Required Actions of the associated Conditions shall be met , except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. When an LCO is not met and the associated ACTIONS are not met , an associated ACTION is not provided , or if directed by the associated ACTIONS , the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit , as applicable , in: a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1 , 2 , 3 , and 4. When an LCO is not met , entry into a MODE or other specified condition in the Applicability shall only be made: a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b. After performance of a risk assessment addressing inoperable systems and components , consideration of the results , determination of the acceptability of entering the MODE or other specified condition in the Applicability , and establishment of risk management actions , if appropriate (exceptions to this Specification are stated in the individual Specifications)

or Cook Nuclear Plant Unit 1 3.0-1 Amendment No. 2-37 , ~. 344 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 SR 3.0.4 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs , unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once ," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per ... " basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a Surveillance was not performed within its specified Frequency , then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery , up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency , whichever is greater. This delay period is permitted to allow performance of the Surveillance.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met , and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency , except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met , entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. Cook Nuclear Plant Unit 1 3.0-4 Amendment No. 237, ~. 344 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C. 20555-0001 INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-316 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 326 License No. DPR-74 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Indiana Michigan Power Company (the licensee), dated May 4, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR), Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act , and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-74 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 326, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. Enclosure 2 3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

Attachment:

FOR THE NUCLEAR REGULATORY COMMISSION D~~n x hie 1~ Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: .Apr i 1 1 O, 2 O 1 9 ATTACHMENT TO LICENSE AMENDMENT NO. 326 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-74 DOCKET NO. 50-316 Replace the following page of the Renewed Facility Operating License DPR-74 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. REMOVE INSERT Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

• 1.3-1 1.3-2 1.3-3 1.3-4 1.3-5 1.3-6 1.3-7 1.3-8 1.3-9 1.3-10 3.0-1 3.0-4 1.3-1 1.3-2 1.3-3 1.3-4 1.3-5 1.3-6 1.3-7 1.3-8 1.3-9 1.3-10 3.0-1 3.0-4 radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30 and 70 , to possess , but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50 , and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3468 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to the renewed operating license. The preoperational tests, startup tests and other items identified in Attachment 1 to this renewed operating license shall be completed.

Attachment 1 is an integral part of this renewed operating license. (2) Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B , as revised through Amendment No. 326, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan. (3) Additional Conditions (a) Deleted by Amendment No. 76 (b) Deleted by Amendment No. 2 (c) Leak Testing of Emergency Core Cooling System Valves Indiana Michigan Power Company shall prior to completion of the first inservice testing interval leak test each of the two valves in series in the Renewed License No. DPR-74 Amendment No., 300,307 , ~. J.4-0 , 344 , 342-, J4.3, 344 , 34-9, 34-7 , 343, 34-B, ~. 325, 326 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTIOt;J The purpose of this section is to establish the Completion Time convention

.and to provide guidance for its use. Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s). The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources -Operating," Required Action B.3, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable.

The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability. If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Cook Nuclear Plant Unit 2 1.3-1 Amendment No. 299, 326 1.3 Completion Times DESCRIPTION (continued)

Completion Times 1.3 Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability

a. Must exist concurrent with the first inoperability; and b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either: a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry.

These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery

... " Example 1.3-3 illustrates one use of this type of Completion Time. The 10 day Completion Time specified for Conditions A and B in Example 1.3-3 may not be extended.

Cook Nuclear Plant Unit 2 1.3-2 Amendment No. ~. 326 Completion Times 1.3 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION B. Required Action and associated Completion Time not met. REQUIRED ACTION COMPLETION TIME B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered. The Required Actions of Condition B are to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> AND in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is allowed for reaching MODE 3 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) is allowed for reaching MODE 5 from the time that Condition B was entered. If MODE 3 is reached within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> , the time allowed for reaching MODE 5 is the next 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> because the total time allowed for reaching MODE 5 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If Condition B is entered while in MODE 3, the time allowed for reaching MODE 5 is the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Cook Nuclear Plant Unit 2 1.3-3 Amendment No. 269, 326 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION A. One pump inoperable. B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Restore pump to OPERABLE status. B.1 Be in MODE 3. AND B.2 Be in MODE 5. Completion Times 1.3 COMPLETION TIME 7 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours When a pump is declared inoperable , Condition A is entered. If the pump is not restored to OPERABLE status within 7 days , Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the inoperable pump is restored to OPERABLE status after Condition Bis entered, Conditions A and Bare exited , and therefore, the Required Actions of Condition B may be terminated.

When a second pump is declared inoperable while the first pump is still inoperable , Condition A is not re-entered for the second pump. LCO 3.0.3 is entered , s i nce the ACTIONS do not include a Condition for more than one inoperable pump. The Completion Time clock for Condition A does not stop after LCO 3.0.3 is entered , but continues to be tracked from the time Condition A was initially entered. While in LCO 3.0.3 , if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has not expired , LCO 3.0.3 may be exited and operation continued in accordance with Condition A. While in LCO 3.0.3 , if one of the inoperable pumps is restored to OPERABLE status and the Completion Time for Condition A has expired, LCO 3.0.3 may be exited and operation continued in accordance with Condition B. The Completion Time for Condition B is tracked from the time the Condition A Completion Time expired. Cook Nuclear Plant Unit 2 1.3-4 Amendment No. ~. 326 1.3 Completion Times EXAMPLES (continued)

Completion Times 1.3 On restoring one of the pumps to 9PERABLE status, the Condition A Completion Time is not reset, but continues from the time the first pump was declared inoperable.

This Completion Time may be extended if the pump restored to OPERABLE status was the first inoperable pump. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> extension to the stated 7 days is allowed, provided this does not result in the second pump being inoperable for > 7 days. EXAMPLE 1.3-3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One A.1 Restore Function X 7 days Function X train to OPERABLE train status. AND inoperable.

10 days from discovery of failure to meet the LCO B. One 8.1 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function Y train to OPERABLE train status. AND inoperable.

10 days from discovery of failure to meet the LCO C. One C.1 Restore Function X 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Function X train to OPERABLE train status. inoperable. OR AND C.2 Restore Function Y 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> One train to OPERABLE Function Y status. train inoperable. Cook Nuclear Plant Unit 2 1.3-5 Amendment No. ~. 326 1.3 Completion Times EXAMPLES (continued)

Completion Times 1.3 When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable.

The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (i.e., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions B and C are exited. If the Completion Time for Required Action A.1 has not expired, operation may continue in accordance with Condition A. The remaining Completion Time in Condition A is measured from the time the affected train was declared inoperable (i.e., initial entry into Condition A). The Completion Times of Conditions A and B are modified by a logical connector with a separate 10 day Completion Time measured from the time it was discovered the LCO was not met. In this example, without the separate Completion Time, it would be possible to alternate between Conditions A, B , and C in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO. The separate Completion Time modified by the phrase "from discovery of failure to meet the LCO" is designed to prevent indefinite continued operation while not meeting the LCO. This Completion Time allows for an exception to the normal "time zero" for beginning the Completion Time "clock." In this instance, the Completion Time "time zero" is specified as commencing at the time the LCO was initially not met, instead of at the time the associated Condition was entered. Cook Nuclear Plant Unit 2 1.3-6 Amendment No. 299, 326 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-4 ACTIONS CONDITION A. One or more valves inoperable.

B. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Restore valve(s) to OPERABLE status. B.1 Be in MODE 3. AND B.2 Be in MODE 4. Completion Times 1.3 COMPLETION TIME 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 6 hours 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A single Completion Time is used for any number of valves inoperable at the same time. The Completion Time associated with Condition A is based on the initial entry into Condition A and is not tracked on a per valve basis. Declaring subsequent valves inoperable, while Condition A is still in effect, does not trigger the tracking of separate Completion Times. Once one of the valves has been restored to OPERABLE status, the Condition A Completion Time is not reset, but continues from the time the first valve was declared inoperable.

The Completion Time may be extended if the valve restored to OPERABLE status was the first inoperable valve. The Condition A Completion Time may be extended for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provided this does not result in any subsequent valve being inoperable for > 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If the Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (including the extension) expires while one or more valves are still inoperable , Condition B is entered. Cook Nuclear Plant Unit 2 1.3-7 Amendment No. ~. 326 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-5 ACTIONS Completion Times 1.3 --~--~--~-------~--~~-~-~-~-~-~-NOTE--~--~----~-~-~-~-~-~--~~--~---

Separate Condition entry is allowed for each inoperable valve. CONDITION REQUIRED ACTION COMPLETION TIME , , A. One or more A.1 Restore valve to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> valves OPERABLE status. inoperable.

B. Required 8.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and associated AND Completion Time not met. 8.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table. The Note allows Condition A to be entered separately for each inoperable valve, and Completion Times tracked on a per valve basis. When a valve is declared inoperable, Condition A is entered and its Completion Time starts. If subsequent valves are declared inoperable, Condition A is entered for each valve and separate Completion Times start and are tracked for each valve. If the Completion Time associated with a valve in Condition A expires, Condition B is entered for that valve. If the Completion Times associated with subsequent valves in Condition A expire, Condition B is entered separately for each valve and separate Completion Times start and are tracked for each valve. If a valve that caused entry into Condition B is restored to OPERABLE status, Condition B is exited for that valve. Since the Note in this example allows multiple Condition entry and tracking of separate Completion Times, Completion Time extensions do not apply.

• Cook Nuclear Plant Unit 2 1.3-8 Amendment No. ~. 326 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-6 ACTIONS CONDITION A. One channel inoperable. B. Required Action and associated Completion Time not met. REQUIRED ACTION A. 1 Perform SR 3.x.x.x. OR A.2 Reduce THERMAL POWER to s 50% RTP. 8.1 Be in MODE 3. Completion Times 1.3 COMPLETION TIME Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8 hours 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Entry into Condition A offers a choice between Required Action A.1 or A.2. Required Action A.1 has a "once per" Completion Time, which qualifies for the 25% extension, per SR 3.0.2, to each performance after the initial performance.

The initial 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of Required Action A.1 begins when Condition A is entered and the initial performance. of Required Action A.1 must be complete within the first 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval.

If Required Action A.1 is followed, and the Required Action is not met within the Completion Time (plus the extension allowed by SR 3.0.2), Condition B is entered. If Required Action A.2 is followed and the Completion Time of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is not met, Condition B is entered. If after entry into Condition B, Required Action A.1 or A.2 is met, Condition B is exited and operation may then continue in Condition A. Cook Nuclear Plant Unit 2 1.3-9 Amendment No. ~. 326 1.3 Completion Times EXAMPLES (continued)

EXAMPLE 1.3-7 ACTIONS CONDITION A. One subsystem inoperable.

8. Required Action and associated Completion Time not met. REQUIRED ACTION A.1 Verify affected subsystem isolated.

AND A.2 Restore subsystem to OPERABLE status. 8.1 Be in MODE 3. AND 8.2 Be in MODE 5. Completion Times 1.3 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 6 hours 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter" interval begins upon performance of Required Action A.1. If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or any subsequent 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired. IMMEDIATE When "Immediately" is used as a Completion Time, The Required Action COMPLETION TIME should be pursued without delay and in a controlled manner. Cook Nuclear Plant Unit 2 1.3-10 Amendment No. ~. 326 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 / LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8. Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met , except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated. When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided , or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable , in: a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />; b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS , completion of the actions required by LCO 3.0.3 is not required. LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4. When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made: a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability , and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications);

or Cook Nuclear Plant Unit 2 3.0-1 Amendment No. 2:eG, 340, 326 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 SR 3.0.4 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once," the above interval extension.does not apply. If a Completion Time requires periodic performance on a "once per ... " basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not metmay be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. Cook Nuclear Plant Unit 2 3.0-4 Amendment No. ~. 34-0, 326 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON , D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 344 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-58 AND AMENDMENT NO. 326 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-315 AND 50-316

1.0 INTRODUCTION

By application dated May 4, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 18129A219), Indiana Michigan Power Company (l&M, licensee) requested changes to the technical specifications

{TS) for Donald C. Cook Nuclear Plant (CNP), Units 1 and 2. Specifically, the licensee requested changes consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-529 , Revision 4 , "Clarify Use and Application Rules," dated February 29, 2016 (ADAMS Accession No. ML 16062A271).

The licensee proposed changes to CNP, Units 1 and 2, TS Sections 1.3, "Completion Times," and 3.0, "Limiting Condition for Operation (LCO) Applicability" and " Surveillance Requirement (SR) Applicability." The proposed changes clarify and expand the use and application of CNP's TS usage rules. 2.0

2.1 REGULATORY EVALUATION

Background TSTF-529, Revision 4, was approved by the U.S. Nuclear Regulatory Commission (NRC or Commission) by letter dated April 21, 2016 (ADAMS Package Accession No. ML 16060A441).

TSTF-529, Revision 4, modifies the current Standard T~chnical Specifications (STS), NUREG-1431 , Revision 4.0 , "Standard Technical Specifications:

Westinghouse Plants," Volume 1, April 2012 (ADAMS Accession No. ML 12100A222). The STS provide guidance on the format and content of TS for light-water reactor (LWR) nuclear steam supply systems. TSTF-529, Revision 4, makes changes to Section 1.3, "Completion Times," LCO 3.0.4, and SR 3.0.3. The proposed changes also clarify and expand the use and application of the STS usage rules. Enclosure 3 LCOs specify the minimum requirements for ensuring safe operation of the facility.

When an LCO is not met, the licensee must shut down the reactor or follow any remedial actions permitted by the TS until the LCO can be met. TSs typically specify one or more conditions for each LCO which describe the ways in which the LCO is not met. For each stated condition, the TS specify one or more Required Actions and associated completion times (i.e., remedial actions).

TSTF-529, Revision 4, changes STS Section 1.3 to revise and clarify how the completion times for Required Actions are implemented.

In the STS, LCO 3.0.1 through 3.0.9 establish the general requirements applicable to all TS and apply at all times unless otherwise stated. The STS LCO 3.0.4 specifies the only three situations where it is permissible to enter a mode or other specified condition when an LCO is not met. TSTF-529, Revision 4, changes STS LCO 3.0.4 to clarify that these three situations are independent of each other. Similarly, in the STS, SR 3.0.1 through 3.0.4 establish the general requirements for SRs that are applicable to all TS and apply at all times unless otherwise stated. The STS SR 3.0.3 allows a licensee to delay declaring an LCO not met, for a specified time period , when it is discovered that a required surveillance was not performed within its specified frequency.

Historically, the NRC staff and nuclear power plant licensees interpreted LCO 3.0.3 to apply only to surveillances that had been performed in the past; this interpretation was based on the rationale that where the surveillance had been performed successfully prior to the missed surveillance, it was reasonable to determine that the SR would likely be met upon performance of the missed surveillance.

TSTF-529, Revision 4, changes STS SR 3.0.3 to permit its use when it is discovered that a surveillance was never performed, and to clarify that the delay period may only be used when there is a reasonable expectation that the SR will be met when the surveillance is performed.

2.2 Description of TS Changes The changes that TSTF-529, Revision 4, makes to STS Section 1.3, LCO 3.0.4, and SR 3.0.3 are independent of each other and licensees may choose to adopt them separately. For CNP Units 1 and 2, the licensee proposed to make changes to the TS based on TSTF-529.

The licensee's proposed TS changes are described below. 2.2.1 Proposed Changes to TS Section 1.3 "Completion Times" The licensee proposed to revise "DESCRIPTION" for CNP, Units 1 and 2, TS Section 1.3 "Completion Times," to read, in part as follows (added text shown in bold, and deleted text shown in bold strike out): The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO. Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources -Operating," Required Action 8.3, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable.

The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem,* component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended.

To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and b. Must remain inoperable or not within limits after the first inoperability is resolved. 2.2.2 Proposed Changes to LCO 3.0.4 The licensee's proposed change to the CNP, Units 1 and 2, TS LCO 3.0.4 is provided below. Added text is shown in bold and deleted text shown in bold strike out. When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made: a. b. C. I When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications);

or if appropriate; exGeptions to this SpeGifiGation are stated iR the indi*1idual SpeGifiGatiORS, or When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The licensee proposed to clarify LCO 3.0.4.b by placing the statement regarding exceptions in parentheses, removing the semicolon after the word "appropriate," and replacing the ending comma with a semicolon.

The purpose of these proposed changes is to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.c are independent conditions, such that LCO 3.0.4 can be applied when any one of these conditions is met. 2.2.3 Proposed Changes to SR 3.0.3 The licensee proposed changes to SR 3.0.3 for CNP Units 1 and 2. Currently, SR 3.0.3 allows the licensee to delay declaring an LCO not met for a specified period of time when it is discovered that a required surveillance was not performed within its specified frequency.

As stated in Section 2.1 of this SE, LCO 3.0.3 had previously been interpreted to apply only to surveillances that had been successfully performed in the past, since the performance of a prior successful surveillance supported, as reasonable, a determination that the SR would likely be met upon performance of the missed surveillance.

In TSTF-529, Revision 4, the NRC staff approved a revision to STS SR 3.0.3 to permit its use for surveillances that had never been performed, when there is a reasonable expectation that the SR will be met when the surveillance is performed.

In its license amendment request, the licensee requested approval consistent with TSTF-529, Revision 4, to apply SR 3.0.3 to required surveillances which have never been performed, and proposed to revise SR 3.0.3 to clarify that the delay period is only applicable when there is a reasonable expectation that the SR will be met when the surveillance is performed.

The licensee's proposed revision to SR LCO 3.0.3 for CNP, Units 1 and 2 is provided below. Added text is shown in bold and deleted text shown in bold strike out. 2.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met , the LCO must immediately be declared not met , and the applicable Condition(s) must be entered. Regulatory Requirements, and Guidance The NRC staff considered the regulatory requirements , guidance, and licensing information listed below, during its review of the proposed changes. Title 10 of the Code of Federal Regulations ( 10 CFR), Section 50.36(b ), requires that a license authorizing operation of a utilization facility will include TSs. The TSs will be derived from the analyses and evaluations included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34 (describing the technical i nformation to be included in applications for an operating license).

Pursuant to 10 CFR 50.36(c), TSs are required to include items in the following specific categories related to station operation: ( 1) safety limits, limiting safety systems settings, and control settings; (2) LCO; (3) SRs; (4) design features; (5) administrative controls; (6) decommissioning

(7) initial notification; and (8) written reports. The regulations in 10 CFR 50.36(c)(2) establish the requirements for LCOs. LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

When an LCO is not met, the licensee must shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. Section 50.36(c)(3) of 10 CFR establishes the requirements for SRs. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits and that the LCO for operation will be met. The NRC staff's guidance for review of the TSs is in Chapter 16, " Technical Specifications," Revision 3, dated March 2010 (ADAMS Accession No. ML 100351425) of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition." As described therein, as part of the regulatory standardization effort, the staff has prepared improved STSs for each of the LWR nuclear steam supply systems and associated balance-of-plant equipment systems. The licensee's proposed amendment is based on TSTF-529, Revision 4, which is an NRG-approved change to the improved STSs. The NRC staff review includes consideration of whether the proposed changes are consistent with TSTF-529 , Revision 4. Special attention is given to TS provisions that depart from the improved STSs , as modified by NRG-approved TSTF travelers , to determine whether the proposed differences are justified by uniqueness in plant design or other considerations so that the regulation in 10 CFR 50.36 is met. 3.0 TECHNICAL EVALUATION The NRC staff reviewed the licensee's application against the regulatory requirements and guidance discussed in Section 2.3 of this safety evaluation (SE). The staffs evaluation of the proposed changes to CNP's TS Section 1.3, LCO 3.0.4, and SR 3.0.3 are discussed separately below. 3.1 Changes to TS Section 1.3, " Completion Times" The licensee proposed changes to Section 1.3 of the TS for CNP , Units 1 and 2. 3.1.1. Changes to " Time of Discovery" In the STS, the only mention of the term " time of discovery" in relation to completion times is in STS Section 1.3. Throughout the STS the term "discovery" is used to describe the point in time that it .is recognized that the requirements of an LCO are not met. For example , STS LCO 3.0.2 requires in part that upon discovery of a failure to meet an LCO , the Required Actions of the associated conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. As indicated in Section 2.2.1 of this SE , the licensee proposed changes to CNP's TS Section 1.3 which would delete " time of' from statements which refer to " time of discovery." These proposed changes are consistent with TSTF-529 , Revision 4. The NRC staff determined that the proposed change acceptable because it makes Section 1.3 consistent with the term "discovery" in relation to completion time throughout the rest of the TS. These changes are editorial and do not alter the requirements currently in the TS , and they clarify the term " discovery ," as it applies to TS completion time. Therefore , the NRC staff finds the proposed change acceptable. 3.1.2 Proposed Addition of " Time of Discovery" The licensee also proposed to add the following paragraph to Section 1.3 of CNP's TS under DESCRIPTION, which is identical to the text from TSTF-529 , Revision 4: Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The "otherwise specified" exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time. For example, LCO 3.8.1, "AC Sources -Operating," Required Action 8.3, requires declaring required feature(s) supported by an inoperable diesel generator, inoperable when the redundant required feature(s) are inoperable.

The Completion Time states, "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

The operating shift crew is responsible for overall control of facility operation.

As part of that responsibility, the operating shift crew must be aware of the status of the plant and condition of structures, systems, and components. This includes status of degraded or nonconforming conditions that may affect plant operation.

Therefore, the proposed change supports the NRC staff's expectation that a senior licensed operator on the operating shift crew with responsibility for plant operations will make the determination that an LCO is not met and will make the decision to enter the appropriate Condition.

The phrase " and an ACTIONS Condition is entered" in the proposed text is necessary to accommodate circumstances in which LCO 3.0.6 allows an LCO to not be met without entry into a Condition.

In those circumstances, a completion time does not begin until the conditions in the completion time are satisfied.

In addition, an example is provided in the proposed paragraph to illustrate the requirement.

The NRC staff finds the proposed addition of text to the first paragraph of TS Section 1.3 acceptable because it clarifies the senior reactor operator's responsibilities as they relate to Required Actions and associated completion times. 3.1.3 Addition of "Unless Otherwise Specified" The phrase, "unless otherwise specified," in STS Section 1.3, refers to those instances in which TS LCOs define the start of the completion time as different from "discovery." For example, in STS 3.8.1, Required ft..ction 8.2, calls for declaring required feature(s) supported by an inoperable diesel generator inoperable when the redundant required feature(s) are inoperable.

The completion time states: " 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s)." In this case, the completion time does not begin until the conditions are satisfied.

As discussed above in Section 3.1.2 of this SE, the TSTF-529, Revision 4, includes the phrase "unless otherwise specified" in the additional text added to the first paragraph of STS Section 1.3. The added text further discusses the "otherwise specified" exceptions.

The licensee proposed to add the identical sentences to CNP's TS Section 1.3 , which contains the phrase "unless otherwise specified:" Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. In addition, the licensee proposed adding the phrase "unless otherwise specified" to the following two statements in CNP TS Section 1.3: and If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

The addition of the phrase " unless *otherwise specified" acknowledges that there are instances, as indicated in the individual TS, when the completion time does not start at discovery.

These exceptions are varied, such as when a Required Action Note or SR Note provides an alternative time to perform specific tasks, such as testing, without starting the completion time. During the time that the Note is in effect, if a condition arises that is not addressed by the Note, the completion time begins. Should the time allowance in the Note be exceeded, the clock for the completion time begins at that point as well. The NRC staff finds the proposed change acceptable since it clarifies that there are exceptions and, therefore, provides a clear and objective application of CNP's TS Required Actions and associated completion times. 3.2 Changes to LCO 3.0.4 The STS LCO 3.0.4 specifies the only three situations (LCOs 3.0.4.a, b, and c) where it is permissible to enter a mode or other specified condition when an LCO is not met. In the STS, LCO 3.0.4.a ends with a semicolon and LCO 3.0.4.b ends with a comma followed by "or." The STS LCO 3.0.4.b states: After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or As currently written, it is possible operators could misapply this statement by believing the " or" applies to the clause regarding exceptions and that LCO 3.0.4.a, b, and c apply concurrently.

The licensee proposed to clarify this sentence by placing the statement regarding exceptions in parentheses, removing the semicolon after the word " appropriate" and replacing the ending comma with a semicolon.

The proposed TS LCO 3.0.4.b statement would be the following:

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specification);

or The NRC staff finds that the change is editorial since it does not change the requirements currently in the technical specifications.

The NRC staff finds the proposed change acceptable since it removes the potential for misapplication of LCO 3.0.4 allowances and, therefore, provides a clear and objective application of CNP's TS Required Actions. 3.3 Changes to SR 3.0.3 The licensee requested approval to apply SR 3.0.3 to surveillances that have never been previously performed, and proposed changes to SR 3.0.3 consistent with TSTF-529, Revision 4. Currently, SR 3.0.3 allows the licensee to delay declaring an LCO not met for a specified period of time when it is discovered that a required surveillance was not performed within its specified frequency.

TSTF-529, Revision 4, revises the interpretation of SR 3.0.3 to allow it to be applied to SRs for surveillances which have never been performed , and revises SR 3.0.3 to read as follows (added text shown in bold): If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed , from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance.

The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed. If the Surveillance is not performed w i thin the delay period , the LCO must immediately be declared not met , and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met , and the applicable Condition(s) must be entered. The NRC has previously interpreted SR 3.0.3, as inapplicable to surveillances that had never been performed. This is because the allowance provided by SR 3.0.3 is based on the view that if the SR was satisfactorily met in the past , the most probable result of performing the surveillance when required is that the surveillance would satisfactorily establish conformance with the SRs. Therefore , there is a reasonable expectation the SR will be met when the surveillance is performed.

The same rationale, however, may also apply to surveillances which have never been performed, if a reasonable determination can be made that the SR will be met when the surveillance is performed.

In this regard, the NRC staff recognizes that there are instances in which a required surveillance may not have been performed in the past, but there is still a reasonable expectation the SR will be met when the surveillance is performed.

For example if a licensee finds a relay contact has never been tested as required in accordance with a particular SR, the licensee can determine that there is reasonable expectation the SR will be met when the surveillance is performed if the relay contact has been successfully tested by another SR or based on historical operation.

The delay period allowed by CNP's SR 3.0.3 offers adequate time to complete surveillances that have been missed. In addition, this delay period permits the completion of a surveillance before complying with Required Actions or other remedial measures that might preclude completion of the SR. The NRC staff finds the application of the delay period provided by SR 3.0.3 acceptable for use on surveillances that have never been performed as long as the licensee can demonstrate a reasonable expectation that the SR will be met when the surveillance is performed.

When making a determination of reasonable expectation that a SR will be met when the surveillance is performed, licensees must take into consideration many factors. These factors include, but are not limited to, the period of time since the surveillance was last performed, whether the surveillance, or a portion thereof, has ever been performed, and other indications, tests, or activities that might support the expectation that the SR will be met when the surveillance is performed.

It is not sufficient to infer the performance of the associated equipment from the performance of similar equipment.

The determination of whether there is a reasonable expectation that an SR will be met when the surveillance is performed, depends, in part, on the length of time since the surveillance was last performed.

If the surveillance has been performed recently, a review of the SR history and equipment performance may be sufficient to support a reasonable expectation that the SR will be met when the surveillance is performed.

For surveillances that have not been performed in a long time or that have never been performed, an evaluation based on objective evidence should provide a high degree of confidence that the equipment is capable of performing its specified safety function(s).

The evaluation should be documented in sufficient detail to allow a review of the basis for the determination.

The NRC staff finds the delay period allowed by CNP's SR 3.0.3 offers adequate time to complete required surveillances that may have been missed, including those that have never been performed.

In addition, the proposed change supports plant safety since it could prevent unnecessary shutdowns by providing adequate time to complete SRs for surveillances that have never been performed but are likely to be met when the surveillances are performed.

The staff finds that the proposed change, which expands the scope of SR 3.0.3 to apply to surveillances that have never been performed, is acceptable because the licensee must determine that there is a reasonable expectation the SR will be met when the surveillance is performed.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment on December 18, 2018.

• The State official had no comments. 5.0 ENVIRONMENTAL CONSIDERATION The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration published the Federal Register on July 17, 2018 (83 FR 33269), and there has been no public comment on such finding. Accordingly, the amendment meets the el i gibility criteria for categorical exclusion set forth in 10 CFR 51.22( c)(9). Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

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

's regulations , and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor

C. Tilton , NRR/DSS Date of issuance: April 10, 2019 J. Gebbie

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 -ISSUANCE OF AMENDMENTS 344, 326 REGARDING REQUEST TO ADOPT TSTF-529, REVISION 4, " CLARIFY USE AND APPLICATION RULES" (EPID L-2018-LLA-0124)

DATED APRIL 10, 2019 DISTRIBUTION:

PUBLIC PM File Copy RidsNrrDorlLpl3 Resource RidsNrrPMDCCook Resource RidsNrrLASRohrer Resource RidsACRS MailCTR Resource RidsRgn3MailCenter Resource RidsNrrDssStsb Resource SGoetz ADAMS Accession No: ML 190318966 OFFICE DORL/LPL3/PM DORL/LPL3/LA NAME SGoetz SRohrer DATE 2/11/2019 2/12/2019 OFFICE OGC NLO DORL/LPL3/BC NAME STurk DWrona DATE 2/21/2019 4/10/2019 OFFICIAL RECORD COPY r '*via memorandum NRR/DSS/STSB VCusumano*

12/13/2018 DORL/LPL3/PM SGoetz 4/10/2019