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

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Unit 2, Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 Provide Actions for One Steam, Supply to Turbine Driven Afw/Efw Pump Inoperable
ML20126G454
Person / Time
Site: Cook  
Issue date: 04/07/2020
From: Gebbie J
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2020-09, TSTF-412, Rev 3
Download: ML20126G454 (25)
v • d • e


Text

INDIJINA MICHIGAN POWIR April 7, 2020 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant, Unit 1 and Unit 2 Indiana Michigan Power Company Nuclear Genera1,on Gro.,p One Cook Place Bridgman. Ml 49106 aep.com AEP-NRC-2020-09 10 CFR 50.90 Application to Revise Technical Specifications to Adopt TSTF-412, Revision 3 "Provide Actions for

.One Steam, Supply to Turbine Driven AFW/EFW Pump Inoperable."

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP), is submitting a request for an amendment to Technical Specifications (TS) for CNP Unit 1 and Unit 2.

The proposed amendment establishes Conditions, Required Actions, and Completion, Times in the Standard Technical Specifications (STS) for the Condition where one steam supply to the turbine driven Auxiliary Feedwater (AFW) pump is inoperable concurrent with an inoperable motor driven AFW. train. In addition, this amendment establishes changes to the STS that establish specific Actions: (1) For when two motor driven AFW trains are inoperable at the same time and; (2) for when the turbine driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply. The change is consistent with Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) Traveler, TSTF--412, Revision 3, Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable." The availability of this TS improvement was announced in the Federal Register on July 17, 2007 as part of the consolidated line item improvement process (CLIIP). provides an affirmation statement pertaining to the information contained herein. provides a description and assessment of the proposed changes.

Enclosures 3 and 4 provide existing Unit 1 and Unit 2 TS pages, respectively, marked up to show the proposed changes.

U. S. Nuclear Regulatory Commission AEP-NRC-2020-09.

Page 2 Enclosures 5 and 6 provide existing Unit 1 and Unit 2 TS Bases pages, respectively, marked up to.

show the proposed changes. TS Bases markups are included for information only. Changes to the existing TS Bases will be implemented under TS 5.5.12, "Technical Specifications (TS) Bases Control Program."

New, clean, Unit 1 and Unit 2 TS pages, with proposed changes incorporated will be provided to the NRC Licensing Project Manager when requested.

. Approval of the proposed amendment is requested in accordance with the normal NRC review schedule for such changes. Once approved, the amendment shall be implemented within 90 days.

In accordance with 1 O CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan state officials.

There are no new regulatory commitments made in this letter.. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.

Sincerely, Joel P. Gebbie Senior Vice President &

Chief Nuclear Officer DLW/mll

Enclosures:

1.

Affirmation

2.

Description and Assessment of the Technical Specification Changes

3.

Donald C. Cook Nuclear Plant Unit 1 Technical Specification Pages Marked To Show Proposed Changes

4.

Donald C. Cook Nuclear Plant Unit 2 Technical Specification Pages Marked To Show Proposed Changes

5.

Donald C. Cook Nuclear Plant u*nit.1 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only)

6.

Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked To Show Proposed Changes (For Information Only)

U. S. Nuclear Regulatory Commission Page3

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R J. Ancona - MPSC EGLE - RMD/RPS J.B. Giessner-NRC Region Ill NRC Resident Inspector D. J. Roberts - NRC Region Ill S.P. Wall - NRC, Washington, D.C.

A. J. Williamson - AEP Ft. Wayne, w/o enclosures AEP-NRC-2020-09 to AEP*NRC-2020-09 Affirmation to AEP*NRC-2020*09

. AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am the Senior Vice President and Chief Nuclear Officer of Indiana Michigan Power Company (l&M), that I am authorized to sign and file this request with the U.S. Nuclear.Regulatory Commission on behalf of l&M, and that the statements made and the matters set forth herein pertaining to l&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Qompany Joel P. Gebbie Senior Vice President &

Chief Nuclear Officer SWORN TO AND SUBSCRIBED BEFORE ME 2020 My Commission Expires <.'.::}'-\\ -t)'\\ -rl'i:::)~'-\\

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DANIELLE BURGOYNE Notary Publlo, State of. Mlohlr,,n County of Berrien My Commission Explrea04*04-2024 Acting ln_t~e County of:>> C:(,~

Enclqsure 2 to AEP*NRC-2020*09 Description and Assessment of the Technical Specification Changes

1.0 DESCRIPTION

2.0 ASSESSMENT

2.1

  • Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION to AEP-NRC-2020-09 Page2

1.0 DESCRIPTION

The proposed License amendment establishes a new Completion Time in Standard Technical

  • Specifications Section 3.7.5 where one steam supply to the turbine driven Auxiliary
  • Feedwater (AFW) pump is inoperable concurrent with an inoperable motor.driven AFW train. This amendment also establishes specific Conditions and Action requirements: (1) for when two motor driven AFW trains are inoperable at the same time and; (2) for when the turbine driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler;TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW Pump Inoperable." The *availability of this Technical Specification (TS) improvement was announced in the Federal Register on July 17, 2007 (72 FR 39089) as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of Publlshed Safety Evaluation Indiana Michigan Power (l&M) the licensee for Donald C. Cook Nuclear Plant (CNP), Unit 1 and Unit 2. has reviewed the safety evaluation published on July 17, 2007 (72 FR 39089), as part of the CLIIP. This verification included a review of the NRC staff's evaluation, as well as the supporting information provided in TSTF-412, Revision 3.

l&M has concluded that the justifications presented in TSTF-412 and the safety evaluation prepared by the NRC staff are applicable to CNP Unit 1 and Unit 2, including consideration of related information provided in NRC letter (ML15286A331) dated October 30, 2015, and justify this amendment for the incorporation of the changes to the CNP Unit 1 and Unit 2 TS.

2.2 Optional Changes and Variations l&M is not proposing any variations or deviations from the TS changes described in TSTF-412, Revision 3, or the NRC staff's model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089).

Note that CNP Unit 1 and Unit 2 TS 3.7.5 Actions A and B still contain the second Completion Time that limits the time from discovery ofa failure. TSTF-439 eliminated the second completion time and is reflected in the sample shown in TSTF-412 Revision 3.

CNP has not adopted TSTF-439 and is. not requesting approval to eliminate the second Completion Time in this submittal.

With respect to the Completion Times associated with new Required Actions C.1 and C.2, l&M has chosen a 24-hour Completion Time.

to AEP-NRC-2020-09 Page3

3.0 REGULATORY ANALYSIS

A description of the proposed change and its relationship to applicable regulatory requirements and guidance was provided in the Notice of Availability published on July 17, 2007 (72 FR 39089).

3.1 No Significant Hazards Consideration Determination l&M has reviewed the proposed no significant hazards consideration determination published on July 17, 2007, as part of the CLIIP. l&M has concluded that the proposed determination presented

. in the notice is applicable to CNP Unit 1 and Unit 2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments.

There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION l&M has reviewed the environmental evaluation included in the model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089), as part of the CLIIP. l&M has concluded that the NRC staff's findings presented in that evaluation are applicable to CNP Unit 1 and Unit 2, and the evaluation Is hereby incorporated by reference for this application.

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

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

AFW System 3.7.5

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

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

APPLICABILITY:

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

ACTIONS

NOTE-----------------------------------------------"'------------

LCO 3.0.4.b is not applicable.

CONDITION A. Turbine driven AFW train inoperable due to one inoperable steam filJ.QQ.!y. One steam supply to turbine driven

/\\FW pump inoperable.

OR

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

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

Turbine driven AFW pump inoperable in MODE 3 following refueling.

Cook Nuclear Plant Unit 1 A.1 REQUIRED ACTION COMPLETION TIME Restore affected equipment 7 days to OPERABLE status.

3.7.5-1 10 days from discovery of failure to meet the LCO Amendment No. 2-8+

ACTIONS (continued)

CONDITION B. One AFW train inoperable in MODE 1, 2, or 3 for reasons other than Condition A.

C. Turbine driven AFW train inogerable due to one inogerable steam suggly.

AND One motor driven AFW train inogerable.

GD. Required Action and associated Completion Time fef-of Condition A,

~. or 8Q_not met.

OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

Of.. Three AFW trains inoperable in MODE 1, 2, or 3.

Cook Nuclear Plant Unit 1 REQUIRED ACTION B.1 Restore AFW train to OPERABLE status.

C.1 Restore the steam suggly to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

GD.1 Be in MODE 3.

AND GD.2 Be in MODE 4.

Q.f_.1

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

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to -

OPERABLE status.

Initiate action to restore one AFW train to OPERABLE status.

3.7.5-2 AFW System 3.7.5 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 10 days from discovery of failure to meet the LCO 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 18 hours Immediately Amendment No. 287, 334

AFW System 3.7.5 CONDITION REQUIRED ACTION COMPLETION TIME E. Required AFW train inoperable in MODE 4.

E.1 Initiate action to restore AFW train to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SR 3.7.5.1 SR 3.7.5.2 SR 3.7.5.3 SURVEILLANCE

*-------------NOTE-----------------------------

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

Verify each required AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

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

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

Verify the developed head of each required AFW pump at the flow test point is greater than or equal to the required developed head.

NOTES----------------------------

1.

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

2.

Only required to be met in MODES 1, 2, and 3.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the INSERVICE TESTING PROGRAM Cook Nuclear Plant Unit 1 3.7.5-3 Amendment No. 287, ~

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

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

AFW System 3.7.5

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

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

APPLICABILITY:

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

ACTIONS

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

LCO 3.0.4.b is not applicable.

CONDITION A. Turbine driven AFW train inoperable due to one inoperable steam supply. One steam supply to turbine driven

.A.'FW pump inoperable.

OR

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

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

Turbine driven AFW pump inoperable in MODE 3 following refueling.

Cook Nuclear Plant Unit 2 A.1 REQUIRED ACTION COMPLETION TIME Restore affected equipment 7 days to OPERABLE status.

3.7.5-1 10 days from discovery of failure to meet the LCO Amendment No.--2e9

ACTIONS (continued)

CONDITION B. One AFW train B.1 inoperable in MODE 1, 2, or 3 for reasons other than Condition A.

C. Turbine driven AFW C.1 train inoperable due to one inoperable steam supply.

OR AND C.2 One motor driven AFW train inoperable.

GD. Required Action and GD.1 associated Completion Time fef-of Condition A AND

.12... or 8 Q not met.

GD.2 OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

Qf. Three AFW trains Qf.1 inoperable in MODE 1, 2, or 3.

Cook Nuclear Plant Unit 2 REQUIRED ACTION Restore AFW train to OPERABLE status.

Restore the steam supply to the turbine driven train to OPERABLE status.

Restore the motor driven AFW train to OPERABLE status.

Be in MODE 3.

Be in MODE 4.

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

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one AFW train to OPERABLE status.

3.7.5-2 AFW System 3.7.5 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> AND 10 days from discovery of failure to meet the LCO 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 18 hours Immediately Amendment No. 2e9, a+e

AFW System 3.7.5 CONDITION REQUIRED ACTION COMPLETION TIME ef. Required AFW train inoperable in MODE 4.

ef.1 Initiate action to restore AFW train to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SR 3.7.5.1 SR 3.7.5.2 SURVEILLANCE

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

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

Verify each required AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

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

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

Verify the developed head of each required AFW pump at the flow test point is greater than or equal to the required developed head.

FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the INSERVICE TESTING PROGRAM Cook Nuclear Plant Unit 2 3.7.5-3 Amendment No. 269, ~

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

BASES LCO (continued)

APPLICABILITY ACTIONS AFW System B 3.7.5 The AFW System is configured into three trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE.

This requires that the two motor driven AFW pumps be OPERABLE in two independent discharge paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of two main steam lines upstream of the SGSVs, and shall be capable of supplying AFW to all of the steam generators. The piping, valves, instrumentation, and controls required to perform the safety related function also are required to be OPERABLE.

The LCO is modified by a Note indicating that only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

This is because of the reduced heat removal requirements and short period of time in MODE 4 during which the AFW is required and the insufficient steam available in MODE 4 to power the turbine driven AFW pump.

In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.

In MODE 4 the AFW System may be used for heat removal via the steam generators.

In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the Cook Nuclear Plant Unit 1 B 3.7.5-4 Revision No. O

BASES AFW System B 3.7.5 ACTIONS (continued) inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a.

For the inoperability of a steaFR s~1313ly ta the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.

b.

For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c.

For both the inoperability of a steaFR s~1313ly liRe te the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 1 O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 1 O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling. Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the Cook Nuclear Plant Unit 1 B 3.7.5-5 Revision No. 63

AFW System B 3.7.5 loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a OBA occurring during this time period.

The second Completion Time for Required Action B.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 1 O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 1 O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Assuming no single active failures when in this condition, the accident (a MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the analysis requiring flow from two AFW pumps.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump D.1 and D.2 When Required Action A.1.. &F 8.1, C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

Cook Nuclear Plant Unit 1 B 3.7.5-6 Revision No. 63

BASES AFW System 8 3.7.5 ACTIONS (continued)

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.

If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

Required Action GE. 1 is modified by a Note indicating that all required MODE changes or power roduotions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the required AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. Verification of the AFW System water supply flow path includes both the suction (either a flow path from the CST or the Essential Service Water (ESW) System) and discharge flow paths. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

Cook Nuclear Plant Unit 1 B 3.7.5-7 Revision No. 63 to AEP-NRC-2020-09 Donald C. Cook Nuclear Plant Unit 2 Technical Specification Bases Pages Marked to Show Proposed Changes (For Information Only) 83.7.5-5 83.7.5-6 83.7.5-7

BASES ACTIONS AFW System B 3.7.5 A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

If ono of tt:io t1N-0 steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

a.

For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.

b.

For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c.

For both the inoperability of a steam supply lino to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.

The second Completion Time for Required Action A.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 1 O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 7 days and 1 O days Cook Nuclear Plant Unit 2 B 3.7.5-5 Revision No. O

BASES AFW System B 3.7.5 ACTIONS (continued) dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turine driven AFW pump in MODE 3 to when the unit is in MODE 3 following a refueling. Condition A allows the turbine driven AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time in Condition 8. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA occurring during this time period.

The second Completion Time for Required Action 8.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

The 1 O day Completion Time provides a limitation time allowed in this specified Condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B are entered concurrently. The AND connector between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 1 O days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the analysis requiring flow from two AFW.

Cook Nuclear Plant Unit 2 B 3.7.5-6 Revision No. O

BASES AFW System B 3.7.5 ACTIONS (continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump.

D.1 and D.2 When Required Action A.1, GF B.1, C.1, or C.2 cannot be completed within the associated Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 4 within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.

If all three AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

Required Action Gf.1 is modified by a Note indicating that all required MODE changes er 130*.ver reel1:1eti0As are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.

Cook Nuclear Plant Unit 2 B 3.7.5-7 Revision No. 0

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