AEP-NRC-2013-71, First Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies

First Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies

ML13240A308
Person / Time
Site:	Cook
Issue date:	08/26/2013
From:	Gebbie J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2013-71, EA-12-049
Download: ML13240A308 (9)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant OWER One Cook Place Bridgman, MI49106 A unit of American Electric Power Indiana Mic higa nPower.com August 26, 2013 AEP-NRC-2013-71 10 CFR 50.54(f)

Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 First Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. Letter from E. J. Leeds and M. R. Johnson, U. S. Nuclear Regulatory Commission (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, '.Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, ML12059A735.

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012, ML12229A174.

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012, ML12242A378.

4. Letter from J. P. Gebbie, Indiana Michigan Power Company, to NRC, "Donald C. Cook Nuclear Plant, Units 1 and 2, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 26, 2012, ML12312A473.

5. Letter from J. P. Gebbie, Indiana Michigan Power Company, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013, ML13101A381.

U. S. Nuclear Regulatory Commission AEP-NRC-2013-71 Page 2 On March 12, 2012, the Nuclear Regulatory Commission issued order EA-12-049 (Reference 1) to Indiana Michigan Power Company (I&M), the licensee for the Donald C. Cook Nuclear Plant (CNP)

Units 1 and 2. Reference 1 was immediately effective and directed I&M to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements were outlined in Attachment 2 of the enclosure of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified. Reference 4 provided the CNP initial status report regarding mitigation strategies. Reference 5 provided the CNP overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports.

The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, delineating progress made in implementing the requirements of Reference 1. Enclosure 1 to this letter provides an affirmation. Enclosure 2 to this letter provides the six month update for the implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation of Strategies for Beyond-Design-Basis External Events, including an update of milestone accomplishments since the initial status report, and a change to the compliance method. There is no change to the final implementation schedule, or need for relief at this time.

This letter contains no new or revised regulatory commitments. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely, fbfZ-Joel P. Gebbie Site Vice President DMB/kmh

Enclosures:

1. Affirmation

2. Indiana Michigan Power Company's First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

U. S. Nuclear Regulatory Commission AEP-NRC-2013-71 Page 3 c: J. T. King, MPSC J. A. Kratchman, NRR/JLD/PMB, NRC S. M. Krawec, AEP Ft. Wayne, w/o enclosure E. J. Leeds, NRR, NRC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III T. J. Wengert, NRC Washington, DC

Enclosure 1 to AEP-NRC-2013-71 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company r Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME DANIELLE BURGOYNE THIS j DAY OF Ž,.*, AK, 2013 Notary Public. State of Michigan County of Berrien My Commission Expires 04A,4-2018 Acting in the County of4 My ComisioENotax-blic\- '-

My Commission Expires Q!5A - 1ý)_**-*\:

Enclosure 2 to AEP-NRC-2013-71 Indiana Michigan Power Company's First Six Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP),

developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the OIP, including a change to the compliance method. There is no change to the final implementation schedule, or need for relief/relaxation at this time.

2. Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP (Reference 1), and are current as of July 30, 2013.

None (no milestones were scheduled to be completed between 2/28/13 and 8/27/13).

3. Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Target Revised Milestone Completion Activity Target Date Status Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Submit 6 Month Updates:

Update 1 August 2013 Complete with this submittal Update 2 February 2014 Not Started Update 3 August 2014 Not Started Update 4 February 2015 Not Started Walk-throughs or Demonstrations June 2015 Not Started Perform Staffing Analysis June 2014 Not Started Modifications:

Modifications Evaluation December 2013 Started Unit 1 Design Engineering June 2014 Started Unit 1 Implementation Outage November 2014 Not Started Unit 2 Design Engineering December 2014 Started Unit 2 Implementation Outage May 2015 Not Started to AEP-NRC-2013-71 Page 2 Target Revised Milestone Completion Activity Target Date Status Completion Date_ _Date Storage:

Storage Design Engineering December 2013 Started December 2014 November Storage Implementation Unit 1 Not Started 2014 July 2015 Unit 2 Common Bldg.

FLEX Equipment:

Procure On-Site Equipment June 2014 Started Develop Strategies with Regional Response Center May 2014 Not Started Install Off-Site Delivery Station (if November 2014 Not Started Necessary)

Procedures:

PWROG issues NSSS-specific November 2014 Started guidelines Create Site-Specific FLEX Support September Started Guidelines (FSGs) - Unit 1 2014 Create Site-Specific FSGs - Unit 2 September Started February 2015 2014 Create Maintenance Procedures August 2014 Not Started Training:

Develop Training Plan March 2014 Started Training Complete September Not Started 2014 Unit 1 FLEX Implementation November 2014 Not Started Unit 2 FLEX Implementation April 2015 Not Started Full Site FLEX Implementation April 2015 Not Started Submit Completion Report August 2015 Not Started

4. Changes to Compliance Method There is one change to the compliance method as documented in the OIP (Reference 1). CNP will store phase 2 portable equipment in a single building qualified to withstand the postulated events for which the equipment will be needed. The initial submittal indicated by schedule that there would be a storage building for each unit.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation I&M expects to comply with the order implementation date and no relief/relaxation is required at this time.

to AEP-NRC-2013-71 Page 3

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the Draft Safety Evaluation (SE) and the status of each item.

Pending Action Overall Integrated Plan Open Item Status 1 Completion of FLEX equipment storage facilities. In Progress Perform final validation of timing requirement to route Not Started 2 alternate suction source to Turbine Driven Auxiliary Feed Water (TDAFW) pump.

3 Implement administrative controls program for FLEX Not Started related equipment.

A systematic approach to training will be used to evaluate training requirements for station personnel based upon changes to plant equipment, implementation of FLEX portable equipment, and new or revised procedures that result from implementation of the FLEX strategies. In Progress Complete detailed load shedding and battery duration 5 analysis of Train A and Train B 250 Vdc batteries to validate final FLEX implementation strategy, including required procedure changes. Not Started Modification to TDAFW pump suction piping from 6 Essential Service Water system to provide connection point from the discharge of the fire water pumps. In Progress Complete detailed load shedding and battery duration 7 analysis of N-Train battery to validate final FLEX implementation strategy, including required procedure changes. Not Started Develop FSGs and associated procedure revisions to 8 implement FLEX mitigation strategies. In Progress Modify the fire protection header inside the Turbine 9 Building to provide an adequately sized connection to enable transfer of water to Auxiliary Feedwater pump suction. In Progress Permanent nitrogen bottle racks will be installed near each SG PORV operating station with hose and regulators to align for control to remain available in the control room. In Progress Modification to connect portable diesel generator to 11 600 Vac bus 11B [11 D] and 21B [21D]. In Progress Modification to connect portable diesel generator to CRP-3 In Progress Modification to connect portable diesel generator to 13 MCC ABD-B to provide alternate power supply to N-Train battery charger. In Progress to AEP-NRC-2013-71 Page 4 Pending Action Overall Integrated Plan Open Item Status Modification for hose connection of all main Feed 14 Water line flow nozzle inspection port flanges located near B.5.b connection. In Progress 4160 Vac bus T1 1A/D (T21A/D) will be modified to 15 allow connection of external 4160 Vac three-phase portable diesel generator. In Progress 16 Replace Reactor Coolant Pump seals with Westinghouse SHIELD low leakage seals. In Progress Modification adding connection point for portable electric pump to the safety-related 600 Vac buses (e.g., 11 B and 11D (21B and 21D)) for the portable boron addition pump. In Progress 18 Modify monitor tanks installing temporary hose connections. In Progress A transfer switch will be installed in the feeder cable 19 between 600 Vac bus 11D and MCC AB-C to provide power to CVCS holdup tank recirculation pump to facilitate water transfers. In Progress Perform containment analysis to validate that 20 containment integrity can be maintained until containment cooling can be restored during Phase 3. In Progress Modify Chemical and Volume Control System (CVCS) 21 cross-tie to allow connection of portable boron addition pump. In Progress Modify the fire test header inside the Fire Pump 22 House to allow for the hose connection. In Progress Modify the boric acid transfer pump suction header to 23 add a branch connection with quick disconnect fittings. In Progress Modify the boric acid transfer pump discharge header 24 to add a branch connection with quick disconnect fittings. In Progress Install standpipe from the 609 ft. elevation in the Auxiliary Building crane bay just inside the personnel 25 door near the roll-up door through a stairwell to the overhead of the 587 ft. elevation to a location near the charging pump room entries. In Progress Fuel consumption will be finalized when equipment 26 has been procured and tested. Not Started Perform calculation to verify time required to establish 27 flow to the Reactor Coolant System in MODE 6 with the Rx Cavity filled. Not Started 28 Modify vent connection downstream of the boron injection tanks for portable pump connection. In Progress Draft Safety Evaluation Open Item Status None to AEP-NRC-2013-71 Page 5

7. Potential Draft Safety Evaluation Impacts CNP has not yet received a Draft Safety Evaluation; therefore, no potential impacts can be determined.

8. References The following references support the updates to the OIP described in this attachment.

1. I&M's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2013 (AEP-NRC-2013-13).

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.