AEP-NRC-2014-31, Response to a Request for Additional Information Regarding the License Amendment Request Regarding Containment Divider Barrier Seal
| ML14167A374 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/13/2014 |
| From: | Gebbie J Indiana Michigan Power Co |
| To: | |
| References | |
| AEP-NRC-2014-31, TAC MF3052, TAC MF3053 | |
| Download: ML14167A374 (6) | |
Text
z INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant 19111 ERQ One Cook Place Bridgman, MI 49106 Aunit ofAmerican Electric Power IndianaMichiganPower.com June 13, 2014 AEP-NRC-2014-31 10 CFR 50.90 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Response to a Request for Additional Information Regarding the License Amendment Request Regarding Containment Divider Barrier Seal
References:
- 1. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant Unit 1 and Unit 2, License Amendment Request Regarding Containment Divider Barrier Seal," AEP-NRC-2013-50, dated November 6, 2013, Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13312A006.
- 2. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Request for Additional Information Concerning the Containment Divider Barrier Seal License Amendment Request (TAC Nos. MF3052 and MF3053)," dated May 15, 2014, ADAMS Accession No. ML14127A470.
This letter provides Indiana Michigan Power Company's (I&M), licensee for Donald C. Cook Nuclear Plant Units 1 and 2, response to Requests for Additional Information (RAI) by the U. S. Nuclear Regulatory Commission (NRC) regarding a license amendment request regarding the containment divider barrier seal.
By Reference 1, I&M submitted a request to amend the Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74. I&M proposes to change TS 3.6.13, Divider Barrier Integrity, Surveillance Requirement 3.6.13.5 for the divider barrier seal inspection. By Reference 2, the NRC transmitted RAIs regarding the proposed amendment. This letter provides I&M's response to Reference 2.
Enclosure 1 to this letter provides an affirmation statement. Enclosure 2 to this letter provides I&M's response to the NRC's RAIs.
U. S. Nuclear Regulatory Commission AEP-NRC-2014-31 Page 2 Copies of this letter and its enclosures are being transmitted to the Michigan Public Service Commission and Michigan Department of Environmental Quality, in accordance with the requirements of 10 CFR 50.91. There are no new regulatory commitments associated with this response. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Joel P. Gebbie Site Vice President JMT/amp
Enclosures:
- 1. Affirmation
- 2. Response to Request for Additional Information Regarding Containment Divider Barrier Seal License Amendment Request c: J. T. King, MPSC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III T. J. Wengert, NRC Washington, D.C.
A. J. Williamson, AEP Ft. Wayne, w/o attachments
Enclosure I to AEP-NRC-2014-31 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 U. S. 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 Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAYFOF 2014 DANIELLE BURGOYNE Notary Public, State of Michigan County of Berrien p ublic'" -
NotanE MY Commission Expires o -04.2018.
Acting ,n the. County o;f My Cornmission Expires '-,- _-,, * *\ _
Enclosure 2 to AEP-NRC-2014-31 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTAINMENT DIVIDER SEAL LICENSE AMENDMENT REQUEST By letter dated November 6, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13312A006), Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, submitted a request to amend the Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74.
I&M proposes to change TS 3.6.13, Divider Barrier Integrity, Surveillance Requirement (SR) 3.6.13.5 for the divider barrier seal inspection. The U. S. Nuclear Regulatory Commission (NRC) staff has reviewed the submittal and requests the following information to complete its review.
Containment and Ventilation Systems Branch (SCVB)
SCVB Request for Additional Information (RAI)-1 Please describe the diaphragm floor joint components that the term "connections"would be referring to as distinguishedfrom just "bolts." Please identify the plant procedure or document in which this list/description would be included.
Response to SCVB RAI-1 The connections currently holding the divider barrier seal in place include bolts, screws, welded studs, nuts, welds, and concrete anchors. The controlled design drawings that show these connections include but are not limited to 1-2-3207E, 1-2-3207F, and 1-AEQS-226-A.
SCVB RAI-2 Please describe the procedural guidance used to determine proper! acceptable installation of these connections.
Response to SCVB RAI-2 Procedures for performing the divider barrier seal surveillance contain design configuration criteria for the proper/acceptable installation of these connections. The criteria specified by the surveillance procedures include: bolt spacing, edge distances, number of connections, and tightness.
SCVB RAI-3 Please provide the NRC approved methodology used to determine that the acceptance criteria for the bypass area have been met.
Response to SCVB RAI-3 In case deficient connections are discovered, then the resulting divider barrier bypass would be determined, using an accepted standard, the American Institute of Steel Construction (AISC) to AEP NRC 2014-31 Page 2 Manual of Steel Construction, (tables for beam diagrams and formulas), as referenced in Updated Final Safety Analysis Report (UFSAR) Chapter 5, or using a simplified method that is more conservative, to determine the deflections of the as found configurations due to a postulated blowdown, and these deflections would be used to quantify the bypass area. The total bypass area for that unit is then compared against the Allowable Design Basis Bypass Area of seven square feet, per UFSAR 5.3.5.15.4. The assumed Analysis Value is 35 square feet, per UFSAR 14.3.4.1.3.1.1.e.
Technical Specifications Branch (STSB)
STSB RAI-1 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3), "Surveillance requirements"states:
Surveillance requirements. Surveillance requirements 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 limiting conditions for operation [LCO] will be met SR 3,6.13.5 currently states:
Visually inspect > 95% of the divider barrierseal length, and verify:
- a. Seal and seal mounting bolts are properly installed; and
- b. Seal material shows no evidence of deterioration due to holes, ruptures, chemical attack, abrasion, radiation damage, or changes in physical appearance.
The above SR 3.6.13.5.a is proposed to be deleted and replaced with the following:
ProposedInsert for SR 3.6.13.5:
- a. Seal and seal mounting connections are installed such that the total divider barrierbypass area is maintainedwithin design limits; and STSB RAI-I(a) Explain how the proposed SR meets the above 10 CFR 50.36 Surveillance Requirement (test, calibration,or inspection) and does not require an Operability determination or other unspecified analysis to determine if the LCO is met.
Response to STSB RAI-1 (a)
In case deficient connections are discovered, then the resulting divider barrier bypass would be determined, using an accepted standard, the AISC Manual of Steel Construction, (tables for beam diagrams and formulas), as referenced in UFSAR Chapter 5, or using a simplified method that is more conservative, to determine the deflections of the as found configurations due to a postulated blowdown, and these deflections would be used to quantify the bypass area. The total bypass area for that unit is then compared against the Allowable Design Basis Bypass Area of seven square feet, per UFSAR 5.3.5.15.4. The assumed Analysis Value is 35 square feet, per UFSAR 14.3.4.1.3.1.1.e. Therefore, the surveillance is a quantification of overall to AEP NRC 2014-31 Page 3 bypass that is compared against the criteria of the total bypass allowed. Satisfactory results of the surveillance demonstrate operability of the containment divider barrier safety function.
STSB RAI-I(b)
What is the bypass area "design limit" and why is it not identified in the proposed SR?
(i.e., What are the SR acceptance criteria for "... seal mounting connections are installed such that the total divider barrierbypass area is maintainedwithin design limits"?)
Response to STSB RAI-I (b)
The Allowable Design Basis Bypass Area is seven square feet, per UFSAR 5.3.5.15.4. This value will also be added to the TS Bases for this SR as represented in Enclosures 5 and 6 of the initial License Amendment Request dated November 6, 2013 (ADAMS Accession No. ML13312A006). This will be controlled under the Technical Specifications Bases Control Program described in TS 5.5.12.
STSB RAI-I(c)
What constitutes a "sealmounting connection" and where are they identified or described in the CNP updated safety analysis report (USAR)?
Response to STSB RAI- (c)
Seal mounting connections currently holding the divider barrier seal in place include bolts, screws, welded studs, nuts, welds, and concrete anchors. These connections are not specifically described in the UFSAR but are described on various CNP controlled design drawings, including but not limited to 1-2-3207E, 1-2-3207F, and 1-AEQS-226-A.