AEP-NRC-2015-13, Fourth 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)

Fourth 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)

ML15058A032
Person / Time
Site:	Cook
Issue date:	02/25/2015
From:	Gebbie J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2015-13, EA-12-049
Download: ML15058A032 (10)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER One Cook Place Bridgman, Ml 49106 A unit of American Electric Power IndianaMichiganPnwer.com February 25, 2015 AEP-NRC-2015-13 10 CFR 50.54(f)

Docket No.: 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 2 Fourth 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, Agencywide Documents Access Management System (ADAMS) Accession No. ML12054A736.

2. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), 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),"

AEP-NRC-2013-13, dated February 27, 2013, ADAMS Accession No. ML13101A381.

3. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 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)," AEP-NRC-2013-71, dated August 26, 2013, ADAMS Accession No. ML13240A308.

4. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, Second 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)," AEP-NRC-2014-17, dated February 27, 2014, ADAMS Accession No. ML14063A042.

U. S. Nuclear Regulatory Commission AEP-NRC-2015-13 Page 2

5. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, Third 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)," AEP-NRC-2014-17, dated August 27, 2014, ADAMS Accession No. ML14241A235.

6. Letter from J. P. Gebbie, I&M, to NRC, Donald C. Cook Nuclear Plant Units 1, "Compliance with March 12, 2012, NRC Order Regarding Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated December 16, 2014, ADAMS Accession No. ML14353A004.

7. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0766 AND MF0767)," dated January 24, 2014, ADAMS Accession No. ML13337A325.

On March 12, 2012, the U. S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049 (Reference 1) to all power reactor licensees, including Indiana Michigan Power Company, the licensee for the Donald C. Cook Nuclear Plant (CNP) Units 1 and 2. Reference 1 was immediately effective and directed licensees 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.

Order EA-12-049 required submission of an Overall Integrated Plan (OIP), including a description of how compliance with requirements in the order would be achieved. Reference 2 provided the OIP for CNP. The order also required submission of status reports at six-month intervals following submittal of the OIP. References 3, 4, and 5 provided the first, second, and third six-month status reports, respectively. The purpose of this letter is to provide the fourth six-month status report delineating progress made in implementing the requirements of the order. to this letter provides an affirmation. Enclosure 2 to this letter provides the fourth six-month update regarding the implementation of Order EA-12-049 at CNP Unit 2, including an update of milestone accomplishments. The information in Enclosure 2 applies only to CNP Unit 2, because Unit 1 compliance with Order EA-12-049 was achieved in October 2014, as documented in Reference 6. Updates for Unit 1 are therefore no longer required.

There have been no changes to the compliance method as documented in the NRC Interim Staff Evaluation (Reference 7). However, some specific methods of implementation have changed, as summarized in Enclosure 2. There is no change to the final implementation schedule, or need for relief.

U. S. Nuclear Regulatory Commission AEP-NRC-2015-13 Page 3 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, Joel P. Gebbie Site Vice President JRW/mhs

Enclosures:

1. Affirmation

2. Indiana Michigan Power Company's Fourth 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.

c: J. P. Boska, NRC Washington, DC M. L. Chawla, NRC Washington, DC J. T. King, MPSC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III A. J. Williamson, AEP Ft. Wayne, w/o enclosures

Enclosure 1 to AEP-NRC-2015-13 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 PrW/L Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME TKSý '-A OFV*VWj, 2015 Notary Public My Commission Expires )I ,3 2D Ic P&ArRICIA ANN EDDIE iNotary Public, CountyState of Micgan of Berflen A,.." in ft Courdnty _;ý"

Enclosure 2 to AEP-NRC-2015-13 Indiana Michigan Power Company's Fourth 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 References for this enclosure are identified in Section 7.

1. Introduction In response to Reference 1, Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 2, developed an Overall Integrated Plan (OIP) documenting the diverse and flexible mitigation strategies (FLEX) for beyond-design-basis external events. The OIP was submitted to the U. S. Nuclear Regulatory Commission (NRC) by Reference 2. This enclosure provides an update of milestones (Table 1) and OIP Open Items (Table 2). The information in Table 1 and Table 2 applies only to CNP Unit 2, because Unit 1 compliance with Order EA-12-049 was achieved in October 2014, as documented in Reference 4. Updates for Unit 1 are, therefore, no longer required. Although there have been no changes to the CNP compliance method as documented in the Interim Staff Evaluation (ISE)

(Reference 3), some specific methods of implementation have changed as summarized in Section 4 below. There is no change to the final implementation schedule, or need for relief/relaxation at this time. The information in this Enclosure is current as of February 6, 2015.

2. Milestone Accomplishments Table 1 below identifies the milestone(s) completed since the development of the OIP (Reference 2).

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

Table 1 - Milestone Schedule Previous Target Activity Revised Target Milestone Completion Status Completion Date Date Submit 60-Day Status Report October 2012 Complete Submit OIP February 2013 Complete Submit Six-Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete to AEP-NRC-2015-13 Page 2 Table 1 - Milestone Schedule Previous Target Activity Revised Target Milestone Completion Status Completion Date Date t4 Complete with Update 4February 2015 this submittal Walk-throughs or Demonstrations June 2015 In Progress April 2015 Perform Staffing Analysis June 2014 Complete Modifications:

Modifications Evaluation December 2013 Complete Unit 2 Design Engineering December 2014 Complete Unit 2 Implementation Outage April 2015 Not Started Storage:

Storage Design Engineering March 2014 Complete Storage Implementation November 2014 In Progress April 2015 Note 1,2 FLEX Equipment:

Procure On-Site Equipment October 2014 In Progress April 2015 Note 2 Develop Strategies with Regional September 2014 Complete Response Center Install Off-Site Delivery Station (No NA NA installation necessary)

Procedures:

Pressurized Water Reactor Owners Group (PWROG) issues nuclear steam November 2014 Complete system supply-specific guidelines.

(Modes 1-4)

PWROG issues nuclear steam system supply-specific guidelines. December 2014 Complete (Modes 5 & 6)

Create Site-Specific FLEX Support February 2015 In Progress March 2015 Guidelines (FSG) - Unit 2 Create Maintenance Procedures October 2014 In Progress March 2015 Note 2 Training:

Develop Training Plan March 2014 Complete Training Complete September 2014 In Progress March 2015 Note 2 to AEP-NRC-2015-13 Page 3 Table I - Milestone Schedule Previous Target Activity Revised Target Milestone Completion Status Completion Date Date Unit 2 FLEX Implementation April 2015 In Progress Full Site FLEX Implementation April 2015 In Progress Submit Completion Report June 2015 Not Started Note 1: This Milestone includes in-plant storage.

Note 2: The previous target completion date applied to Unit 1. The revised target completion date applies to Unit 2.

4. Changes to Compliance Method Although there have been no changes to the compliance method as documented in the ISE (Reference 3), some specific methods of implementation have changed since the previous update. With the unit in Mode 5 with the Steam Generators (SGs) unavailable, or in Mode 6, the previously identified primary strategy for Reactor Coolant System (RCS) boration and inventory control relied on the borated water from the Boric Acid Storage Tanks (BASTs) and the Boric Acid Reserve Tank (BART) blended with raw water from the Circulating Water System intake forebay to provide RCS makeup. To provide the additional inventory that may be needed to supply RCS makeup for both units, I&M plans to use the Refueling Water Storage Tanks (RWSTs) as the primary source of borated makeup water. Undiluted RWST water would be used for the first four hours, followed by RWST water blended with water from the forebay. The BASTs and BART will continue to be available for additional blended boration. A description of the currently planned strategies is posted on the CNP Fukushima e-portal.

Need for Relief/Relaxation and Basis for the Relief/Relaxation I&M expects to comply with the order implementation date and no relief or relaxation is requested.

5. Open Items from OIP and Draft Safety Evaluation The following table provides a summary of the open items documented in the OIP and the status of each item for Unit 2.

to AEP-NRC-2015-13 Page 4 Table 2 - OIP Open Items Pending OIP Open Item Status Action Complete outside Protected Area Completion of FLEX equipment storage facilities In Progress inside Protected Area Perform final validation of timing requirement to route 2 alternate suction source to Turbine Driven Auxiliary Feed In Progress Water (TDAFW) pump as Level B Time Sensitive Action per NRC approved guidance.

3 Implement administrative controls program for FLEX In Progress related equipment.

A systematic approach to training will be used to evaluate training requirements for station personnel based upon changes to plant equipment, implementation Complete of FLEX portable equipment, and new or revised procedures that result from implementation of the FLEX strategies.

Complete detailed load shedding and battery duration Analysis: Complete analysis of Train A and Train B 250 Volt (V) direct current batteries to validate final FLEX implementation Procedures: In Progress strategy, including required procedure changes. g Modification to TDAFW pump suction piping from 6 Essential Service Water (ESW) system to provide In Progress connection point from alternate sources.

Complete detailed load shedding and battery duration Analysis: Complete analysis of N-Train battery to validate final FLEX implementation strategy, including required procedure Procedures: In Progress changes.

Develop FSGs and associated procedure revisions to In Progress 8 implement FLEX mitigation strategies.

Modification of fire protection not required. Condensate 9 Storage Tanks are the credited Auxiliary Feedwater NA (AFW) supply until the infinite source (Lake Michigan) is made available.

10 10 Operated Relief Proceduralize Valve.

handwheel operation of SG Power Complete 11 Modification to connect portable diesel generator (DG) to In Progress 600 Volt alternating current (Vac) bus 21 D.

to AEP-NRC-2015-13 Page 5 Table 2 - 0IP Open Items Pending OIP Open Item Status Action Fabricate cables and procure E-Cart for powering each 12 control room instrumentation 120 V isolimiter transformer Complete from 350 kilowatt N+1 DG.

Modification to connect portable DG to motor control 13 center (MCC) ABD-B to provide alternate power supply In Progress to N-Train battery charger.

Modification to place a new hose connection in the motor 14 driven AFW discharge line in the east main steam stop In Progress enclosure.

Modification of bus T21A/D not needed. 4 kilovolt leads will be fabricated and stored to allow connection of an external 4160 Vac three-phase portable DG to the load In Progress side of breaker 2-2A2.

16 Modification to replace Reactor Coolant Pump seals with in Progress Westinghouse SHIELD low leakage seals.

17 Modification adding a portable boron addition pump In Progress powered by a dedicated portable DG.

18 Monitor tanks modification and associated strategy not N/A required.

19 Modification to provide power to middle boric acid Complete evaporator feed pump.

Perform containment analysis to validate that 20 containment integrity can be maintained until Complete containment cooling can be restored during Phase 3.

Modify Chemical and Volume Control System charging 21 header to allow connection of portable pump for boron In Progress addition and RCS makeup.

Strategy changed to use existing hose connections on 22 fire test header at the Fire Pump House. Modification of N/A fire test header not needed.

23 Modify boric acid transfer pump (BATP) suction header In Progress to add connection points.

24 Modify BATP discharge header to add connection points. In Progress 25 Modification to install standpipe not required. Strategy N/A revised to use hose connections.

26 Fuel consumption will be finalized when equipment has Complete been procured and tested.

to AEP-NRC-2015-13 Page 6 Table 2 - OIP Open Items Pending OIP Open Item Status Action Perform calculation to verify time required to establish Complete 27 flow to the RCS in MODE 6 with the Reactor Cavity filled.

Modification of boron injection tank downstream vent not 28 required. Strategy changed to use existing Safety N/A Injection Pumps discharge header vents and drains.

Fabricate a tool to provide large volume Phase 3 raw 29 water tie-in to ESW supporting component cooling water In Progress cooling for Residual Heat Removal.

Modify 600 Vac MCC circuit breakers to provide Phase 2 30 electrical power connections to close Safety Injection In Progress accumulator discharge valves.

6. Potential Draft Safety Evaluation Impacts I&M has not received a draft Safety Evaluation. Therefore, no potential impacts can be determined. The changes identified in Section 4 above occurred subsequent to issuance of the Reference 3 ISE.

7. 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, Agencywide Documents Access Management System (ADAMS) Accession No. ML12054A736.

2. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), 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),"

AEP-NRC-2013-13, dated February 27, 2013, ADAMS Accession No. ML13101A381.

3. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M,

Subject:

"Donald C. Cook Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0766 and MF0767)," dated January 24, 2014.

4. Letter from J. P. Gebbie, I&M, to NRC, Donald C. Cook Nuclear Plant Units 1, "Compliance with March 12, 2012, NRC Order Regarding Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated December 16, 2014, ADAMS Accession No. ML14353A004.