AEP-NRC-2018-81, Supplement to Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping

Supplement to Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping

ML18333A032
Person / Time
Site:	Cook
Issue date:	11/27/2018
From:	Lies Q American Electric Power, Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2018-81
Download: ML18333A032 (6)

Text

-s INDIANA Indiana Michigan Power MICHIGAN- . Cook Nuclear Plant. .

-POWER* One Cook Place Briqginan)/11 49106 A unit ofAmerican Eiectric Power

• lndianaMichiganPower.com November 27, 2018 AEP-NRC-2018-81 10 CFR -50.90 Docket No.: 50-315 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Unit 1.

Supplement to Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping

References:

1. Letter from Q. S. Lies, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant, Unit 1, Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping," dated March 7, 2018, Agencywide Documents Access and Management System Accession (ADAMS) No. ML18072A012.

2. E-mail from A. W. Dietrich, NRC, to H. L. Levendosky, l&M, "D. C. Cook Unit No. 1 - RAI for Leak-Before-Break LAR (EPID L-2018-LLA-0054)," dated September 14, 2018.

3. Letter from Q. S. Lies, l&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1, Response to Request for Additional Information Regarding License Amendment Request for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping," dated September 27, 2018, Agencywide Documents Access and Management System Accession (ADAMS) No. ML18274A093.

This letter provides Indiana Michigan Power Company's (l&M), licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, supplement to the response to the Request for Additional Information (RAI) by the U. S. Nuclear Regulatory Commission (NRC)' concerning the License Amendment Request (LAR) for an amendment to Technical Specifications for CNP, Unit.1.

By Reference 1, l&M submitted the LAR for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping in Unit 1. By Reference 2, the NRC transmitted an RAI (RAl-7) concerning the LAR submitted by l&M in Reference 1. By Reference 3, l&M submitted a response to the RAI (RAl-7) in Reference 2. On November 1, 2018, a conference call was held between representatives from l&M and the NRC. During that conference call it was determined that further clarification was needed for l&M's response to the RAI (RAl-7) in Reference 2.

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U. S. Nuclear Regulatory Commission. AEP-NRC-2018-81.

Page 2. '

Enclosure 1 to this letter provides an affirmation statement. l&M is providing Enclosure 2 to this letter as its supplement to the response to the NRC's RAI (RAl-7) from Reference 2.

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,

• Site Vice President JMT/mll

U.S. Nuclear Regulatory Commission . AEP-NRC~2018-81 .

Page 3

Enclosures:

1. Affirmation

2. Supplement to Response to Request for Additional Information Regarding License Amendment Request for Application of Leak-Before-Break Evaluations for Accumulator, Safety Injection, and Residual Heat Removal Piping (RAl-7) c: R. J. Ancona - MPSC R. F. Kuntz, NRG Washington DC MDEQ - RMD/RPS NRG Resident Inspector K. S. West; NRC Region Ill A. J. Williamson - AEP Ft. Wayne, w/o enclosures.

Enclosure 1 to AEP-NRC-2018-81

• AFFIRMATION I, Q. Shane Lies, being duly sworn, state that I am the Site Vice President 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 Company Q.l~i~

Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS dl . DAY OF ~ovef'<\'cer , 2018

~L)Not~~ I My Commission Expires D \ 1d \ j ao;,5

• _*_._ ..,

  .- -~ . : ., .

Enclosure 2 to AEP-NRC-2018-81 Supplement to Response* to Request for Additional Information Regarding License Amendme~t Request for Applicatiori of Leak-Before~Break Evaluations for Accumulator~

• Safety Injection, and Residual Heat Removal Piping (RAl-,7) *. . *

• .* 1 The U. S. Nuciear Regulatory Commission (NRCfst~ff isreviewing .the Indiana Michigan Power.

Company (l&M), the

• Licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1, License

. Amendment Request (LAR) application dated March 7*, 2018, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18072A012). The LAR would allow for the.

application of Leak-Before-Break (LBB) evaluations for accumulator piping, Safety Injection (SI) , *

• . piping, arid Residual Heat Removal (RHR) piping at CNP, Unit No.: 1.. The NRG staff has determined that additional information is necessary in order to complete its review. . . ..

By electronic mail dated September 14, 2018; the NRG transmitted a Request for Additional>.

Information (RAI) (RAl-7) regarding the March 7, 2018, LAR. l&M provid~d a response to this

• request in a letter dated September 27, 2018, (ADAMS Accession No. ML18274A093)..

• On November 1, 2018, a conference call was held between representatives from l&M and the NRG;

• During that conference call it was determined that further clarification *was needed for l&M's response to the RAI (RAl-7). The text of th.e RAI (RAl-7)and l&M's response is provided below_.

The regulatory guidelines in _Regulatory Guide 1A5, "Guidance on Monitoring and Responding to .

Reactor Coolant System Leakage. ,{ADAMS Accession No. ML073200271) states that "all monitoring systems referenced in *the* technical. specifications should *respond to a leakage .

increase of 1 [gallon per minute (gpin)] (3. ~ [liters per. minute]) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or/ess. .* *

' In its ' application, ' me _* licensee .stated, .: 'F\ CNP leakage detection *. capability 'ca/c~Jation.

• demonstrates the 0. 8 gpm leak detection capability is valid for leaks in the Accumulator, RHR, and SI piping. As such, the 0._8 gpmleak.detection.capf}bility is the basis for (.BB evaluation of

• . the Accumulator, RHR, and SJ lines with no response time ass.urned." -

• The NRG staff. considers response time lo include both transport ;espons~ time_ and detector

,response time .. The application is not clear what is meant by "no response time assumed.,; *

• Clarify the assumption of "no response time assumed" in. the calculation d~scribed above, and its *_

effect on the calculation results and acceptability.

. Supplement to l&M Response to RAl~7 *

• tb

• The assumptio~ of:"no_ respons~ time:~ssumed". isnofr~1ated thi*1eakage de1~cti~~ c~pabillty _: *. *

• calculation. The statement above was 'taken from_ Section 2.2 of Enclosure 2 c:if the LAR '.The-..*._

. section has been.rewritten and clarified toread as follows: . ' . ' ,; ,,,c,,:

• Enclosure 2 to AEP-NRC-2018-81 , ***Page~-**.

• :2~2 Current Technicaf Specifications Requirements *

,

• A reliable leak detection system is required for application of the LBB methodology. This reliability .*..

is necessary to monitor initiation of a leak in the reactor coolant pressure boundary so that

• • appropriate actions can be taken to place the plant in -~* safe condition. ..

• At CNP', the TS for Unit 1 requires that the reactor coolant leakage detection system be operable

. ,in operating Modes 1 through 4. Per the current Unit 1 TS Bases, the particulate co_ntainment, atmosphere radioactivity monitor is OPERABLE when it is capable Qf detecting a. 0.8 gpm *

• increase.in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed

.in the design calculations for the monitors. The gaseous containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE.

, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the

--*monitors~ . * * * *

• ' The CNP re~ctor coolant leakage d~tectionsyste'ni is consistent with the intentof the regulatory position in Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection

.*.. Systems," (Reference 5) in that it is capable of detecting a 1 gpm leak in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This exceeds the criterion of 1.0 gpm detection within4 hours, stated in Generic Letter 84-04 (Reference 3) and NUREG 1061, Volume 3, Section 5.7(b) (Reference 4) as being acceptable for applying the LBB methodology. * * * * **

Furthermore, the application of LBB has been previously evaluated for the pressurizer surge line .*

at CNP Unit 1. The basis for the surge line LBB evaluation considered a leak detection rate of

• 0.8 gpm, below the 1.0 gpm leak detection capability criterion (References 3, 4, and 5); The NRG

• approval for implementation of the surge line LBB was predicated on demonstration that the CNP

.. leakage detection systems are capable of reliably detecting 0.8 gpm of primary coolant

• lea.kage .. The Safety Evaluation Report for the surge line LBB (Reference 6) documents that the 0.8.. gpm leakage detection capability was adequately justified __

• A CNP. leakage detection a

capability calculation demonstrates the capability to detect 0.8 gpm RCS leak within one hour_

is valid for leaks in the Accumulator, RHR, and SI piping: As such, the capability to detect a 0;8 gpm RCS leak within one hour is the basis for LBB *evaluation. The technical evaluations of *

.LBB for the Accumulator, RHR, and. SI lines l:!re not dependent on the specific response times of

• the credited leak detection systems.

. .