ML082490171
| ML082490171 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/19/2008 |
| From: | Lois James Plant Licensing Branch III |
| To: | Rencheck M Indiana Michigan Power Co |
| beltz T, NRR/DORL/LPL3-1, 301-415-3049 | |
| References | |
| GL-08-001, TAC MD7817, TAC MD7818 | |
| Download: ML082490171 (7) | |
Text
September 19, 2008 Mr. Michael W. Rencheck Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7817 AND MD7818)
Dear Mr. Rencheck:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated April 10, 2008, Indiana Michigan Power (the licensee) submitted a 3-month response to GL 2008-01 for Donald C. Cook (CNP), Units 1 and 2. The NRC staffs assessment of the responses for CNP, Units 1 and 2 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for CNP, Units 1 and 2, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
M.
If you have any questions regarding this letter, please contact Terry Beltz at (301) 415-3049.
Sincerely,
/RA/
Lois M. James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316
Enclosures:
As stated cc w/encl: See next page
M.
If you have any questions regarding this letter, please contact Terry Beltz at (301) 415-3049.
Sincerely,
/RA/
Lois M. James, Chief Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316
Enclosures:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrDorlLpl3-1 RidsNrrDorlDPR LPL3-1 R/F RidsOgcRp DBeaulieu, DPR/PGCB RidsNrrLATHarris RidsAcrsAcnw&mMailCenter SSun, DSS/SRXB RidsNrrPMTBeltz RidsRgn3MailCenter WLyon, DSS/SRXB ADAMS Accession Number: ML082490171 NRR-106 OFFICE LPL3-1:PM LPL3-1:PM LPL3-1:LA PGCB:BC DSS/DD LPL3-1:BC NAME TBeltz PTam THarris MMurphy JWermiel LJames DATE 09/ 09 /08 09/ 10 /08 09/ 08 /08 09/ 15 /08 09/ 10 /08 09/ 19 /08 OFFICIAL RECORD COPY
Donald C. Cook Nuclear Plant, Units 1 and 2 cc:
Attorney General Department of Attorney General 525 West Ottawa Street Lansing, MI 48913 Township Supervisor Lake Township Hall P.O. Box 818 Bridgman, MI 49106 U.S. Nuclear Regulatory Commission Resident Inspector's Office 7700 Red Arrow Highway Stevensville, MI 49127 James M. Petro, Jr.
Senior Nuclear Counsel Indiana Michigan Power Company One Cook Place Bridgman, MI 49106 Mayor, City of Bridgman P.O. Box 366 Bridgman, MI 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, MI 48909 John A. Zwolinski Regulatory Affairs Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 Michigan Department of Environmental Quality Waste and Hazardous Materials Div.
Radiological Protection Section Radiological Assessment Unit Constitution Hall, Lower-Level North 525 West Allegan Street P. O. Box 30241 Lansing, MI 48909-7741 Joel P. Gebbie, Plant Manager Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106 Lawrence J. Weber, Site Vice President Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
Enclosure NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-315 and 50-316
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated April 10, 2008, Indiana Michigan Power (the licensee) submitted a 3-month response to GL 2008-01 for Donald C. Cook Nuclear Plant (CNP), Units 1 and 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of CNP, Units 1 and 2, cannot be completed. The GL subject systems include the emergency core cooling system, containment spray, and residual heat removal systems. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to the following reasons: (1) extensive scaffolding in containment is required for completion; (2) insulation needs to be removed from piping; and (3) prolonged containment building entries are needed.
CNP, Unit 1, initiated a refueling outage on March 26, 2008. The licensee indicates that the walkdowns for those piping segments located in the Unit 1 containment building could not be completed during that time because of insufficient lead-time to perform the proper pre-planning prior to the outage.
The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Unit 1 scheduled for fall 2009 and for Unit 2 scheduled for spring 2009. The licensees letter dated April 10, 2008, listed the following commitments:
- 1. Perform system walkdowns in Units 1 and 2 containments as required for the response to GL 2008-01 during each of the fall 2009 and spring 2009 refueling outages at CNP, Units 1 and 2, respectively.
- 2. Provide a supplemental evaluation to the response to GL 2008-01 for each unit three months following the completion of each unit's refueling outage.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. Performance of system walkdowns will ensure that as-installed piping is accurately reflected in design drawings, including isometric drawings. Where deviations exist between as-installed and design drawings there is potential to have a gas accumulation location. Filling and venting of systems and flushing of systems after draining are the means used to ensure that system piping is full. An exception to this is the containment spray system piping in containment, which is maintained dry by design and has been analyzed for that condition.
- 2. The ECCS piping in containment is kept full by station operating and surveillance procedures that require fill and vent, and system flush.
Based on the above considerations, the licensee stated that with the systems full and an evaluation of gas sources as required by the GL, it is reasonable to allow the system walkdowns to be completed during the next refueling outages for Units 1 and 2.
- 3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described procedures associated with managing gas accumulation at CNP, Units 1 and 2.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the CNP, Units 1 and 2, refueling outages, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within three months following the completion of each of the fall 2009 and spring 2009 refueling outages at CNP, Units 1 and 2, respectively.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 10, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.