Text

Regulatory Commitment Management Program Audit Report
	ML092170536
Person / Time
Site:	Cook
Issue date:	08/19/2009
From:	Beltz T; Plant Licensing Branch III
To:	Jensen J; Indiana Michigan Power Co
	beltz T, NRR/DORL/LPL3-1, 301-415-3049
References
	TAC ME1360, TAC ME1361
	Download: ML092170536 (18)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 19, 2009 Mr. Joseph N. Jensen 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 - REGULATORY COMMITMENT MANAGEMENT PROGRAM AUDIT REPORT (TAC NOS. ME1360 AND ME1361)

Dear Mr. Jensen:

On August 4-5,2009, the NRC staff performed an audit of Indiana Michigan Power Company's (I&M) Donald C. Cook Nuclear Plant, Units 1 and 2, regulatory commitments management program.

The purpose of the audit was to examine I&M's regulatory commitments management program and the regulatory commitments change process. The staff examined I&M commitment management records, including a sample of regulatory commitments that have not been previously inspected or otherwise audited by the NRC staff, that are risk significant, and that were important to the U.S. Nuclear Regulatory Commission (NRC) staff's decision-making process on the licensing actions for which respective commitments were made.

Based on the results of the on-site audit of I&M's procedures, processes, and records for managing regulatory commitments, and reviewing an identified sample of regulatory commitments, the NRC staff concludes that I&M has implemented the regulatory commitments management program effectively. The regulatory commitments management program and the requiatory commitments change process were effectively implemented consistent with the Nuclear Energy Institute's (NEI) industry guidance, NEI 99-04, and were generally in accordance with the NRC staff's Office Instruction L1C-105.

Details of the audit and the NRC staff's conclusions are set forth in the enclosed audit report.

J. Jensen

- 2 The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-3049 or by electronic mail at Terry.Beltz@nrc.gov.

~~~----

~eltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316

1.0 INTRODUCTION AND BACKGROUND

In Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21,2000, the U.S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, "Guidelines for Managing NRC Commitment Changes," contains acceptable guidance for controlling regulatory commitments and encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented, and that changes to the regulatory commitments are evaluated, and when appropriate, reported to the NRC.

On May 27,2003, the Office of Nuclear Reactor Regulation (NRR) issued Office Instruction L1C-105, "Managing Regulatory Commitments Made by Licensees to the NRC." L1C-105 is publicly available electronically from the Internet at the NRC web site, from the Agencywide Documents Access and Management System (ADAMS), Public Electronic Reading Room, ADAMS Accession No. ML022750041. L1C-105 provides the NRC staff and its stakeholders a reference for handling regulatory commitments made by the licensees for commercial nuclear power reactors. The guidance provided in L1C-105 is consistent with industry guidance prepared by NEI in NEI 99-04, "Guidelines for Managing NRC Commitment Changes."

As defined in NEI 99-04 and according to L1C-105, a "regulatory commitment" is an explicit statement to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on the docket to the NRC. L1C-105 directs the NRR staff to audit the licensee's commitment management program by assessing the adequacy of the licensee's implementation of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and activities (bulletins, generic letters, etc.). L1C-105 instructs the NRR project managers to perform audits of the licensees' commitments every 3 years.

The guidance that Indiana Michigan Power Company (I&M, the licensee) developed for the Donald C. Cook Nuclear Plant (CNP) to manage commitments made to the NRC and other regulatory and oversight agencies is established in procedure PMP-2350-CMS-001, "Commitment Management," Revision 3, effective July 31,2009. This procedure details the CNP commitment management process, including defining responsibilities, commitment Enclosure

- 2 identification and tracking, extension of commitment due dates, commitment closure, periodic review of commitments, and implementing changes to regulatory commitments.

On August 4-5, 2009, the NRC staff performed an audit of the regulatory commitments management program at CNP, Units 1 and 2. A summary of the NRC staff's activities, reviews, and conclusions is outlined below.

2.0 AUDIT PROCEDURE AND RESULTS On August 4-5, 2009, the NRC staff performed the regulatory commitments management audit at the CNP, Units 1 and 2. L1C-105Iimits the audit of commitments to those made by the licensee in writing to the NRC as a result of licensing actions (e.g., amendments, relief requests, exemptions, etc.) or licensing activities (e.g., bulletins, generic letters, etc.).

In preparation for the audit, the NRC staff searched in ADAMS for licensing actions, licensing activities, and other reports involving regulatory commitments and regulatory commitment changes during past 3 years. The staff also contacted I&M and obtained its list of regulatory commitments reported to the NRC staff during the past 3-year period. From the collected information, the NRC staff selected a representative sample of regulatory commitments that met the selection criteria identified in L1C-105 for the audit. The NRC staff asked I&M to provide the requisite documentation related to the commitments sample selected to support the audit.

The documents furnished by I&M included summary sheets providing the status of the commitments, the respective commitment management number(s), source documents, and appropriate backup documentation as needed (i.e., plant procedures, examination records, and/or other plant documentation). The regulatory commitments management records reviewed by the NRC were summaries of regulatory commitments implementation records, and summaries of regulatory commitments change reports.

The audit excluded the following types of commitments that are internal to licensee processes:

(1) Commitments made on the licensee's own initiative among internal organizational components.

(2) Commitments that pertain to milestones of licensing action/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.

(3) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee by the licensee having taken timely action in accordance with the subject requirements.

2.1 Verification of Licensee's Program for Implementation of Regulatory Commitments The NRC staff's audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff in past licensing communications.

- 3 The NRC staff found that licensee procedure PMP-2350-CMS-001 was an effective tool for managing and maintaining regulatory commitments, and generally provided an acceptable program as described in NEI 99-04.

The licensee enters the regulatory commitments made to the NRC that are explicit statements to take a specific action agreed to, or volunteered by a licensee, and submitted in writing on docket to the NRC into a commitment database. Each commitment is numbered and described by a commitment title and brief description. Comments and implementation dates are captured.

The licensee's staff is regularly trained in procedures for entering and updating the regulatory commitments in its regulatory commitments management program. The regulatory commitments program procedure, PMP-2350-CMS-001, is followed in documenting, tracking, and implementing the regulatory commitments.

The sources of the commitments are documented in a source document. Incorporating documents provide the procedures or processes for maintaining and implementing the commitments. Closing documents provide the procedure or process for assuring that each regulatory commitment was properly completed, appropriately closed, and well documented. summarizes the representative sample of selected regulatory commitments that were evaluated for this audit. Based on the review of the selected sample of the regulatory commitments, the NRC staff concludes that the licensee's regulatory commitments management program generally conforms to the NRC accepted guidance in NEI 99-04, and is acceptable.

2.2 Verification of Licensee's Processes for Changes to Regulatory Commitments The regulatory commitments changes are evaluated in accordance with provisions of Nuclear Energy Institute's guidance in NEI 99-04, "Guidelines for Managing NRC Commitments." The changes are reported to NRC biannually.

Based on its review, the NRC staff concludes that the changes to regulatory commitments are being reported to the NRC consistent with the NRC guidance.

3.0 CONCLUSION

The NRC staff concludes, based on the results of the on-site audit of I&M procedures, processes, and documentation for managing regulatory commitments, that I&M has implemented the regulatory commitments management program effectively, and implemented regulatory commitment changes appropriately, in accordance with L1C-105 and generally consistent with the NRC accepted guidance in NEI 99-04.

- 4 4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Michael K Scarpello Paul Schoepf Julie Newmiller Principal Contributor:

Terry A. Beltz Date: August 19, 2009

Attachment:

As stated

ATTACHMENT REGULATORY COMMITMENTS -

SUMMARY

OF AUDIT RESULTS AUDIT PERFORMED AUGUST 4-5, 2009 DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2

REGULATORY COMMITMENTS -

SUMMARY

OF AUDIT RESULTS AUDIT PERFORMED AUGUST 4-5, 2009 DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 Letter Number Subject Commitment /

CR Action No.

Description of Commitment Implementation Status AEP:NRC:6054-07 Donald C. Cook Nuclear Plant, 8418 This information pertains to RAls or other GL 2004-02 CLOSED on 02/29/2008 10 CFR 50.54(f)

Units 1 and 2 - Revision of Commitments for Additional issues requested in the letter from P.S. Tam, NRC, to M.K. Nazar, I&M, dated February 9,2006 12/19/2006 Information Regarding Nuclear Regulatory Commission Generic (ML060370547).

ML063610088 Letter 2004-02 The licensee will provide future update(s) within 60 days after all the information and supporting analysis results are available, but no later than December 31,2007.

AEP:NRC:7504 10 CFR 50.4 02/09/2007 ML070520400 Donald C. Cook Nuclear Plant, Units 1 and 2 - Hydrogen Igniter Backup Power Supply 8440 Install design modifications in both Unit 1 and Unit 2 to provide an alternative method of activating the hydrogen igniters from an area other that the control room complex.

The commitment date is December 31,2007.

CLOSED on 12/27/2007 CLOSED on 11/05/2007 AEP:NRC:6055-09 Donald C. Cook Nuclear Plant, 8420 Withdraw approved relief requests ISIR-005 and 10 CFR 50.55a(3)(i)

Units 1 and 2 - Request for Approval of Risk-Informed ISIR-006.

09/29/2006 Inservice Inspection Program for Class 1 and 2 Piping American Following approval and implementation of the risk-informed inservice inspection program.

ML062850540 Society of Mechanical Engineers Code, Category B-F, B-J, C-F-1 and C-F-2 Piping Welds CLOSED AEP:NRC:2073-38 Donald C. Cook Nuclear Plant, 8421 - 8430 I&M provided a list of commitments regarding 10 CFR 50.4 Units 1 and 2 - Response Providing Information Regarding requirements specified in Section B.5.b of NRC Orders related to mitigation strategies required by site security 8421 - 04/20/2007 8426 - 05/31/2007 01/10/2007 Implementation Details for the Phase 2 and 3 Mitigation and emergency plans.

8422 - 04/20/2007 8427 - 08/31/2007 8423 - 04/20/2007 8428 - 08/16/2007 ML070230486 Strategies Scheduled completion dates were from 04/30/2007 through 12/30/2007.

8424 - 03/13/2007 8429 - 12/06/2007 8425 - 05/31/2007 8430 - 12/20/2007

- 2 Letter Number Subject Commitment I CR Action No.

Description of Commitment Implementation Status AEP:NRC:6055-16 AEP:NRC:6055-17 10 CFR 50.55a 09/26/2006 09/26/2006 ML062720122 ML062780203 Donald C. Cook Nuclear Plant, Unit 1 - Supplement to Proposed Alternatives to the American Society of Mechanical Engineers Code,Section XI, Repair Requirements 8409 Complete stress analysis summaries of the preemptive weld overlay prior to restart of Unit 1 and provide the summaries within four weeks after restart from the Unit 1 (Fall 2006) refueling outage.

CLOSED on 12/07/2006 AEP:NRC:6055-16 Donald C. Cook Nuclear Plant, 8410 Provide the Preemptive Weld Overlay ultrasonic CLOSED on 11/06/2006 AEP:NRC:6055-17 Unit 1 - Supplement to examination results to the NRC.

10 CFR 50.55a Proposed Alternatives to the American Society of Mechanical The results will include:

09/26/2006 Engineers Code,Section XI, a listing of indications detected 09/26/2006 Repair Requirements the disposition of all indications using the standards of the ASME Code,Section XI, ML062720122 IWB-3514-3 andlor IWB-3514-3 criteria and, if ML062780203

possible, the type and nature of the indications.

Also included in the results will be a discussion of any repairs to the overlay material andlor base metal and the reason for the repair.

Subsequent inservice examination of the structural weld overlays on pressurizer will be in accordance with ASME Code,Section XI, Appendix Q, Q-4300 The information will be provided within 14 days after the completion of the last ultrasonic examination of the weld overlays.

- 3 Letter Number Subject Commitment /

CR Action No.

Description of Commitment Implementation Status AEP:NRC:6046-01 Donald C. Cook Nuclear Plant, 8302

1) Provide a new Unit 1 small break LOCA analysis of CLOSED on 03/29/2007 AEP:NRC:7046-01 Units 1 and 2 - Thirty-Day the safety injection cross-tie valves closed case.

AEP:NRC:7046-03 Report for Loss-of-Coolant 10 CFR 50.46 Accident (LOCA) Evaluation Model Changes Scheduled completion date is March 2007.

12/07/2006 8385

2) Provide a new Unit 1 large break LOCA analysis.

CLOSED on 12/27/2007 06/15/2007 10/16/2007 Scheduled completion date is December 2007.

ML063530324 8304

3) Provide a new Unit 2 small break LOCA analysis of CLOSED on 03/30/2009 ML071770136 both the safety injection cross-tie valves closed case and ML072990070 the safety injection cross-tie valves open case.

Scheduled completion date is March 2009.

8306

4) Provide a new Unit 2 large break LOCA analysis.

Schedule completion date is March 2009.

CLOSED on 03119/2009 AEP:NRC:7565-01 Donald C. Cook Nuclear Plant.

8482 Complete the residual heat removal (RHR) cross-tie CLOSED on 04/23/2008 10 CFR 50.90 Units 1 - License Amendment Request Regarding Loss-of valve modification, allowing the Donald C. Cook Nuclear Plant, Unit 1, to operate with RHR cross-tie valves open 12/27/2007 Coolant Accident Analysis Methodology and four-loop injection during a postulated large break LOCA.

ML080090299 License amendment request approval and modification completion prior to entering Mode 3 following the Unit 1, Cycle 22, refueling outage.

Due Date: 04/30/2008

- 4 Letter Number Subject Commitment 1 CR Action No.

Description of Commitment Implementation Status AEP:NRC:8054-04 AEP-NRC-2008-43 10 CFR Part 50.54(f)

Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 Perform system walkdowns in Unit 1 and Unit 2 Containment as required for the response to GL 2008-01.

April 10, 2008 (3-month response)

October 14,2008 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat 8459 Unit 1 - Scheduled completion date is by the end of the Unit 1 RFO (U1C23) planned for Fall 2009.

Note: U1C23 scheduled for Spring 2010.

Due Date: 03/31/2010 OPEN (9-month response)

ML081120235 ML082950467 Removal, and Containment Spray Systems" 8458 Unit 2 - Scheduled completion date is by the end of the Unit 2 RFO (U2C18) planned for Spring 2009.

Due Date: 04114/2009 CLOSED on 04/04/2009 AEP:NRC:8054-04 Donald C. Cook Nuclear Plant, Provide a supplemental evaluation for Unit 1 and Unit 2 AEP-NRC-2008-43 Units 1 and 2 - Response to in response to GL 2008-01.

10 CFR Part 50.54(f) NRC Generic Letter 2008-01 issued pursuant to 10 CFR 8461 Unit 1 - Scheduled completion date is within 3 months OPEN April 10, 2008 50.54(f), "Managing Gas following the end of the Unit 1 RFO (U1C23) planned for (3-month response)

Accumulation in Emergency Fall 2009.

October 14, 2008 Core Cooling, Decay Heat Note: U1C23 scheduled for Spring 2010.

(9-month response)

Removal, and Containment Due Date: 06/15/2010 Spray Systems" 8460 ML081120235 Unit 2 - Scheduled completion date is within 3 months CLOSED on 07/24/2009 ML082950467 following the end of the Unit 2 RFO (U2C18) planned for Spring 2009.

- 5 Letter Number Subject Commitment I CR Action No.

Description of Commitment Implementation Status AEP-NRC-2008-43 Donald C. Cook Nuclear Plant, 8462 Create a Gas Accumulation Condition Monitoring CLOSED on 03/12/2009 10 CFR Part 50.54(f)

Units 1 and 2 - Response to NRC Generic Letter 2008-01 Program document. This document will contain the following:

October 14, 2008 issued pursuant to 10 CFR Performance Monitoring - Description of the (9-month response) 50.54(f), "Managing Gas Accumulation in Emergency routine monitoring and trending of plant parameters that may indicate an increased ML082950467 Core Cooling, Decay Heat Removal, and Containment Spray Systems" potential for gas accumulation.

Testing - Location and periodicity of UTs performed to monitor ECCS piping for void formation Evaluation - Methodology for evaluating identified voids, including acceptance criteria for operability.

Scheduled completion date is March 14,2009.

AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" 8476 Add a description of the Gas Accumulation Condition Monitoring Program to the UFSAR.

Scheduled completion date is March 31, 2009.

CLOSED on 03/26/2009 AEP-NRC-2008-43 Donald C. Cook Nuclear Plant, 8470 Evaluate the STF Traveler for gas accumulation to either OPEN 10 CFR Part 50.54(f) Units 1 and 2 - Response to NRC Generic Letter 2008-01 supplement or replace the current TS requirements.

October 14,2008 issued pursuant to 10 CFR Scheduled completion date is 60 days after the TSTF is (9-month response) 50.54(f), "Managing Gas Accumulation in Emergency approved by the NRC.

ML082950467 Core Cooling, Decay Heat Removal, and Containment Spray Systems" Due date is contingent upon NRC issuance of TSTF.

- 6 Letter Number AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14,2008 (9-month response)

ML082950467 Subject Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Commitment 1 CR Action No.

8463 8464 8471 8465 8472 8466 Description of Commitment Incorporate interim criteria for operability into the Gas Accumulation Condition Monitoring Program.

Scheduled completion date is March 14, 2009. This date coincides with creation of the Gas Accumulation Condition Monitoring Program document.

Add a vent to the CCP Appendix R discharge unit crosstie. (1)

Scheduled completion date is by the end of the Unit 2 RFO (U2C18) planned for Spring 2009.

Add vent valves to the RCP seal line. (1)

Unit 1 - Scheduled completion date is by the end of the Unit 1 RFO (U1C23) planned for Fall 2009.

Note: U1C23 scheduled for Spring 2010.

Unit 2 - Scheduled completion date is by the end of the Unit 2 RFO (U2C18) planned for Spring 2009.

Add a vent valve to the CCP ELO piping downstream of the flow restricting orifice. (1)

Unit 1 - Scheduled completion date is by the end of the Unit 1 RFO (U1C23) planned for Fall 2009.

Note: U1C23 scheduled for Spring 2010.

Unit 2 - Scheduled completion date is by the end of the Unit 2 RFO (U2C18) planned for Spring 2009.

Implementation Status CLOSED on 03112/2009 CLOSED on 04/14/2009 OPEN CLOSED on 04/29/2009 OPEN CLOSED on 04/16/2009 Note (1): In the event of a unit shutdown of extended duration, the modifications will be installed prior to startup if it is determined that there will be no impact on the unit return to service schedule.

- 7 Letter Number AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14,2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 AEP-NRC-2008-43 10 CFR Part 50.54(f)

October 14, 2008 (9-month response)

ML082950467 Subject Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Donald C. Cook Nuclear Plant, Units 1 and 2 - Response to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Commitment 1 CR Action No.

8473 8467 8477 8483 Description of Commitment Complete walkdown of piping inside the Auxiliary Building LDEs.

Scheduled completion date is January 15, 2009.

Modify the Work Control procedure to better describe the role of the Work Assessment Group in preventing gas intrusion.

Scheduled completion date is March 14,2009.

Develop a guideline for outage scheduling to assist in the proper schedule sequencing of maintenance activities and system restoration.

Scheduled completion date is March 14, 2009.

Monitor ongoing industry programs for Gas Accumulation.

Gas transport in pump suction piping Pump gas void ingestion tolerance limits Commitment for monitoring is an ongoing evolution.

Implementation Status CLOSED on 01/14/2009 CLOSED on 03/13/2009 CLOSED on 03/09/2009 OPEN

- 8 Letter Number Subject Commitment I CR Action No.

Description of Commitment Implementation Status AEP-N RC-2008-43 Donald C. Cook Nuclear Plant, 8478 Define added scope of UTs and documents in the Gas CLOSED on 03112/2009 10 CFR Part 50.54(f) Units 1 and 2 - Response to NRC Generic Letter 2008-01 Intrusion Condition Monitoring Program.

October 14, 2008 issued pursuant to 10 CFR Scheduled completion date is March 14, 2009.

(9-month response) 50.54(f), "Managing Gas Accumulation in Emergency ML082950467 Core Cooling, Decay Heat Removal, and Containment Spray Systems" AEP:NRC:8046 Donald C. Cook Nuclear Plant, 8457 Provide the NRC information on the Unit 1 small break CLOSED on 07/24/2008 10 CFR 50.46 Units 1 - Response to Request for Additional Information LOCA analysis 8.75-inch case using the corrected flow rates.

February 29, 2008 Regarding the Reanalysis of Unit 1 Small Break LOCA Scheduled submittal date is June 30, 2008.

ML090740053 NRR provided verbal authorization on June 27, 2008, to extend due date to July 25, 2008.

AEP:NRC:8054-02 Donald C. Cook Nuclear Plant, 8442 Modify the insulation on the NESW lines inside the crane CLOSED on 04/20/2008 10 CFR 50.54(f)