AEP-NRC-2010-31, Response to Second RAI Regarding License Amendment Request to Revise Operating Licenses, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan

Response to Second RAI Regarding License Amendment Request to Revise Operating Licenses, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan

ML100820078
Person / Time
Site:	Cook
Issue date:	03/19/2010
From:	Weber L Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2010-31, FOIA/PA-2010-0209, TAC ME0483, TAC ME0484
Download: ML100820078 (6)

Text

ENDIANA MICHIGAN Indiana Michigan Power P0V R One Cook Place Bridgman, MI 49106 A unit ofAmerican Electric Power IndianaMichiganPower.com March 19, 2010 AEP-NRC-2010-31 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Donald C. Cook Nuclear Plant Units 1 and 2 Docket No. 50-315 and 50-316 Response to Second Request for Additional Information Regarding License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan

References:

1. Letter from L. J. Weber, Indiana Michigan Power Company (I&M), to Nuclear Regulatory Commission (NRC) Document Control Desk, "License Amendment Request to Revise Operating Licenses DPR-58 and DRP-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan," AEP-NRC-2008-01, dated January 14, 2009 (ML090350210).

2. Letter from T. A. Beltz, NRC, to J. N. Jensen, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 -

Requests for Additional Information Re: License Amendment Request to Revise Operating Licenses, DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part, II, Non-Radiological Environmental Protection Plan (TAC Nos. ME0483 and ME0484)," dated September 2, 2009 (ML092400026).

3. Letter from L. J. Weber, I&M, to NRC Document Control Desk, "Response to Request for Additional Information Regarding License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan," AEP-NRC-2009-69, dated October 30, 2009 (ML093140255).

4. Letter from T. A. Beltz, NRC, to J. N. Jensen, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Request for Additional Information (Second Round) Re:

License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan (TAC Nos. ME0483 and ME0484)," dated March 8, 2010 (ML100670426).

Dear Sir or Madam:

This letter provides Indiana Michigan Power Company's (l&M's) response to a second request for additional information (RAI) regarding a proposed license amendment involving the Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2 Environmental Technical Specifications.

Lool

U. S. Nuclear Regulatory Commission AEP-NRC-2010-31 Page 2 In Reference 1, I&M submitted a license amendment request to revise Operating Licenses DPR-58 and DPR-74, Appendix B,

Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan for CNP Unit 1 and Unit 2. The amendment request proposed deletion of obsolete program information to relieve I&M of the burden of preparing and submitting unnecessary environmental reports. Reference 2 and Reference 3 transmitted, respectively, a Nuclear Regulatory Commission (NRC) RAI regarding the license amendment request and I&M's response to that RAI. Reference 4 transmitted a second RAI regarding the license amendment request. This letter provides I&M response to the second RAI. provides an affirmation statement pertaining to this letter. Enclosure 2 provides I&M's response to the RAI.

There are no new or revised commitments in this letter. Should you 'have any questions, please contact Mr. James M. Petro, Jr., Regulatory Affairs Manager, at (269) 466-2489.

Sincerely, Lawrence J. Weber Site Vice President RSP/rdw

Enclosures:

1.

Affirmation

2.

Response to Second Request for Additional Information Regarding License Amendment Request to Revise Environmental Technical Specifications c:

T. A. Beltz - NRC Washington, DC J. T. King - MPSC S. M. Krawec, Ft. Wayne AEP, w/o enclosures MDNRE - WHMD/RPS NRC Resident Inspector M. A. Satorius - NRC Region III to AEP-NRC-2010-31 AFFIRMATION I, Lawrence J. Weber, 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 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 Lawrence J. Weber Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF *[-tch

,2010 My Commission Expires

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A' to AEP-NRC-2010-31 Response to Second Request for Additional Information Regarding License Amendment Request to Revise Environmental Technical Specifications The references for this enclosure are identified on Page 3.

In Reference 1, Indiana Michigan Power company (I&M) submitted a license amendment request to revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2. The amendment request proposed deletion of obsolete program information to relieve I&M of the burden of preparing and submitting unnecessary environmental reports.

Reference 2 and Reference 3 transmitted, respectively, a Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding the license amendment request and I&M's response to that RAI.

Reference 4 transmitted a second RAI regarding the license amendment request.

I&M's response to the second RAI is provided below.

NRC RAI In Section 5.4.1, "Routine Reports," [of Attachment 2 to Reference 1] I&M provides justification for removing the Annual Environmental Operating Report by stating that the information contained in this report will be fully addressed through 10 CFR 50.72, 10 CFR 50.90, and existing CNP programs. However, when the NRC staff reviewed previous years' Annual Environmental Operating Reports, not all of the information contained in the report was readily locatable..

Please describe how (phone, letter, email, etc.) and to whomat the NRC (Operations Center, NRC Resident Inspector, Document Control Desk, DORL Project Manager, etc.) each of the following items in the Annual Environmental Operating Report is reported, and would continue to be reported, independent of the Annual Environmental Operating Report submittal:

i.

Non-routine reports ii. Herbicide Application Report iii. Molluscs Biofouling Monitoring Program Report iv. NPDES Applications

v. Special Reports (when applicable)

I&M Response to NRC RAI The specific items identified in the RAI are addressed below.

i.

Non-routine reports - These reports are currently transmitted to the NRC within 30 days of the occurrence, and summaries of these reports are currently included in the Annual Environmental Operating Report. These documents are transmitted in hard copy to the to AEP-NRC-2010-31 Page 2 NRC Document Control Desk, with copies to NRC Region Ill, the NRC Resident Inspector, and the NRC Licensing Project Manager.

Following NRC-approval of the amendment proposed in Reference 1, Section 5.4.2 of the Environmental Protection Plan will continue to require that non-routine reports be submitted to the NRC within 30 days of the occurrence.

In accordance with 10 CFR 50.4, such reports will be. submitted via a letter to the NRC Document Control Desk, with copies to the NRC Resident Inspector and the NRC Region III Office. Additionally, the applicable CNP procedure requires that a copy be sent to the NRC Licensing Project Manager.

ii. Herbicide Application Report - This information is currently reported only in the Annual Environmental Operating Report, which is transmitted to the NRC Document Control Desk in hard copy, with copies to NRC Region Ill, the NRC Resident Inspector, and the NRC Licensing Project Manager.

Following NRC-approval of the amendment proposed in Reference 1, written reports on herbicide application will continue to be filed in.the CNP Nuclear Document Management electronic document retrieval system when issued. The NRC Resident Inspector has access to documents in this electronic retrieval system.

Additionally, electronic copies or hardcopies of these reports can be provided to the applicable NRC office(s) upon request.

Note that, as proposed in Reference 1, Section 4.2.1 of the Environmental Protection Plan will continue to require that the use of herbicides conform to requirements by the Environmental Protection Agency (EPA) and state authorities. Herbicide reports will be prepared if required by the EPA or Michigan state authorities.

iii.

Mollusc Biofoulinq Monitoring Progqram Report - This information is currently reported only in the Annual Environmental Operating Report, which is transmitted to the NRC Document Control Desk in hard copy, with copies to NRC Region III, the NRC Resident Inspector, and the NRC Licensing Project Manager. Following NRC-approval of the amendment proposed in Reference 1, written reports on the mollusc monitoring and control activities in the plant service water and circulating water systems will continue to be filed in the CNP Nuclear Document Management electronic document retrieval system when issued.

The NRC Resident Inspector has access to documents in this electronic retrieval system. Additionally, electronic copies or hardcopies of these reports can be provided to the applicable NRC office(s) upon request.

Note that, as proposed in Reference 1, Section 2.1 of the Environmental Protection Plan will state that effluent limitations and monitoring requirements are contained in the NPDES or groundwater permits issued by the federal or state permitting authority, and the NRC will rely on these agencies for regulation of these matters as they involve water quality and aquatic biota.

Reports on the mollusc biofouling monitoring program effectiveness will be prepared if required by CNP procedures for the program.

iv. NPDES Applications -

Violations, changes, renewals, etc, of NPDES permit and state certifications are currently transmitted to the NRC when required by Section 3.2 of-the existing Environmental Protection Plan.

Summaries of these documents are currently included in the Annual Environmental Operating Report. These documents are transmitted in hard copy to the NRC Document Control Desk, with copies to NRC Region Ill, the NRC Resident Inspector, and the NRC Licensing Project Manager. Following NRC-approval of the amendment proposed in Reference 1, Section 3.2 of the Environmental Protection Plan will require that the NRC be provided a copy of the current NPDES permit or state certification within 30 days of approval. Section 3.2 will also require that changes to the to AEP-NRC-2010-31 Page 3 NPDES permit or state certification be reported to the NRC within 30 days of the date the change is approved.

In accordance with 10 CFR 50.4, these permits, certifications, and changes will be submitted via a letter to the NRC Document Control Desk, with copies to the NRC Resident Inspector and the NRC Region III Office.

Additionally, the applicable CNP procedure requires that a copy be sent to the NRC Licensing Project Manager.

v. Special Reports (when applicable) - This information is currently reported only in the Annual Environmental Operating Report, which is transmitted in hard copy to the NRC Document Control Desk, with copies to NRC Region Ill, the NRC Resident Inspector, and the NRC Licensing Project Manager.

Following NRC-approval of the amendment proposed in Reference 1, special reports will continue to be filed in the CNP Nuclear Document Management electronic document retrieval system when issued.

The NRC Resident Inspector has access to documents in this electronic retrieval system.

Additionally, electronic copies or hardcopies of these reports can be provided to the applicable NRC office(s) upon request.

References

1.

Letter from L. J. Weber, I&M, to NRC Document Control Desk, "License Amendment Request to Revise Operating Licenses DPR-58 and DRP-74, Appendix B,

Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan," AEP-NRC-2008-01, dated January 14, 2009 (ML090350210).

2.

Letter from T. A. Beltz, NRC, to J. N. Jensen, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Requests for Additional Information Re: License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan (TAC Nos.

ME0483 and ME0484)," dated September 2, 2009 (ML092400026).

3.

Letter form L. J. Weber, I&M, to NRC Document control Desk, "Response to Request for Additional Information Regarding License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan," AEP-NRC-2009-69, dated October 30, 2009 (ML093140255).

4.

Letter from T. A. Beltz, NRC, to J. N. Jensen, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Request for Additional Information (Second Round) Re: License Amendment Request to Revise Operating Licenses DPR-58 and DPR-74, Appendix B, Environmental Technical Specifications, Part II, Non-Radiological Environmental Protection Plan (TAC Nos.

ME0483 and ME0484),"

dated March 8,

2010 (ML100670426).