AEP-NRC-2011-38, Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses
| ML11256A017 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/01/2011 |
| From: | Gebbie J Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2011-38, TAC ME7115, TAC ME7116 | |
| Download: ML11256A017 (4) | |
Text
Indiana Michigan Power INDIANIA Cook Nuclear Plant MICHIGAN One Cook Place Pi M R Bridgman, MI 49106 AERcom A unit of American Electric Power September 1,2011 AEP-NRC-2011-38 10 CFR 50.4 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 REVISION TO REGULATORY COMMITMENTS ASSOCIATED WITH APPLICATION FOR RENEWED OPERATING LICENSES
Reference:
- 1) Letter from M. K. Nazar, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket No. 50-315 and 50-316, Application for Renewed Operating Licenses,"
AEP:NRC:3034, dated October 31, 2003.
- 2) Letter from J. N. Jensen, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission, "Donald C. Cook Nuclear Plant Units 1 and 2, Docket No. 50-315 and 50-316, License Renewal Application - Response to Requests for Additional Information," AEP:NRC:4034-17, dated October 18, 2004.
- 3) Regulatory Issue Summary 2011-07, "License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management," dated July 21, 2011.
Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP),
Units 1 and 2, is providing notification, in this letter, of changes to commitments documented in Reference 1 and Reference 2.
In Reference 1, I&M made the following commitment with a due date of October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2:
The following enhancements to the System Testing Program will be implemented prior to the period of extended operation:
Develop a PM [preventive maintenance] procedure to inspect the centrifugal charging pumps minimum flow orifices and the Unit 1 centrifugal charging pumps discharge orifices.
Ensure procedures for engineered safety features ventilation unit, the fuel handing area exhaust unit, and the control room ventilation unit surveillance testing include visual verification that the drain valves and drain piping have not experienced loss of material to the extent that their pressure boundary function is compromised.
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U. S. Nuclear Regulatory Commission AEP-NRC-2011-38 Page 2 I&M is changing this commitment because the Unit 1 centrifugal charging pumps no longer have discharge orifices. The orifices were removed. Therefore, the words "and the Unit 1 centrifugal charging pumps discharge orifices" are being deleted from the commitment language.
Additionally, inspection of the centrifugal charging pumps minimum flow orifices is not possible.
These components are multi-stage flow restricting orifices, which are welded in place and cannot be disassembled for an internal inspection without being destroyed. The purpose of the preventive maintenance for these orifices is to inspect for internal erosion. There are other methods available that can indicate degradation due to internal erosion (e.g., hydraulic surveillance parameters). Therefore, this commitment is being revised to state, "Develop a periodic surveillance for the centrifugal charging pump minimum flow orifice to detect internal erosion."
In Reference 2, I&M made the following commitment with a due date of October 25, 2011, for Unit 1 and December 23, 2014, for Unit 2:
I&M will submit the Reactor Vessel Internals Plates, Forgings, Welds, and Bolting Program for NRC Staff review and approval three years prior to the period of extended operations.
I&M is changing this commitment consistent with guidance in Reference 3.
Reference 3 provides guidance to licensees on acceptable changes to existing license renewal commitments for aging management programs (AMP) in order to account for the recent issuance of the NRC's Safety Evaluation of MRP-227, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, Revision 0, and the forthcoming issue of the NRC approved MRP-227. CNP is in Category B as defined in Reference 3, which are plants that have received renewed licenses but have not yet been required to submit their programs for NRC review and approval per their commitments. Reference 3 states that for Category B plants, licensees who would be required to make their submittals prior to one year after issuance of Reference 3 may modify their commitments to reflect a requirement to submit their AMP no later than October 1, 2012.
Therefore, this commitment is being revised to change the due date for Unit 1 from October 25, 2011, to October 1, 2012. The due date for Unit 2 remains December 23, 2014.
This letter contains no new regulatory commitments and two revised regulatory commitments as summarized in the enclosure to this letter.
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 JEN/jmr Enclosure
U. S. Nuclear Regulatory Commission AEP-NRC-2011-38 Page 3 c:
J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosure MDEQ - WHMD/RPS NRC Resident Inspector M. A. Satorius, NRC Region III P. S. Tam, NRC Washington DC
ENCLOSURE TO AEP-NRC-2011-38 REGULATORY COMMITMENTS The following table identifies those actions committed to by Indiana Michigan Power Company (I&M) in this document. Any other actions discussed in this submittal represent intended or planned actions by I&M. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Commitment Date The following enhancements to the System Testing Program will be implemented prior to the period of extended operation:
Unit 1:
Develop a periodic surveillance for the centrifugal October 25, 2014 charging pump minimum flow orifice to detect internal erosion.
Unit 2:
Ensure procedures for engineered safety features December 23, 2017 ventilation unit, the fuel handing area exhaust unit, and the control room ventilation unit surveillance testing include visual verification that the drain valves and drain piping have not experienced loss of material to the extent that their pressure boundary function is compromised.
I&M's Supplemental Response to RAI B.1.27-2:
[NOTE: This commitment supplements I&M's LRA commitment Unit 1:
to develop and implement a Reactor Vessel Internals Plates, October 1, 2012 Forgings, Welds, and Bolting Program prior to the period of extended operation.]
Unit 2:
December 23, 2014 I&M will submit the Reactor Vessel Internals Plates, Forgings, Welds, and Bolting Program for NRC Staff review and approval three years prior to the period of extended operation for Unit 2 and no later than October 1, 2012, for Unit 1.