AEP-NRC-2013-06, Unit 2, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 1, Integrated Assessment Approach

Unit 2, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 1, Integrated Assessment Approach

ML13037A305
Person / Time
Site:	Cook
Issue date:	01/25/2013
From:	Gebbie J Indiana Michigan Power Co, American Electric Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2013-06
Download: ML13037A305 (4)

Text

INDIANA MICHIGAN Indiana Michigan Power POWERO One Cook Place Bridgman, MI 49106 A unit ofAmerican Electric Power IndianaMichiganPower.com January25, 2013 AEP-NRC-2013-06 10 CFR 50.54(f) 10 CFR 50.4 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

Subject:

Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 1, Integrated Assessment Approach

References:

1) NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident; dated March 12, 2012, Accession No. ML12073A348.

2) NRC Japan Lessons-Learned Project Directorate, JLD-ISG-2012-05, Guidance for Performing the Integrated Assessment for External Flooding, Interim Staff Guidance, Revision 0, dated November 30, 2012, Accession No. ML12311A214.

3) NRC Letter, D. L. Skeen Nuclear Regulatory Commission (NRC) to J. E. Pollock Nuclear Energy Institute (NEI), Trigger Conditions for Performing an Integrated Assessment and Due Date for Response, dated December 3, 2012, Accession No. ML12326A912.

4) AEP-NRC-2012-41, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f)

Regarding theFlooding Aspects ýof Recommendations 2.1 and 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated June 8, 2012.

On March 12, 2012, the NRC issued Reference 1 to request information associated with Near-Term Task Force (NTTF) Recommendation 2.1 for Flooding. One of the Required Responses in this letter directed licensees to submit an approach for developing an Integrated Assessment Report, including criteria for identifying vulnerabilities, within 60 days after issue of the NRC's guidance on the subject (Reference 2). Additionally, Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, committed in Reference 4 to submit an approach for developing an Integrated Assessment. This letter provides the 60 day response for I&M.

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U.S. Nuclear Regulatory Commission AEP-NRC-2013-06 Page 2 OnNovember 30, 2012, the NRC issued the Reference 2 Interim Staff Guidance. I&M commits to use the Reference 2 guidance as the approach for developing the NTTF 2.1 flooding Integrated Assessment Report for CNP if the reevaluated flooding hazard is not bounded by the current design basis flooding evaluation.

I&M.also commits to use the guidance provided by Reference 3 regarding the trigger conditions and scope of any required Integrated Assessment.

This letter contains new regulatory commitments. If there are any questions concerning this letter, please contact Mr. Michael K. Scarpello, Manager, Nuclear Regulatory Affairs, at (269) 466-2649.

Sincerely, Joel P. Gebbie Site Vice President DMB/kmh

Enclosures:

1. Affirmation

2. Commitment c: C. A. Casto, NRC Region III J. T. King, MPSC S, M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ - RMD/RPS NRC Resident Inspector T. J. Wengert, NRC Washington, DC

Enclosure 1 to AEP-NRC-2013-06 AFFIRMATION I, Joel P. Gebbie, 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 Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME

,_0 DANIELLE BURGOYNE THIS 2 DAY OF '. 2013 Notary Public, State of Michigan County of Berrien My Commission Expires 04-q4-2018

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Enclosure 2 to AEP-NRC-2013-06 REGULATORY COMMITMENT 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 I&M will perform the external flood Integrated Assessment (if the March 12, 2017 reevaluated flooding hazard is not bounded by the current design basis flooding evaluation) using the guidance provided in NRC Japan Lessons-Learned Project Directorate, JLD-ISG-2012-05, "Guidance for Performing the Integrated Assessment for External Flooding", Interim Staff Guidance, and the guidance provided in NRC Letter, D. L. Skeen Nuclear Regulatory Commission (NRC) to J. E. Pollock Nuclear Energy Institute (NEI), "Trigger Conditions for Performing an Integrated Assessment and Due Date for Response," regarding the trigger conditions and scope of any required Integrated Assessment.