AEP-NRC-2013-15, Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses

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Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses
ML13073A110
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 03/01/2013
From: Gebbie J
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2013-15
Download: ML13073A110 (7)


Text

z INDIANA MICHIGAN POWER° A unit of American Electric Power Indiana Michigan Power Cook Nuclear Plant One Cook Place Bridgman, Ml 49106 IndianaMichiganPower.com AEP-NRC-2013-15 10 CFR 50.4 March 1, 2013 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

References:

1) Safety Evaluation Report Related to the License Renewal of the Donald C. Cook Nuclear Plant, Units 1 and 2 from the U.S. Nuclear Regulatory Commission to Indiana Michigan Power Company, dated May 2005.
2) Letter from J. P. Gebbie, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission, "10 CFR 50.71(e) Update and Related Site Change Reports," AEP-NRC-2010-61, dated October 8, 2010.

Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant, Units 1 and 2, is providing notification of a change to two commitments documented in Reference 1, and supplemented by Reference 2.

Change to Commitment 1:

In Reference 1, the U.S. Nuclear Regulatory Commission (NRC) documented that I&M made the following commitment (Reference 1, Appendix A, Item 16) with a due date of October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2:

The Preventive Maintenance (PM) Program will be enhar.ced to include the attributes documented in License Renewal Appi cation Section B.1.25, Pages B-86 and B-87, and as amended in the supplemental response to Request for Additional Information 2.3.3.8-6.

The following enhancements to the PM Program will be implemented prior to the period of extended operation:

Revise PM tasks for the emergency diesel generator ventilation system to include inspection of the flex joints; for the control room ventilation air handler packages to include inspection of the heat exchanger tubes and flex joints; and for the auxiliary feedwater pump room cooling units to include insp.ctici of the internal evaporator tubes, valves, and tubing;

U. S. Nuclear Regulatory Commission AEP-NRC-2013-15 Page 2 The PM program will manage the aging effects for the emergency diesel engine elastomer flex hoses or tubing, reactor coolant pump lube oil leakage collection components, rubber hoses in the compressed air system, rubber hoses in the Post-Accident Containment Hydrogen Monitoring System reagent gas supply, security diesel engine elastomer flex hoses or tubing, and elastomer condensate storage tanks floating head seals.

In Enclosure I of Reference 2, I&M made the following.supplement to this commitment with a due date of October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2:

The following enhancements will be made to the PM Program:

The PM program will manage the aging effects of the following components:

Flapper valve, flange, and flange bolts in the turbine room sump overflow line; Hatch over the flapper valve and hold down bolts; Rubber flex hoses and fittings in the backup air supply for the Essential Service Water strainer backwash valves.

I&M is changing this commitment to remove the statement, "security diesel engine elastomer flex hoses or tubing." I&M is changing this commitment because the security diesel generator engine does not meet the scoping requirements specified in 10 CFR 54.4, because the security diesel generator does not perform a safety function and is not credited for outside lighting for either the Appendix R or National Fire Protection Association (NFPA) 805 Fire Protection Programs. This commitment change is consistent with the guidance provided in NEI 99-04, Guidelines for Managing NRC Commitment Changes, dated July 1999.

The revised commitment will read as follows:

The Preventive Maintenance (PM) Program will be enhanced to include the attributes documented in License Renewal Application Section B.1.25, Pages B-86 and B-87, and as amended in the supplemental response to Request for Additional Information 2.3.3.8-6.

The following enhancements to the PM Program will be implemented prior to the period of extended operation:

Revise PM tasks for the emergency diesel generator ventilation system to include inspection of the flex joints, for the control room ventilation air handler packages to include inspection of the heat exchanger tubes and flex joints, and for the auxiliary feedwater pump room cooling units to include inspection of the internal evaporator tubes, valves, and tubing; The PM program will manage the aging effects for the emergency diesel engine elastomer flex hoses or tubing, reactor coolant pump lube oil leakage collection components, rubber hoses in the compressed air system, rubber hoses in the Post-Accident Containment Hydrogen Monitoring System reagent gas supply, and elastomer condensate storage tanks floating head seals.

U. S. Nuclear Regulatory Commission AEP-NRC-2013-15 Page 3 The PM program will manage the aging effects of the following components:

Flapper valve, flange, and flange bolts in the turbine room sump overflow line; Hatch over the flapper valve and hold down bolts; Rubber flex hoses and fittings in the back up air supply for the Essential Service Water strainer backwash valves.

Change to Commitment 2:

In Reference 1, the NRC documented that I&M made the following commitment (Reference 1, Appendix A, Item 23) with a due date of October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2:

The Structures Monitoring Program will be consistent with the program described in NUREG-1801, July 2001,Section XI.S6.

The program will be enhanced to include the attributes documented in License Renewal Application, Section B.1.32, Pages B-101 and B-102.

The following enhancements to the Structures Monitoring Program will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program: equipment supports, instrument panels, racks, cable trays, conduits, cable tray supports, conduit

supports, elastomers, pipe hangers/supports, fire protection pump house superstructure and walls, gas bottle storage tank rack and foundation, security diesel generator room, switchyard control house, fire protection water storage tank foundation, primary water storage tank foundation, and the roadway west of the screenhouse.

In Enclosure 1 of Reference 2, I&M made the following supplement to this commitment with a due date of October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2:

The following enhancements to the Structures Monitoring Program will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program:

Turbine sump emergency overflow sump; Ramp curbs at the turbine room entrance to passageway between the diesel generator rooms; The reinforced concrete grade beam wall and tops of the ramps on the west side of the Turbine Building I&M is changing this commitment to remove the statement, "security diesel generator room." I&M is changing this commitment because the security diesel generator room does not meet the scoping requirements specified in 10 CFR 54.4 because the security diesel generator does not perform a safety function and the security diesel is not credited for outside lighting for either the Appendix R or NFPA 805 Fire Protection Programs. This commitment change is consistent with the guidance provided in NEI 99-04, Guidelines for Managing NRC Commitment Changes, dated July 1999.

U. S. Nuclear Regulatory Commission AEP-NRC-2013-15 Page 4 The revised commitment will read as follows:

The Structures Monitoring Program will be consistent with the program described in NUREG-1801, July 2001,Section XI.S6.

The program will be enhanced to include the attributes documented in License Renewal Application, Section B.1.32, Pages B-101 and B-102.

The following enhancements will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program: equipment supports, instrument panels, racks, cable trays, conduits, cable tray supports, conduit supports, elastomers, pipe hangers/supports, fire protection pump house superstructure and walls, gas bottle storage tank rack and foundation, switchyard control house, fire protection water storage tank foundation, primary water storage tank foundation, and the roadway west of the screenhouse.

In addition, the following enhancements to the Structures Monitoring Program will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program:

turbine sump emergency overflow sump; ramp curbs at the turbine room entrance to passageway between the diesel generator rooms; the reinforced concrete grade beam wall and tops of the ramps on the west side of the Turbine Building.

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 KMH/ssl Enclosure

U. S. Nuclear Regulatory Commission AEP-NRC-2013-15 Page 5 c:

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

ENCLOSURE 1 TO AEP-NRC-2013-15 REGULATORY COMMITMENTS The following table identifies the revised action 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 Preventive Maintenance (PM) Program will be enhanced to Unit 1:

include the attributes documented in License Renewal October 25, 2014 Application Section B.1.25, Pages B-86 and B-87, and as amended in the supplemental response to Request for Additional Unit 2:

Information 2.3.3.8-6.

December 23, 2017 The following enhancements to the PM Program will be implemented prior to the period of extended operation:

Revise PM tasks for the emergency diesel generator ventilation system to include inspection of the flex joints; for the control room ventilation air handler packages to include inspection of the heat exchanger tubes and flex joints; and for the auxiliary feedwater pump room cooling units to include inspection of the internal evaporator tubes, valves and tubing.

" The PM program will manage the aging effects for the emergency diesel engine elastomer flex hoses or tubing, reactor coolant pump lube oil leakage collection components, rubber hoses in the compressed air system, rubber hoses in the Post-Accident Containment Hydrogen Monitoring System reagent gas supply, and elastomer condensate storage tanks floating head seals.

The PM program will manage the aging effects of the following components:

Flapper valve, flange, and flange bolts in the turbine room sump overflow line; Hatch over the flapper valve and hold down bolts; Rubber flex hoses and fittings in the back up air supply for the Essential Service Water strainer backwash valves.

to AEP-NRC-2013-15 Page 2 The Structures Monitoring Program will be consistent with the Unit 1:

program described in NUREG-1801, July 2001,Section XI.S6.

October 25, 2014 The program will be enhanced to include the attributes documented in License Renewal Application, Section B.1.32, Unit 2:

Pages B-101 and B-102.

December 23, 2017 The following enhancements will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program: equipment supports, instrument panels, racks, cable trays, conduits, cable tray supports, conduit

supports, elastomers, pipe hangers/supports, fire protection pump house superstructure and walls, gas bottle storage tank rack and foundation, switchyard control house, fire protection water storage tank foundation, primary water storage tank foundation, and the roadway west of the screenhouse.

In addition, the following enhancements to the Structures Monitoring Program will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program:

turbine sump emergency overflow sump; ramp curbs at the turbine room entrance to passageway between the diesel generator rooms; the reinforced concrete grade beam wall and tops of the ramps on the west side of the Turbine Building.