AEP-NRC-2013-66, Response to Request for Additional Information Concerning Revisions to Regulatory Commitments Associated with the Preventive Maintenance and Structures Monitoring Programs within the Application for Renewed Operating Licenses

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Response to Request for Additional Information Concerning Revisions to Regulatory Commitments Associated with the Preventive Maintenance and Structures Monitoring Programs within the Application for Renewed Operating Licenses
ML13240A129
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 08/22/2013
From: Gebbie J
Indiana Michigan Power Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2013-66
Download: ML13240A129 (5)
v • d • e


Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant WEROne Cook Place PO WROBridgmnan, MI 49106 A unit ofAmerican Electric Power Indiana Michigan Power.com August 22, 2013 AEP-NRC-2013-66 10 CFR 50.4 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Response to Request for Additional Information Concerning Revisions to Regulatory Commitments Associated with the Preventive Maintenance and Structures Monitoring Programs within the Application for Renewed Operating Licenses for Donald C. Cook Nuclear Plant Units 1 and 2

References:

1. NUREG-1831, "Safety Evaluation Report Related to the License Renewal of the Donald C. Cook Nuclear Plant, Units 1 and 2," dated May 2005 (ADAMS Accession No. ML051510092).
2. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M),

to Nuclear Regulatory Commission (NRC), "10 CFR 50.71(e) Update and Related Site Change Reports," AEP-NRC-2010-61, dated October 8, 2010.

3. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses," AEP-NRC-2013-15, dated March 1, 2013 (ADAMS Accession No. ML13073A110).
4. Email from T. Wengert, NRC, to H. Etheridge, I&M, "DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)," dated July 11, 2013 (ADAMS Accession No. ML13213A447).

This letter provides Indiana Michigan Power Company's (l&M's), licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, response to the Request for Additional Information (RAI) from the U. S. Nuclear Regulatory Commission (NRC) regarding revision to regulatory commitments associated with application for renewed operating license.

A 130i

U. S. Nuclear Regulatory Commission AEP-NRC-2013-66 Page 2 By Reference 1, the NRC documented I&M's commitment to enhance CNP's Preventive Maintenance and Structures Monitoring Programs by implementing specific attributes identified within Sections B.1.25 (Pages B-86 and B-87) and B.1.32 (Pages B-101 and B-102) of I&M's license renewal application for CNP prior to the period of extended operation for each unit.

By Reference 2, I&M supplemented the commitments within Reference 1.

By Reference 3, I&M notified the NRC of a revision to exclude CNP's security diesel generator and the security diesel generator room from the commitments within References 1 and 2, consistent with NRC regulations, 10 CFR 54.4 and 10 CFR 50, Appendix R. Reference 4 is the NRC's RAI regarding I&M's request to exclude CNP's security diesel generator from inclusion within CNP's Preventive Maintenance Program, and to exclude CNP's security diesel generator room from inclusion within CNP's Structures Monitoring Program. provides I&M's responses to the RAI in Reference 4.

Although this letter contains no new or revised commitments, it pertains to I&M's request within Reference 3 to revise commitments within CNP's current licensing basis.

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/dmb

Enclosure:

Indiana Michigan Power Company's Response to Request for Additional Information Concerning Revision to Regulatory Commitments Associated with the Preventive Maintenance and Structures Monitoring Programs within the Application for Renewed Operating Licenses for Donald C. Cook Nuclear Plant, Units 1 and 2 c:

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

ENCLOSURE I TO AEP-NRC-2013-66 Indiana Michigan Power Company's Response to Request for Additional Information Concerning Revision to Regulatory Commitments Associated with the Preventive Maintenance and Structures Monitoring Programs within the Application for Renewed Operating Licenses for Donald C. Cook Nuclear Plant, Units I and 2 Documents referenced herein are provided as references at the end of this Enclosure.

NRC RAI-1 Table 2.4.4-1 of the CNP license renewal application (LRA) listed the security diesel generator room as a yard structure with a license renewal function of shelter and support for the security diesel generator, which provides lighting required for 10 CFR 50.48, in accordance with the scoping criteria in 10 CFR 54.4(a)(3). LRA Section 2.3.3.6 also states that the function of the security diesel is to provide power for emergency lighting for access to nitrogen regulator valves and that the security diesel is required to support the Appendix R safe shutdown analysis...

Indicate specifically what equipment, relative to the function stated above, is credited in the Appendix R safe shutdown analysis.

I&M RESPONSE TO NRC RAI-1 The 10 CFR Part 50, Appendix R safe shutdown analysis for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2 no longer credit any equipment as a backup source of power to emergency lighting in the vicinity of nitrogen regulator valves located outside of the power block building.

On May 26, 1987, the U. S. Nuclear Regulatory Commission (NRC) issued Indiana Michigan Power Company (I&M), the licensee for CNP Units 1 and 2, an exemption (Reference 1) from a requirement within 10 CFR Part 50, Appendix R (Reference 2), for an 8-hour battery power supply to emergency lighting associated with operation of safe shutdown equipment at CNP during a fire.

Reference 1 permitted use of CNP's security diesel generator as a source of power for emergency lighting to nitrogen regulator valves.

Because CNP's 10 CFR 50, Appendix R safe shutdown analysis at the time (Reference 3, Attachment 2, Pages 1-5) took credit for manual operation of the nitrogen regulator valves as a backup source of motive force to steam generator power-operated relief valves (SG PORVs), CNP's security diesel generator was identified within CNP's Operating License Renewal Application for Units 1 and 2 (Reference 4, Section 2.3.3.6) as a structure, system, or component with functions satisfying NRC operating license renewal review criteria at 10 CFR 54.4 (Reference 5).

Because the SG PORVs can also operate automatically (they are designed with both a spring and power actuator relief valve function and would open as system pressure increases) when the plant is in the hot stand by condition (Reference 6 at Page 33), I&M in October 2009 revised CNP Technical Evaluation 12.7 (Reference 7) to remove the nitrogen regulator valves as a source of backup motive force for SG PORVs within CNP's 10 CFR Part 50, Appendix R safe shutdown analysis.

to AEP-NRC-2013-66 Page 2 The removal of the nitrogen regulator valves from CNP's 10 CFR 50, Appendix R safe shutdown analysis eliminated the need for the emergency lighting associated with the security diesel generator. Consequently, both the security diesel generator and the security diesel generator room no longer satisfied NRC operating license renewal scoping criteria in 10 CFR 54.4.

Because CNP's 10 CFR 50, Appendix R safe shutdown analysis does not require an 8-hour backup power supply to emergency lighting in the vicinity of the nitrogen regulator valves, CNP no longer credits any equipment as a source of power to emergency lighting in the vicinity of nitrogen regulator valves.

NRC RAI-2 If equipment other than the security diesel is used to perform the stated function, state whether the equipment and supporting or sheltering structures or components are in scope of the Structures Monitoring AMP.

If those structures or components are not in the Structures Monitoring AMP, provide technical bases for excluding them from the program.

I&M RESPONSE TO NRC RAI-2 As explained above, CNP no longer credits any equipment as a source of power to emergency lighting in the vicinity of nitrogen regulator valves. Consequently, the security diesel generator and the security diesel generator room do not satisfy the NRC operating license renewal scoping criteria at 10 CFR 54.4, and need not be included in CNP's Preventive Maintenance or Structures Monitoring Programs.

REFERENCES:

1. Letter from D. L Wigginton, Nuclear Regulatory Commission (NRC), to J. Dolan, Indiana Michigan Electric Company (I&M),

"Exemption from Certain Requirements of 10 CFR Part 50, Appendix R, Section III J - Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2," dated May 26, 1997.

2. 10 CFR 50, Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979."
3. "Technical Evaluation 12.7 Donald C Cook Nuclear Plant Safe Shutdown Manual Activity Feasibility Study," Revision 4, dated February 3, 2006.
4. Donald C. Cook Nuclear Plant Units 1 and 2 Operating License Renewal Application, dated October 2003.
5. 10 CFR 54.4, "Scope" of Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
6. "American Electric Power Nuclear Generation Donald C. Cook Nuclear Plant Safe Shutdown Capability Assessment", Revision 15, dated July 29, 2011.

to AEP-NRC-2013-66 Page 3

7.

"Technical Evaluation 12.7 Donald C Cook Nuclear Plant Safe Shutdown Manual Activity Feasibility Study," Revision 5, dated October 26, 2009.

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