AEP-NRC-2013-72, Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13247A050
Person / Time
Site:	Cook
Issue date:	08/26/2013
From:	Gebbie J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2013-72, EA-12-051
Download: ML13247A050 (14)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POWER3 One Cook Place Bridgman, MI 49106 A unit ofAmerican Electric Power Indiana Michigan Powe r.cem August 26, 2013 AEP-NRC-2013-72 10 CFR 50.54(f)

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 Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. Letter from E. J. Leeds and M. R. Johnson, U. S. Nuclear Regulatory Commission (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," NRC Order Number EA-12-051, dated March 12, 2012, ML12054A682

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ML12221A339

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", Revision 1, dated August 2012, ML12240A307

4. Letter from J. P. Gebbie, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission, "Donald C. Cook Nuclear Plant Units 1 and 2, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA 051)," AEP-NRC-2012-85, dated October 26, 2012, ML12312A473

5. Letter from J. P. Gebbie, Indiana Michigan Power Company, to U. S. Nuclear Regulatory Commission, "Donald C. Cook Nuclear Plant Unit 1 and Unit 2, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 27, 2013, ML13071A323.

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U. S. Nuclear Regulatory Commission AEP-NRC-2013-72 Page 2 On March 12, 2012, the Nuclear Regulatory Commission issued an order (Reference 1) to Indiana Michigan Power Company (I&M), the licensee for the Donald C. Cook Nuclear Plant (CNP) Units 1 and 2. Reference 1 was immediately effective and directed I&M to establish reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided I&M's initial status report regarding mitigation strategies. Reference 5 provided I&M's overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports.

The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. Enclosure 1 to this submittal provides an affirmation. Enclosure 2 provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new or revised regulatory commitments. 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 DMB/kmh

Enclosure:

1. Affirmation

2. Indiana Michigan Power company's First Six month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation c: S. R. Jones, NRRPDSS/SBPB, NRC J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosure MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III T. J. Wengert, NRC Washington DC

Enclosure 1 to AEP-NRC-2013-72 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 f4A Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS c.S DAY OF j-,2013 DANIELLE BURGOYNE Notary Public, State of Michigan County of Berrien My Commission Expires 04-04-2018 My Com Notaryeslic " Acting In the County fr My Commission Expires - -' - *-\

ENCLOSURE 2 TO AEP-NRC-2013-72 Indiana Michigan Power Company's First Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation I Introduction Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP),

developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation, in response to (Reference 2 in Section 8). This enclosure provides an update of milestone accomplishments since submittal of the OIP. There are no changes to the compliance method, schedule, or need for relief/relaxation at this time.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the OIP, and are current as of July 30, 2013.

• Commence Engineering Modification Design, order electronics - Engineering commenced on June 6, 2013, and electronics were ordered on July 2, 2013, by issuance of Purchase Order (PO) 01560122.

3 Milestone Schedule Status The following ýprovides an update to the milestone schedule to support the OIP. This section provides the activity status of each item, and the expected completion date noting any change.

The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Target Revised Milestone Completion Activity Target Date Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit OIP Feb 2013 Complete Unit refueling outage ( 1 st RFO) start March 2013 Outage Completed Submit 6 Month Updates:

Complete with Update 1 Aug 2013 this submittal Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started to AEP-NRC-2013-72 Page 2 Revised Target Completion Activity Target Milestone Date Status Completion Date Update 4 Feb 2015 Not Started Modifications:

Commence Engineering Modification Commenced Design April 2013 Complete June 6, 2013 P0 issued Order Electronics April 2013 Complete July 2, 2013 Complete Design* December In Progress 2013 Receive electronics December Not Started April 2014 2013 Commence Installation June 2014 Not Started Complete functional test November Not Started 2014 Procedures:

Issue Maintenance Procedures August 2014 Not Started Training:

Implement Training September Not Started 2014 Submit Completion Report February 2015 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation I&M expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the OIP as discussed in the Request for Additional Information (RAI) (Reference 6) and the subsequent RAI response (Reference 7) and the status of each item. Currently there is no Draft Safety Evaluation (SE).

to AEP-NRC-2013-72 Page 3 Overall Integrated Plan Open Item Status RAI-1 a) The specific functional reasons for identification Complete. Response (Ref 6) of the elevation of Level 1. Specify how the submitted July 11, 2013 identified elevation represents the HIGHER of (Reference 7) the two points described in the NEI 12-02 guidance for this level.

b) Provide a clearly labeled sketch depicting the Complete. Sketch attached to elevation view of the proposed typical mounting this enclosure as Figure 1.

arrangement for the portions of instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets).

Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.

c) The OIP refers to drawings 12-3801, Complete. Response OP-12-5136, and DC-06033. Provide these submitted July 11, 2013 drawings and, if they do not provide the (Reference 7) necessary information requested in this RAI, please provide additional drawinqs.

RAI-2 Please provide a clearly labeled sketch or Sketches attached to this (Ref 6) marked-up plant drawing of the plan view of the enclosure as Figure 2 and SFP area, depicting the inside dimensions, the Figure 3 planned locations / placement of the primary and back-up level sensors, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.

RAI-3 a) The design criteria that will be used to estimate CNP plans to provide this (Ref 6) the total loading on the mounting device(s), information in the February including static weight loads and dynamic 2014 update.

loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

to AEP-NRC-2013-72 Page 4 Overall Integrated Plan Open Item Status b) A description of the manner in which the level CNP plans to provide this sensor (and stilling well, if appropriate) will be information in the February attached to the refueling roof and/or other 2014 update.

support structures for each planned point of attachment of the probe assembly. Indicate in a drawing the portions of the level sensor that will serve as points of attachment for mechanical/mounting and electrical connections.

c) A description of the manner by which the CNP plans to provide this mechanical connections will attach the level information in the February instrument to permanent SFP structures so as 2014 update.

to support the level sensor assembly.

i RAI-4 a) A description of the specific method or CNP plans to provide this (Ref 6) combination of methods that will be applied to information in the February demonstrate the reliability of the permanently 2014 update.

installed equipment under Beyond Design Basis (BDB) ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that CNP plans to provide this will be conducted to provide assurance that the information in the February equipment will perform reliably under the worst- 2014 update.

case credible design basis loading at the location where the equipment will be mounted.

Include a discussion of this seismic reliability demonstration as it applies to: 1) the level sensor mounted in the SFP area, and 2) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

c) A description of the specific method or CNP plans to provide this combination of methods that will be used to information in the February confirm the reliability of the permanently 2014 update.

installed equipment such that, following a seismic event, the instrument will maintain its required accuracy.

RAI-5 a) A description of how the two channels of the CNP plans to provide this (Ref 6) proposed level measurement system meet this information in the February requirement so that the potential for a common 2014 update.

cause event to adversely affect both channels is minimized to the extent practicable.

to AEP-NRC-2013-72 Page 5 Overall Integrated Plan Open Item Status b) Further information on how each level CNP plans to provide this measurement system, consisting of level information in the February sensor electronics, cabling, and readout 2014 update.

devices will be designed and installed to address independence through the application and selection of independent power sources, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RAI-6 a) If the level measurement channels are to be CNP plans to provide this (Ref 6) powered through a battery system (either information in the February directly or through an Uninterruptible Power 2014 update.

Supply), provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BDB event for the minimum duration needed, consistent with the plant mitigation strategies for BDB external events (Order EA-12-049).

b) The location where the batteries will be located, CNP plans to provide this indicating the accessibility, and the distance information in the February from the related instrument display. 2014 update.

RAI-7 a) An estimate of the expected instrument CNP plans to provide this (Ref 6) channel accuracy performance (e.g., in percent information in the February of span) under both: 2014 update.

1) normal SFP level conditions (approximately Level 1 or higher), and

2) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

b) A description of the methodology that will be CNP plans to provide this used for determining the maximum allowed information in the February deviation from the instrument channel design 2014 update.

accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

to AEP-NRC-2013-72 Page 6 Overall Integrated Plan Open Item Status RAI-8 a) A description of the capability and provisions CNP plans to provide this (Ref 6) the proposed level sensing equipment will have information in the February to enable periodic testing and calibration, 2014 update.

including how this capability enables the equipment to be tested in-situ.

b) A description how such testing and calibration CNP plans to provide this will enable the conduct of regular channel information in the February checks of each independent channel against 2014 update.

the other, and against any other permanently-installed SFP level instrumentation.

c) A description of the calibration and functional CNP plans to provide this checks that will be performed, the frequency at information in the February which they will be conducted with a discussion 2014 update.

on the measures taken to detect when the instrumentation is operable but degraded, and how these surveillances will be incorporated into the plant surveillance program.

d) A description of the preventative maintenance CNP plans to provide this tasks required to be performed during normal information in the February operation, and the planned maximum 2014 update.

surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

RAI-9 a) The specific location for the primary and Complete. One instrument (Ref 6) backup instrument channel display. channel display is located in the Unit 1 control room; the second channel display is located in the Unit 2 control room. The channels are identical, and both are suitable for a primary or backup function.

b) If the primary or backup display location is Complete. One instrument other than the main control room, then provide channel display is located in justification for prompt accessibility to displays the Unit 1 control room, the including primary and alternate route second channel display is evaluation, habitability at display location(s), located in the Unit 2 control continual resource availability for personnel room, no additional justification responsible to promptly read displays, and is required.

provisions for communications with decision-makers for the various SFP drain-down scenarios and external events.

to AEP-NRC-2013-72 Page 7 Overall Integrated Plan Open Item Status c) The reasons justifying why the locations Complete. Both control rooms selected enable the information from these will be manned during normal, instruments to be considered "promptly event, and post-event accessible" to various drain-down scenarios conditions and will facilitate and external events. display observation during normal operation and during implementation of post-event FLEX strategies.

RAI-10 Please provide the following: A list of the CNP plans to provide this (Ref 6) operating (both normal and abnormal information in the February response) procedures, calibration/test 2014 update.

procedures, maintenance procedures, and inspection procedures that will be developed for use of the spent fuel pool instrumentation in a manner that addresses the Order requirements. Please include a brief description of the specific technical objectives to be achieved within each procedure. If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable components, when needed.

RAI-1 1 a) Further information describing the maintenance CNP plans to provide this (Ref 6) and testing program the licensee will establish information in the February and implement to ensure that regular testing 2014 update.

and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of how the guidance in CNP plans to provide this NEI 12-02, Section 4.3, regarding information in the February compensatory actions for one or both non- 2014 update.

functioning channels will be addressed.

c) A description of what compensatory actions are CNP plans to provide this planned in the event that one of the instrument information in the February channels cannot be restored to functional 2014 update.

status within 90 days.

to AEP-NRC-2013-72 Page 8 Draft Safety Evaluation Open Item Status None 7 Potential Draft Safety Evaluation Impacts CNP has not yet received a Draft Safety Evaluation; therefore, no potential impacts can be determined.

8 References The following references support the updates to the OIP described in this attachment.

1. I&M's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051)," dated February 27, 2013 (AEP-NRC-2013-14).

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

3. Sargent & Lundy Project No. 12105-405 Notes of Meeting, "Spent Fuel Pool Level Conceptual Design Kick-off - June 6, 2013."

4. I&M Purchase Order (PO) 01560122 issued July 2, 2013 to Mohr Test and Measurement LLC.

5. I&M EC-52892 "Conceptual Design - Spent Fuel Pool Level for NRC Order EA-12-051".

6. Letter from Thomas J. Wengert, NRC, to Lawrence J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Request for Additional Information on the Overall Integrated Plan in Response to Order EA-12-051 Concerning Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0761 and MF0762)," dated June 19, 2013 (ADAMS Accession No. ML13164A381).

7. Donald C. Cook Nuclear Plant Units 1 and 2 Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", dated July 11, 2013 (AEP-NRC-2013-57).

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