AEP-NRC-2014-66, Third Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Third Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML14241A235
Person / Time
Site:	Cook
Issue date:	08/27/2014
From:	Gebbie J Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2014-66, EA-12-049
Download: ML14241A235 (12)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant POMER One Cook Place Bridgman, MI 49106 Aunit of American Electric Power India naMichiga nPower.com August 27, 2014 AEP-NRC-2014-66 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 Third Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, Agencywide Documents Access Management System (ADAMS) Accession No. ML12054A736.

2. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to NRC, "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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

AEP-NRC-2013-13, dated February 27, 2013, ADAMS Accession No. ML13101A381.

3. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, First Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," AEP-NRC-2013-71, dated August 26, 2013, ADAMS Accession No. ML13240A308.

4. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, Second Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events (Order Number EA-12-049)," AEP-NRC-2014-17, dated February 27, 2014, ADAMS Accession No. ML14063A042.

4/5/4

U. S. Nuclear Regulatory Commission AEP-NRC-2014-66 Page 2

5. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0766 AND MF0767)," dated January 24, 2014, ADAMS Accession No. ML13337A325.

On March 12, 2012, the U. S. Nuclear Regulatory Commission issued Order EA-12-049 (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 develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements were outlined in Attachment 2 of the enclosure of Reference 1.

Reference 1 required submission of an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 provided the CNP OIP. Reference 1 also requires submission of a status report at six-month intervals following submittal of the OIP. References 3 and 4 provided the first and second six-month status reports respectively. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition C.2, of Reference 1, delineating progress made in implementing the requirements of Reference 1. Enclosure 1 to this letter provides an affirmation. Enclosure 2 to this letter provides the third six-month update for the implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation of Strategies for Beyond-Design-Basis External Events," including an update of milestone accomplishments since the initial status report.

There have been no changes to the compliance method as documented in the Interim Staff Evaluation (Reference 5); however, some specific methods of implementation have changed.

These changes have resulted in changes to the OIP Open Item list (Enclosure 2). Updated general descriptions of the coping strategies, including station modifications, are posted on the e-portal.

Note: There is no change to the final implementation schedule, or need for relief at this time.

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 JRW/kmh

U. S. Nuclear Regulatory Commission AEP-NRC-2014-66 Page 3

Enclosures:

1. Affirmation

2. Indiana Michigan Power Company's Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events c: M. L. Chawla, NRC Washington, DC J. T. King, MPSC J. A. Kratchman, NRR/JLD/PMB, NRC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III A. J. Williamson, AEP Ft. Wayne, w/o enclosure

Enclosure 1 to AEP-NRC-2014-66 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 U. S. 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 My Commission Expires ) ( -- -I (-

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Enclosure 2 to AEP-NRC-2014-66 Indiana Michigan Power Company's Third Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events References for this enclosure are identified in Section 8.

1. Introduction Indiana Michigan Power Company (I&M), the licensee for Donald C, Cook Nuclear Plant Units 1 and 2, developed an Overall Integrated Plan (OIP) (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the OIP. Although there have been no changes to the compliance method as documented in the Interim Staff Evaluation (ISE)

(Reference 3), some specific methods of implementation have changed. Updated general descriptions of the coping strategies, including station modifications, are posted on the e-portal.

These changes have resulted in changes to "Table 2 - OIP Open Items" below. Changes to OIP Open Items and Statuses identified in the previous OIP update are annotated with "strikeout."

There is no change to the final implementation schedule, or need for relief/relaxation at this time.

2. Milestone Accomplishments Table 1 - Milestone Schedule contains the milestone(s) completed since the development of the OIP (Reference 1), and is current as of July 31, 2014.

3. Milestone Schedule Status The following table provides an update to Attachment 2 of the OIP. The table provides the activity status of each item, and whether the expected completion date has changed. These dates are planning dates subject to change as design and implementation details are developed.

Table 1 - Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60-Day Status Report October 2012 Complete Submit OIP February 2013 Complete Submit Six-Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Complete with this Update 3 August 2014 submittal to AEP-NRC-2014-66 Page 2 Table I - Milestone Schedule Revised Target Completion Activity Status Target Milestone Completion Date Date Update 4 February 2015 Not Started Walk-throughs or Demonstrations June 2015 In Progress Perform Staffing Analysis June 2014 Complete Modifications:

Modifications Evaluation December 2013 Complete Unit 1 Design Engineering June 2014 In Progress September 2014 Unit 1 Implementation Outage November 2014 Not Started October 2014 Unit 2 Design Engineering December 2014 In Progress Unit 2 Implementation Outage April 2015 Not Started Storage:

Storage Design Engineering March 2014 Complete Storage Implementation November 2014 Complete FLEX Equipment:

Procure On-Site Equipment July 2014 In Progress October 2014 Develop Strategies with Regional April 2014 In Progress September Response Center 2014 Install Off-Site Delivery Station q4 NeGessarY4 (No installation NA NA necessary)

Procedures:

Pressurized Water Reactor Owners Group (PRWOG) issues November 2014 Complete nuclear steam system supply-specific guidelines. (Modes 1-4) to AEP-NRC-2014-66 Page 3 Table 1 - Milestone Schedule Target Revised Milestone Completion Activity Status Target Date Completion Date Pressurized Water Reactor Owners Group issues nuclear steam system supply-specific guidelines. (Modes 5 & 6)

Note: Site specific FLEX Support December 2014 In Progress Guidelines will be credited for CNP Unit 1 compliance with EA-12-049, and will be modified as needed following issuance of PWROG guidelines for Mode 5 &6.

Create Site-Specific FLEX Support September In Progress Guidelines (FSGs) - Unit 1 2014 Create Site-Specific FSGs - Unit 2 February 2015 In Progress Create Maintenance Procedures August 2014 In Progress October 2014 Training:

Develop Training Plan March 2014 Complete Training Complete September 2014 In Progress Unit 1 FLEX Implementation November 2014 In Progress October 2014 Unit 2 FLEX Implementation April 2015 In Progress Full Site FLEX Implementation April 2015 In Progress Submit Completion Report August 2015 Not Started

4. Changes to Compliance Method Although there have been no changes to the compliance method as documented in the ISE (Reference 3), some specific methods of implementation have changed. Updated general descriptions of the coping strategies, including station modifications, are posted on the e-portal.

The most recently posted coping strategy description includes the following implementation method changes.

Crediting condensate storage tank level up to 16 feet 7 inches based on tornado missile evaluations.

Crediting Westinghouse SHIELD low leakage reactor coolant pump seals.

to AEP-NRC-2014-66 Page 4 Providing temporary power to containment temperature recorders via a jumper from the Critical Control Room Power inverter.

Manual operation of Steam Generator (SG) Power Operated Relief Valves (PORVs) locally with hand wheels rather than pneumatically.

Removal of the West Essential Service Water (ESW) pump discharge strainer lid and replacement with a temporary lid equipped with a hose connection to accept discharge of the Regional Response Center raw water pump, rather than removal of a spool piece on the west ESW supply header and installation of a flange with hose connections on the downstream side.

Additionally, two rather than three, 250 kW diesel generators (DG) will be available to power the three planned FLEX Boric Acid (BA) Pumps, because one 250 kW DG is capable of powering two FLEX BA Pumps. Therefore, two FLEX BA Pumps and one 250 kW DG will provide N capability for the site, and one additional FLEX BA Pump and one additional 250 kW DG will provide N+1 capability for the site.

Also, one 480 Vac, 350 kW, three-phase DG will provide the N+1 FLEX electrical capability. The 350 kW FLEX generator will supply N+1 600 Vac loads through a 480/600 Vac step up transformer. The 350 kW DG will also provide 120 Vac to the output of each of the four Control Room Instrument Distribution (CRID) Isolimiter Transformers as an alternate means of providing 120 Vac CRID instrument power. The small 6 kW, 120 Vac portable DGs previously credited for providing the N+1 capability will now provide defense in depth.

Some of these changes have resulted in changes to "Table 2 - OIP Open Items" below.

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 OIP and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the Draft Safety Evaluation and the status of each item.

Table 2 - OIP Open Items Pending OIP Open Item Status Action 1 Completion of FLEX equipment storage facilities. inProgress Complete Perform final validation of timing requirement to 2 route alternate suction source to Turbine Driven In Progress Auxiliary Feed Water (TDAFW) pump.

to AEP-NRC-2014-66 Page 5 Table 2 - 0IP Open Items Pending OIP Open Item Status Action 3 Implement administrative controls program for Net Stated FLEX related equipment. In Progress A systematic approach to training will be used to evaluate training requirements for station 4 personnel based upon changes to plant 'R PFegFess equipment, implementation of FLEX portable Complete equipment, and new or revised procedures that result from implementation of the FLEX strategies.

Complete detailed load shedding and battery duration analysis of Train A and Train B 250 Volt 5 (V)'direct current batteries to validate final FLEX Complete implementation strategy, including required procedure changes.

Modification to TDAFW pump suction piping from 6 Essential Service Water (ESW) system to provide In Progress connection point from the discharge of the fire water-pumps alternate sources.

Complete detailed load shedding and battery duration analysis of N-Train battery to validate final Not-Started FLEX implementation strategy, including required Complete procedure changes.

8 Develop FSGs and associated procedure revisions In Progress to implement FLEX mitigation strategies.

Modify the fire protection header inSide the Turbine Building to provide an adequately sized connection to enable transfer of water to Auxiliary Feedwater (ArW) PUMP Su.ctioR.

9 NA Modification of fire protection not required.

Condensate Storage Tanks are the credited Auxiliary Feedwater water supply until the infinite source (Lake Michigan) is made available.

Permanent nitrogen bottle racks will be installed ne-ar e.ach steam generater power operated relief 10 valve operating station with hose and regulators to in-regress align for local manual control. Complete Proceduralize handwheel operation of SG PORV.

11 Modification to connect portable diesel generator In Progress (DG) to 600 Vac bus 11D and 21D.

to AEP-NRC-2014-66 Page 6 Table 2 - 0IP Open Items Pending OIP Open Item Action Status Moed-ific-ation to connect one 6 kWV portable DG to each cAontrol room nruentation distribution 120 V Instrument Distribution Panel.

12 In Progress Fabricate cable to connect one 6 kW portable DG to each control room instrumentation 120 V isolimiter transformer.

Modification to connect portable DG to motor 13 control center (MCC) ABD-B to provide alternate In Progress power supply to N-Train battery charger.

Modification to place a new hose connection in the 14 motor driven AFW discharge line in the east main In Progress steam stop enclosure.

4160 V alternating current (AC) bus !A (2A) will be modified to allow connection of external 4160 VAC three phase portable DG.

15 Modification not needed. 4kV leads will be In Progress fabricated and stored to allow connection of an external 4160 Vac three-phase portable DG to the load side of the breaker.

Replace Reactor Coolant Pump (RCP) seals with 16 Westinghouse SHIELD low leakage seals. On OR Held 16,Hold pending reevaluation of Generation 3 In Progress SHtE=71 D d 17 Modification adding a portable boron addition In Progress pump powered by a dedicated portable DG.

18 Monitor tanks modification and associated strategy N/A not required.

19 Modification to provide power to middle boric acid In Progress evaporator feed pump.

Perform containment analysis to validate that containment integrity can be maintained until hR Peg~ess 20 containment cooling can be restored during Phase Complete 3.

to AEP-NRC-2014-66 Page 7 Table 2 - QIP Open Items Pending OIP Open Item Status Action Modify Chemnic-aland- Volu11me ControlSystem reciprocating positive displacement pump diGcharge flange connection to -AlloW. connection o0 21 portable boron addition pump. In Progress Modify Chemical and Volume Control System charging header to allow connection of portable pump for boron addition and RCS makeup.

Strategy changed to use existing hose connections 22 on fire test header at the Fire Pump House. NA Modification of fire test header not needed.

Modify boric acid transfer pump (BATP) suction In-Progress 23 header to add connection points. Complete 24 Modify BATP discharge header to add connection In-Pregress points. Complete 25 Modification Strategy revisedto install to usestandpipe not required. N/A hose connections.

26 Fuel consumption will be finalized when equipment tR-Preegess has been procured and tested. Complete Perform calculation to verify time required to 27 establish flow to the Reactor Coolant System In Progress (RCS) in MODE 6 with the Reactor Cavity filled.

Modification of boron injection tank downstream 28 vent not required. Strategy changed to use N/A existing Safety Injection Pumps discharge header vents and drains.

Fabricate a tool to provide large volume Phase 3 raw water tie-in to ESW supporting component cooling water cooling for Residual Heat Removal 29 (RHR). In Progress Note: New scope to address Phase 3 reestoration of RHR.

Modify 600 Vac MCC circuit breakers to provide Phase 2 electrical power connections to close safety injection (SI) accumulator discharge valves.

30 In Progress NoQ-te:, NeP-W scope addresses Phas1e 2 need to close SI accumulator discharge valves to prevent nitrogen injection fromn the SI accumulators to AEP-NRC-2014-66 Page 8 Note: The previous Six Month Status Report included Table 3, "ISE Open Items." That table has not been included in this Six Month Status Report because ISE Open Item and Confirmatory Item responses will be provided in separate correspondence if required.

7. Potential Draft Safety Evaluation Impacts I&M has not yet received a draft SE; therefore no potential impacts can be determined. The changes identified in Section 4 above occurred subsequent to issuance of the Reference 3 ISE.

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

1. Letter from J. P. Gebbie, I&M, to NRC, "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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," AEP-NRC-2013-13, dated February 27, 2013, ADAMS Accession No. ML13101A381.

2. Letter from E. J. Leeds and M. R. Johnson, 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 Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, ADAMS Accession No. ML12054A736.

3. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M,

Subject:

"Donald C. Cook Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0766 and MF0767)," dated January 24, 2014.