ML18263A154

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NRR E-mail Capture - D.C. Cook Unit No. 1 - RAI for Leak-Before-Break LAR
ML18263A154
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 09/14/2018
From: Dietrich A
Plant Licensing Branch III
To: Levendosky H
Indiana Michigan Power Co
References
L-2018-LLA-0054
Download: ML18263A154 (3)


Text

NRR-DMPSPEm Resource From: Dietrich, Allison Sent: Friday, September 14, 2018 2:43 PM To: Helen L Levendosky Cc: Joe Tanko (jmtanko@aep.com)

Subject:

D.C. Cook Unit No. 1 - RAI for Leak-Before-Break LAR (EPID L-2018-LLA-0054)

Attachments: DC Cook Unit 1 RAI for LBB LAR.pdf By letter dated March 7, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18072A012), Indiana Michigan Power Company (I&M) submitted a license amendment request (LAR) for the Donald C. Cook Nuclear Plant (CNP), Unit No. 1. The proposed amendment would allow for the application of leak-before-break methodology to piping for the accumulator, residual heat removal, and safety injection systems at CNP, Unit No. 1.

The U.S. Nuclear Regulatory Commission staff has reviewed your submittal. The staff has determined that additional information is needed in order to complete the review, as described in the attached request for additional information (RAI). The draft RAI was sent to I&M via electronic mail on August 29, 2018. A clarification telephone conference was held on September 11, 2018. Please respond to this RAI by October 15, 2018.

Please feel free to contact me if you have any questions or concerns.

Sincerely, Allison W. Dietrich, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-2846 1

Hearing Identifier: NRR_DMPS Email Number: 570 Mail Envelope Properties (Allison.Dietrich@nrc.gov20180914144300)

Subject:

D.C. Cook Unit No. 1 - RAI for Leak-Before-Break LAR (EPID L-2018-LLA-0054)

Sent Date: 9/14/2018 2:43:20 PM Received Date: 9/14/2018 2:43:00 PM From: Dietrich, Allison Created By: Allison.Dietrich@nrc.gov Recipients:

"Joe Tanko (jmtanko@aep.com)" <jmtanko@aep.com>

Tracking Status: None "Helen L Levendosky" <hllevendosky@aep.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1135 9/14/2018 2:43:00 PM DC Cook Unit 1 RAI for LBB LAR.pdf 56015 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR APPLICATION OF LEAK-BEFORE-BREAK EVALUATIONS FOR ACCUMULATOR, SAFETY INJECTION, AND RESIDUAL HEAT REMOVAL PIPING DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 DOCKET NO. 50-315 By letter dated March 7, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18072A012), Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) that would allow for the application of leak-before-break (LBB) evaluations for accumulator piping, safety injection (SI) piping, and residual heat removal (RHR) piping at the Donald C. Cook Nuclear Plant (CNP), Unit No. 1. The NRC staff has determined that additional information is necessary in order to complete its review.

Requests for Additional Information (RAIs) 1 through 6 were sent to the licensee on July 19, 2018 (ADAMS Accession No. ML18204A372). RAI 7 is provided below.

RAI 7

The regulatory guidelines in Regulatory Guide 1.45, Guidance on Monitoring and Responding to Reactor Coolant System Leakage (ADAMS Accession No. ML073200271) state that all monitoring systems referenced in the technical specifications should respond to a leakage increase of 1 [gallon per minute (gpm)] (3.8 [liters per minute]) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less.

In its application, the licensee stated, A CNP leakage detection capability calculation demonstrates the 0.8 gpm leak detection capability is valid for leaks in the Accumulator, RHR, and SI piping. As such, the 0.8 gpm leak detection capability is the basis for LBB evaluation of the Accumulator, RHR, and SI lines with no response time assumed.

The NRC staff considers response time to include both transport response time and detector response time. The application is not clear what is meant by no response time assumed.

Clarify the assumption of no response time assumed in the calculation described above, and its effect on the calculation results and acceptability.