ML19011A351

NRR E-mail Capture - Request for Additional Information DC Cook Unit 1 Leak Before Break Amendment

ML19011A351
Person / Time
Site:	Cook
Issue date:	01/11/2019
From:	Haskell R Plant Licensing Branch III
To:	Levendosky H Indiana Michigan Power Co
References
L-2018-LLA-0054
Download: ML19011A351 (3)

Text

NRR-DMPSPEm Resource From: Haskell, Russell Sent: Friday, January 11, 2019 1:33 PM To: Helen L Levendosky; Joe Tanko

Subject:

Request for Additional Information DC Cook Unit 1 Leak Before Break amendment (EPID L-2018-LLA-0054)

Helen, Joe, By letter dated March 7, 2018, as supplemented by letters dated September 27, 2018 and November 27, 2018, Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request to adopt the leak before break (LBB) methodology at Donald C. Cook Nuclear Plant, Unit No. 1 (CNP). During the staffs ongoing review of the application, as supplemented, it was determined that additional information is required for the NRC to complete the review. By email dated December 17, 2018, two (2) draft RAIs were transmitted to you. At your request, a clarification call was held on January 9, 2019, with the NRC staff. Following the discussion it was agreed that no changes to the draft RAIs were necessary and as included below are considered to be final. Due to previously docketed responses by the licensee for this licensing activity, the 2 RAIs are numbered as RAI-8 & RAI-9 (vs. RAI-1 and RAI-2, respectively).

During the call, your staff indicated these RAIs could be responded to fairly promptly, not to exceed 30 days from the date of this email when these responses are due to the NRC staff.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1129.

Thank you.

Russell S. Haskell II United States Nuclear Regulatory Commission (NRC)

Licensing Project Manager - NRR/DORL/LPL 3 Dresden Nuclear Power Station, Units 2 and 3 Russell.Haskell@NRC.Gov; (301) 415-1129; Office: O-8C01; Mail-Stop O-8B1A REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST FOR APPROVAL OF APPLICATION OF LEAK-BEFORE-BREAK METHODOLOGY FOR REACTOR COOLANT SYSTEM SMALL DIAMETER PIPING INDIANA MICHIGAN POWER - DONALD C. COOK NUCLEAR PLANT, UNIT 1 DOCKET NOS. 50-315 EPID NO. L-2018-LLA-0054 1

RAI-8 (formally draft RAI-1)

The licensee provided Supplement to Response to Request for Additional Information (RAI) Regarding License Amendment Request for the LBB for Approval of Application of Proprietary Leak-Before-Break Methodology for Reactor Coolant Small Diameter Piping (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18333A032) dated November 27, 2018.

In the supplement to the RAI response, the licensee stated, the capability to detect a 0.8 gpm RCS leak within one hour is the basis for LBB evaluation. The technical evaluations of LBB for the Accumulator, RHR, and

[safety injection] SI lines are not dependent on the specific response times of the credited leak detection systems. The NRC staff is not sure what the licensee means in stating the technical evaluations are not dependent on response time.

Regulatory Guide 1.45 states if LBB analysis is approved, the overall response time of the leakage monitoring system should be sufficient to support the LBB analysis procedures. Overall response time includes transport delay time and instrument response time.

Request: Verify that the overall response time was considered when confirming that the leak detection is capable of detecting a 0.8 gpm leak within one hour.

RAI-9 (formally draft RAI-2)

In the supplement to the RAI response, the licensee referenced the leak detection capability calculation for the LBB analysis for the pressurizer surge line. The calculation accounted for reactor coolant radioactivity input, sensor location and piping insulation as stated in Indiana Michigan Power letter dated October 26, 2000 (ADAMS ML003764628). The NRC staff found the calculation satisfactory as stated in NRC Letter dated November 8, 2000 (ADAMS ML003767675).

Request: As with the case for the pressurizer surge line, does the CNP leakage detection calculation which demonstrates the capability to detect a 0.8 gpm leak within one hour throughout the operating cycle for leaks in the Accumulator, RHR, and SI piping satisfactorily address uncertainties of the leakage detection capability introduced by factors such as variation of fluid system radioactivity, proximity of the particulate radiation leak sensor to the Accumulator, RHR and SI piping, and the effects of piping insulation?

2

Hearing Identifier: NRR_DMPS Email Number: 756 Mail Envelope Properties (BN6PR09MB13486A0BC3ED6A4A84232F21ED850)

Subject:

Request for Additional Information DC Cook Unit 1 Leak Before Break amendment (EPID L-2018-LLA-0054)

Sent Date: 1/11/2019 1:32:36 PM Received Date: 1/11/2019 1:32:40 PM From: Haskell, Russell Created By: Russell.Haskell@nrc.gov Recipients:

"Helen L Levendosky" <hllevendosky@aep.com>

Tracking Status: None "Joe Tanko" <jmtanko@aep.com>

Tracking Status: None Post Office: BN6PR09MB1348.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4362 1/11/2019 1:32:40 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: