ML20349A015

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Summary of November 30, 2020, Teleconference with Indiana Michigan Power Company Regarding a Planned License Amendment Request to Extend the Containment Integrated Leak Rate Testing Interval for Donald C. Cook Nuclear Plant, Unit No. 2
ML20349A015
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 12/17/2020
From: Blake Purnell
Plant Licensing Branch III
To:
Indiana Michigan Power Co
Blake P
References
EPID L-2020-LRM-0108
Download: ML20349A015 (4)


Text

December 17, 2020 LICENSEE: Indiana Michigan Power Company, LLC FACILITY: Donald C. Cook Nuclear Plant, Unit No. 2

SUBJECT:

SUMMARY

OF NOVEMBER 30, 2020, TELECONFERENCE WITH INDIANA MICHIGAN POWER COMPANY REGARDING A PLANNED LICENSE AMENDMENT REQUEST TO EXTEND THE CONTAINMENT INTEGRATED LEAK RATE TESTING INTERVAL FOR DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 (EPID L-2020-LRM-0108)

On November 30, 2020, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Indiana Michigan Power Company (I&M or the licensee) via teleconference. The purpose of the meeting was for I&M to provide information on a planned license amendment request (LAR) to extend the interval for performing the containment integrated leak rate test (ILRT) at the Donald C. Cook Nuclear Plant (CNP),

Unit No. 2 (CNP-2), by approximately 15 months. The meeting notice dated November 17, 2020, and agenda are available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML20322A400. The licensees presentation is available under ADAMS Accession No. ML20329A343. A list of attendees is provided as Enclosure 1.

The licensee stated that approximately 50 additional contractors would need to be onsite in close proximity to perform the ILRT. Currently, the ILRT for CNP-2 is scheduled to occur during the Spring 2021 refueling outage. Due to a surge in Coronavirus Disease 2019 (COVID-19) cases, the licensee proposes to extend the ILRT interval to keep onsite staff safe.

On September 3, 2020 (ADAMS Accession No. ML20213C704), the NRC staff issued an amendment for CNP, Unit No. 1 (CNP-1), that allowed the licensee to extend the ILRT for CNP-1 by approximately 5 months. During the meeting, the licensee stated that the planned LAR for CNP-2 would provide the same level of content and detail as the previous LAR for CNP-1. The licensees presentation focused on the differences between the risk information provided for CNP-1 and the planned LAR for CNP-2.

The licensee provided a comparison of the probabilistic risk assessment (PRA) results for CNP-1 and CNP-2. For this assessment, the licensee assumed a 6-month ILRT extension for CNP-1 and an 18-month ILRT extension for CNP-2. The total change in the calculated large early release frequency (LERF) is 3.88 x 10-8 per year for CNP-1 and 1.25 x 10-7 per year for CNP-2. The difference in these values is primarily a result of the different duration of the extension.

The licensee compared the PRA results to the acceptance guidelines in NRC Regulatory Guide (RG) 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, Revision 3, dated January 2018 (ADAMS Accession No. ML17317A256). RG 1.174 states that when the calculated increase in LERF is in the range of 10-7 to 10-6 per year, applications are considered only if it can only be reasonable shown that the total LERF is less that 10-5 per year. The licensee stated that the LAR for CNP-2

will include information regarding the total LERF because the change in total LERF is within this range.

However, the licensee noted that a simple sum of the three PRA models for CNP-2 results in a total LERF slightly higher than 10-5 per year. However, the licensee stated that there are sufficient conservatisms in these models to conclude that a realistic estimate of the total LERF would remain below 10-5 per year. The licensee stated that the LAR for CNP-2 will include information to justify this statement.

During the meeting, the NRC staff referred to Electric Power Research Institute (EPRI) Report No. 1009325, Revision 2, Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals, dated August 2007 (ADAMS Accession No. ML072970208). This EPRI report provides a generic assessment of the risks associated with permanently extending the ILRT interval to 15 years, and it provides a risk-informed methodology to be used to confirm the risk impact of the ILRT extension on a plant-specific basis. The NRC staffs review of this EPRI report is described in an NRC safety evaluation dated June 25, 2008 (ADAMS Accession No. ML081140105). During the meeting, the NRC staff noted that Section 3.2.4.1 of this safety evaluation states that capability category I of the American Society for Mechanical Engineers PRA standard shall be applied as the standard for assessing the PRA quality for ILRT extension applications.

The licensee stated that it plans to submit the LAR on December 17, 2020, and request approval by mid-February 2021.

Please direct any inquiries to Scott Wall, the NRC project manager for CNP, at 301-415-2855, or Scott.Wall@nrc.gov.

Sincerely,

/RA/

Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-316

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES NOVEMBER 30, 2020, PUBLIC MEETING WITH INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 Name Organization Blake Purnell U. S. Nuclear Regulatory Commission (NRC)

Ahsan Sallman NRC Steve Smith NRC Jerry Dozier NRC John Ma NRC Brian Lee NRC Odunayo Ayegbusy NRC Robert Pettis NRC Clinton Ashley NRC Bryce Lehman NRC Michael K Scarpello Indiana Michigan Power Company (I&M)

Helen Levendosky I&M Brad Culwell I&M David Aubrey I&M Amanda Salliotte I&M Gary Sanders I&M Greg Hill I&M Chris Peckat I&M Eric Thornsbury Jensen Hughes James Heyeck Jensen Hughes Enclosure

ML20349A015 *via e-mail OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA* NRR/DORL/LPL3/BC* NRR/DORL/LPL3/PM NAME BPurnell SRohrer NSalgado BPurnell DATE 12/14/20 12/14/20 12/17/20 12/17/20