AEP-NRC-2021-16, Unit 2 - Response to Request for Additional Information Regarding CFR 50.55a Request Associated with the Fifth Ten-Year Inservice Testing Interval
| ML21063A251 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/25/2021 |
| From: | Lies Q American Electric Power, Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2021-16 | |
| Download: ML21063A251 (9) | |
Text
A unit of American Electnc Power February 25, 2021 Docket No.:
50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Donald C. Cook Nuclear Plant Unit 1 and Unit 2 Indiana Michigan Power Cook Nuclear Plant One Cook Place Bndgman, Ml 49100 lnd1anaM1ch1ganPower com AEP-NRC-2021-16 10 CFR 50.55a Response to Request for Additional Information Regarding CFR 50.55a Request Associated with the Fifth Ten-Year lnservice Testing Interval
References:
- 1. Letter from Q. S. Lies, Indiana Michigan Power Company (l&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant, Units 1 and 2, 1 O CFR 50.55a Request Associated with the Fifth Ten-Year lnservice Testing Interval," dated October 5, 2020, Agencywide Documents Access and Management System Accession (ADAMS)
No. ML20290A500.
- 2. E-mail from S. P. Wall, NRC, to M. K Scarpello, l&M, "Final RAI - D.C. Cook 1 & 2 - Relief Request REL-PP2 for Pump and Valve 1ST Fifth 10-year interval (EPID No. L-2020-LLR-0138),"
dated January 26, 2021. ADAMS No. ML21026A347.
This letter provides Indiana Michigan Power Company's (l&M), licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, response to the Request for Additional Information (RAI) by the U. S.
Nuclear Regulatory Commission (NRC) regarding a request that, pursuant to Section 50.55a(z)(1) of Title 10 of the Code of Federal Regulations, the NRC authorize relief request REL-PP2 for CNP Unit 1 and Unit 2.
Specifically, l&M requested authorization of a proposed alternative to certain requirements in the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), associated with the vibration acceptance criteria for smooth running pumps at CNP.
By Reference 1, l&M submitted a request for authorization of relief request REL,-PP2 for CNP Unit 1 and Unit 2. By Reference 2, the NRC submitted an RAI concerning the request submitted by l&M as Reference 1. to this letter provides l&M's response to the NRC's RAI from Reference 2.
U.S. Nuclear Regulatory Commission Page 2 AEP-NRC-2021-16 There are no new regulatory commibnents made in this letter. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Director, at (269) 466-2649.
SinceZ~t Q. Ca~ Lies Site Vice President JMT/mll
Enclosures:
- 1. Response to Request for Additional Information Regarding* Unit 1 and Unit 2 10 CFR 50.55a Request Associated with the Fifth Ten-Year lnservice Testing Interval c:
R. J. Ancona - MPSC EGLE - RMD/RPS J. B. Giessner - NRC Region Ill D. L. Hille - AEP Ft. Wayne, w/o enclosures NRC Resident Inspector R. M. Sistevaris - AEP Ft. Wayne, w/o enclosures S. P. Wall - NRC Washington, D.C.
A. J. Williamson -AEP Ft. Wayne, w/o enclosures J
to AEP-NRC-2021-16 Response to Request for Additional Information Regarding Unit 1 and Unit 2 10 CFR 50.55a Request Associated with the Fifth Ten-Year lnservice Testing Interval By letter dated October 5, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20290A500), Indiana Michigan Power Company (l&M), the licensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, requested that, pursuant to Section 50.55a(z)( 1) of Title 10 of the Code of Federal Regulations ( 10 CFR), the Nuclear Regulatory Commission (NRC) authorize relief request REL-PP2 for CNP Unit 1 and Unit 2. Specifically, l&M requested authorization of a proposed alternative to certain requirements in the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code), associated with the vibration acceptance criteria for smooth running pumps at CNP.
The NRC staff is currently reviewing the submittal and has determined that additional information is needed in order to complete the review. The request for additional information (RAI) and l&M's response are provided below.
RAI-EMIB (REL-PP2)
APPLICABLE REGULATION AND GUIDANCE The NRG regulations in 10 CFR 50.55a(z)(1) require that a licensee must demonstrate that its proposed alternative would provide an acceptable level of quality and safety.
The NRG regulations in 10 CFR 50.55a(f)(4), "lnservice testing standards requirement for operating plants," states, in part, that valves that are within the scope of the ASME OM Code must meet the inservice testing (/ST) requirements set forth in the ASME OM Code; and that valves that are within the scope of the ASME OM Code, but are not classified as ASME BPV Code Class 1, 2, or 3, may be satisfied as part of an augmented /ST program.
RAI-EM/8-01 The NRG staff compared the October 5, 2020, submittal to the version of the CNP /ST Program Plan outlined in letter dated June 30, 2016 (ADAMS Accession No. ML16197A057) and noted apparent differences. Please confirm the information for the components within scope of the /ST Program with respect to the differences noted in the table on the next page.
of AEP-NRC-2021-16 Page2 Pump Submittal Information
/ST Plan Information 1-PP-3E Code Class 2 Code Class 3.
1-PP-3W 1-PP-7E Centrifugal Vertical Una Shaft (VLS) 1-PP-7W 1-PP-9E Code Class 3, OM Group A Code Class 2, OM Group B 1-PP-9W 1-QT-106-AB1 Non Class, OM Group B, Not in /ST Plan Table 1-QT-106-AB2 Positive Displacement Pump 1-QT-106-CD1 1-QT-106-CD2 1-QT-130-AB1 Non Class, OM Group A, Augmented Group B 1-QT-130-AB2 Centrifugal 1-QT-130-CD1 1-QT-130-CD2 2-PP-3E Code Class 2 Code Class 3 2-PP-3W 2-PP-7E Centrifugal VLS 2-PP-7W 2-PP-9E Code Class 3, OM Group A Code Class 2, OM Group B 2-PP-9W 2-QT-106-AB1 Non Class, OM Group B, Not in /ST Plan Table 2-QT-106-AB2 Positive Displacement Pump 2-QT-106-CD1 2-QT-106-CD2 2-QT-130-AB1 Non Class, OM Group A, Not in /ST Plan Table 2-QT-130-AB2 Centrifugal 2-QT-130-CD1 2-QT-130-CD2 l&M Response to RAI-EMIB-01 An incorrect 1ST Pump Table was provided in the request dated October 5, 2020. The Pump Table has been corrected and is included below. This 1ST Pump Table replaces the previously submitted 1ST Pump Table in its entirety. Please note that the pump tables in the 1ST Program have been updated since the 2016 1ST Program Plan, Rev 0, was issued. The 1ST Program infonnation is contained in a database program and the 1ST Program Plan is a direct report from this database. As part of the 5th Interval Update, that was submitted to the NRC on June 30, 2016, Cook migrated the 1ST data to a new software program. Issues with the migration resulted in some of the pumps not being included in the report for the 1ST Program Plan.
The Table below reflects the correct, current, CNP 1ST Program Plan-5th Interval, Revision 3.
of AEP-NRC-2021-16 Page 3 ISTP ump T bl a e Component System Code OM Description Pump Type Class Group Component Group: AFW-1 1-PP-3E Auxiliary Feedwater 3
A EAST MOTOR DRIVEN AUXILIARY Centrifugal FEEDWATER PUMP l-PP-3W Auxiliary Feedwater 3
A WEST MOTOR DRIVEN AUXILIARY Centrifugal FEEDWATER PUMP 2-PP-3E Auxiliary Feedwater 3
A EAST MOTOR DRIVEN AUXILIARY Centrifugal FEEDWATER PUMP 2-PP-3W Auxiliary Feedwater 3
A WEST MOTOR DRIVEN AUXILIARY Centrifugal FEEDW ATER PUMP Component Group: AFW-2 1-PP-4 Auxiliary Feedwater 3
B TURBINE DRIVEN AUXILIARY FEED PUMP Centrifugal 2-PP-4 Auxiliary Feedwater 3
B TURBINE DRIVEN AUXILIARY FEED PUMP Centrifugal Component Group: BAT-1 1-PP-46-1 Chemical and Volume Control 3
A BORIC ACID STORAGE TANKS TRANSFER Centrifugal PUMP #1 1-PP-46-2 Chemical and Volume Control 3
A BORIC ACID STORAGE TANKS TRANSFER Centrifugal PUMP#2 2-PP-46-3 Chemical and Volume Control 3
A BORIC ACID STORAGE TANKS TRANSFER Centrifugal PUMP#3 2-PP-46-4 Chemical and Volume Control 3
A BORIC ACID STORAGE TANKS TRANSFER Centrifugal PUMP#4 Component Group: CCP-1 1-PP-50E Chemical and Volume Control 2
A EAST CENTRIFUGAL CHARGING PUMP Centrifugal 1-PP-50W Chemical and Volume Control 2
A WEST CENTRIFUGAL CHARGING PUMP Centrifugal 2-PP-50E Chemical and Volume Control 2
A EAST CENTRIFUGAL CHARGING PUMP Centrifugal 2-PP-50W Chemical and Volume Control 2
A WEST CENTRIFUGAL CHARGING PUMP Centrifugal of AEP-NRC-2021-16 Page 4 Component System Code OM Description Pump Type Class Group Component Group: CCW-1 1-PP-l0E Component Cooling Water 3
A EAST COMPONENT COOLING WATER PUMP Centrifugal 1-PP-l0W Component Cooling Water 3
A WEST COMPONENT COOLING WATER PUMP Centrifugal 2-PP-l0E Component Cooling Water 3
A EAST COMPONENT COOLING WATER PUMP Centrifugal 2-PP-l0W Component Cooling Water 3
A WEST COMPONENT COOLING WATER PUMP Centrifugal C omponen tG roup: CTS 1 l-PP-9E Containment Spray 2
B EAST CONTAINMENT SPRAY PUMP Centrifugal l-PP-9W Containment Spray 2
B WEST CONTAINMENT SPRAY PUMP Centrifugal 2-PP-9E Containment Spray 2
B EAST CONTAINMENT SPRAY PUMP Centrifugal 2-PP-9W Containment Spray 2
B WEST CONTAINMENT SPRAY PUMP Centrifugal Component Group: EDG-1 1-QT-130-ABl Diesel Jacket Water NC Aug-B AB EMERGENCY DIESEL JACKET WATER Centrifugal PUMP #1 1-QT-130-AB2 Diesel Jacket Water NC Aug-B AB EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#2 1-QT-130-CDl Diesel Jacket Water NC Aug-B CD EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#l 1-QT-130-CD2 Diesel Jacket Water NC Aug-B CD EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#2 2-QT-130-ABl Diesel Jacket Water NC Aug-B AB EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#l 2-QT-130-AB2 Diesel Jacket Water NC Aug-B AB EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#2 2-QT-130-CDl Diesel Jacket Water NC Aug-B CD EMERGENCY DIESEL JACKET WATER Centrifugal PUMP #1 2-QT-13 0-CD2 Diesel Jacket Water NC Aug-B CD EMERGENCY DIESEL JACKET WATER Centrifugal PUMP#2 of AEP-NRC-2021-16 Page 5 Component System Code OM Description Pump Type Class Group Component Group: EDG-2 1-QT-106-ABl Diesel Fuel Oil NC Aug-A AB EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #1 Displacement l-QT-106-AB2 Diesel Fuel Oil NC Aug-A AB EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #2 Displacement 1-QT-106-CDl Diesel Fuel Oil NC Aug-A CD EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #1 Displacement 1-QT-106-CD2 Diesel Fuel Oil NC Aug-A CD EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #2 Displacement 2-QT-106-ABl Diesel Fuel Oil NC Aug-A AB EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #1 Displacement 2-QT-106-AB2 Diesel Fuel Oil NC Aug-A AB EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #2 Disulacement 2-QT-106-CD 1 Diesel Fuel Oil NC Aug-A CD EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #1 Displacement 2-QT-106-CD2 Diesel Fuel Oil NC Aug-A CD EMERGENCY DIESEL FUEL OIL Positive TRANSFER PUMP #2 Displacement Component Group: ESW-1 1-PP-7E Essential Service Water 3
A EAST ESSENTIAL SERVICE WATER PUMP Vertical Line Shaft 1-PP-7W Essential Service Water 3
A WEST ESSENTIAL SERVICE WATER PUMP Vertical Line Shaft 2-PP-7E Essential Service Water 3
A EAST ESSENTIAL SERVICE WATER PUMP Vertical Line Shaft 2-PP-7W Essential Service Water 3
A WEST ESSENTIAL SERVICE WATER PUMP Vertical Line Shaft of AEP-NRC-2021-16 Page 6 Component System Code OM Description Pump Type Class Group C omponen tG roup: RHR 1 1-PP-35E Residual Heat Removal 2
A EAST RESIDUAL HEAT REMOVAL PUMP Centrifugal 1-PP-35W Residual Heat Removal 2
A WEST RESIDUAL HEAT REMOVAL PUMP Centrifugal 2-PP-35E Residual Heat Removal 2
A EAST RESIDUAL HEAT REMOVAL PUMP Centrifugal 2-PP-35W Residual Heat Removal 2
A WEST RESIDUAL HEAT REMOVAL PUMP Centrifugal Component Group: SFP-1 12-PP-31N Spent Fuel Pool Cooling and 3
A NORTHSPENTFUELPITPUMP Centrifugal Cleanup 12-PP-31S Spent Fuel Pool Cooling and 3
A SOUTH SPENT FUEL PIT PUMP Centrifugal Cleanup Component Group: S1-1 1-PP-26N Safety Injection 2
B NORTH SAFETY INJECTION PUMP Centrifugal 1-PP-26S Safety Injection 2
B SOUTH SAFETY INJECTION PUMP Centrifugal 2-PP-26N Safety Injection 2
B NORTH SAFETY INJECTION PUMP Centrifugal 2-PP-26S Safety Injection 2
B SOUTH SAFETY INJECTION PUMP Centrifugal of AEP-NRC-2021-16 Page 7 EMIB REVIEW NOTE ASME prepares Code Cases to provide alternative methods to satisfy certain requirements of the ASME OM Code. Recently, ASME issued Code Case OMN-22, "Smooth Running Pumps," to provide its recommended method for an alternative to the ASME OM Code pump testing requirements for smooth running pumps. The wording in the licensee's alternative request looks similar to OMN-22, but this Code Case is not directly referenced in the alternative request. Does the similarity in wording reflect the licensee's intention to follow OMN-22?
l&M Response to EMIB REVIEW NOTE The intent of this relief request was to follow Code Case OMN-22, "Smooth Running Pumps." The code case was not mentioned in the relief request since it has not been endorsed by the NRC.
Yes, l&M is requesting relief to use Code Case OMN-22 for the remainder of the CNP 1ST 5th Interval.