ML23215A166
| ML23215A166 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 08/17/2023 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Lies Q Indiana Michigan Power Co |
| References | |
| EPID L 2023 LRM 0047 | |
| Download: ML23215A166 (1) | |
Text
August 17, 2023 LICENSEE:
Indiana Michigan Power Company, LLC FACILITY:
Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2
SUBJECT:
SUMMARY
OF JULY 31, 2023, MEETING WITH INDIANA MICHIGAN POWER COMPANY REGARDING OPERATING POWER SOURCES FOR DONALD C.
COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 (EPID L-2023-LRM-0047)
On July 31, 2023, an observation public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Indiana Michigan Power Company (I&M, the licensee) via webinar. The purpose of the meeting was to discuss planned license amendment requests (LARs) for the Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2, related to revising Technical Specifications (TS) 3.8.1, AC [Alternating Current] Sources - Operating, to extend the Completion Time to allow for upgrades to the reserve feed enclosure. The meeting notice and agenda dated July 18, 2023, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML23209A063. I&Ms meeting handout is available at ML23208A292. A list of attendees is enclosed.
The licensee indicated that CNPs existing 34.5kV loop feed enclosure (LFE) 12AB has experienced several past instances of failures contributing to the loss of the Train B reserve feed. One of the failures resulted in the licensee requesting the NRC to exercise discretion to not enforce compliance with the actions required by TS 3.8.1 (ML21063A568). I&M indicated that the root cause of these failures was factored by the non-segregated phase bus duct of the LFE. As such, the licensee intends on replacing the LFE non-segregated phase bus duct with a cable bus. The projected replacement schedule exceeds the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time limit of ACTION A.3 of TS 8.3.1.
The potential LARs would extend the Completion Time on a temporary one-time basis to 9 days. The licensee stated that the proposed amendment will be risk-informed and follow the guidance in 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 (ML17317A256), and RG 1.177, Plant-Specific, Risk-Informed Decision-making: Technical Specifications, Revision 2, dated January 2021 (ML20164A034).
I&M currently plans to submit the LAR request in Fall 2023 and to request approval to support work being performed in September 2024.
The NRC staff provided feedback on the following topics:
Loss-of-Cool Accident (LOCA) Model: The NRC staff noted that the licensee previously transitioned from deterministic to realistic model for the CNP LOCA analysis1,2. The NRC staff recalled its concerns with the predicted peak cladding temperatures (PCTs) for both units using the Westinghouse Electric Company (Westinghouse)-furnished realistic emergency core cooling system (ECCS) evaluation models3,4. Based on the proximity of the PCTs to the regulatory limit of 2200 degree Fahrenheit (°F), approving an increase of the allowed TS time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 9 days without extensive deterministic analysis and/or probabilistic risk assessment (PRA) calculations to address LOCA impacts would be a very significant challenge.
Final Design: During discussions, the licensee indicated that the design of the modification was still draft. The NRC staff noted that it would be difficult to conduct a proper technical review of a draft design and recommended that the application not be submitted until the design was in a state where the project parameters (i.e., required Completion Time, effect on plant parameters, risk results) were finalized.
Supporting Risk Information: The NRC staff suggested that the application include a robust discussion of PRA quality, including identifying any open Facts and Observations (F&Os), and detailed dispositions of the open F&Os including their impact on the application.
Precedent: The licensee referenced a July 2020, LAR for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2 (ML20213C715), as an action similar to what may be submitted for CNP. The NRC staff noted the complexity of the Hatch review and recommended that I&M review the final safety evaluation and TS pages issued (ML20254A067) with a focus how compensatory and risk management control commitments were handled in the approved package. Where applicable, the proposed TS for a one-time extended Completion Time should include language that instructs the licensee on what to do if associated risk management actions (or compensatory measures) are found not met, with a Completion Time. If the licensee chooses not to propose additional TS required actions for unmet risk management actions, the NRC staff recommended that these actions and their Completion Time be listed in the LAR with a reference to the LAR in the proposed TS.
Review Timeline: The licensee requested an estimate duration for the NRC staff to review the application. The NRC staff indicated that the standard review timeline was 1 year subject to the quality of the submittal. When the licensee indicated that the final design may not be completed until April 2024, the NRC staff noted that should the 1 Beltz, T. A., U.S. Nuclear Regulatory Commission, letter to Rencheck, M., Indiana Michigan Power Company, Donald C. Cook Nuclear Plant, Unit 1 - Issuance of Amendment to Renewed Facility Operating License Regarding Use of The Westinghouse Astrum Large Break Loss-of-Coolant Accident Analysis Methodology (TAC No. MD7556),
dated October 17, 2008 (ML082670379).
2 Tam, P. S., U.S. Nuclear Regulatory Commission, letter to Weber, L., Indiana Michigan Power Company, Donald C. Cook Nuclear Plant, Unit 2 (CNP-2) -Issuance of Amendment to Adopt a New Large-Break Loss-of-Coolant Accident Analysis (TAC No. ME1017), dated March 31, 2011 (ML110730783).
3 Evans, M. G., U. S. Nuclear Regulatory Commission to Weber, L., Indiana Michigan Power Company, Donald C.
Cook Nuclear Plant Units 1 and 2 - Information Request Pursuant to 10 CFR 50.54(f) Related to the Estimated Effect on Peak Cladding Temperature Resulting from Thermal Conductivity Degradation in the Westinghouse-Furnished Realistic Emergency Core Cooling System Evaluation (TAC No. M99899), dated February 16, 2012 (ML12041A384).
4 AEP-NRC-2012-13, Donald C. Cook Nuclear Plant Units 1 and 2, Response to Information Request Pursuant to 10 CFR 50.54(f) Related to the Estimated Effect on Peak Cladding Temperature Resulting from Thermal Conductivity Degradation in the Westinghouse-Furnished Realistic Emergency Core Cooling System Evaluation (TAC No. M99899), March 19. 2012 (ML12088A104).
application not be submitted until April or May 2024, to support the licensee work potentially being performed in September 2024, the shorted review timeline would need to be justified (i.e., exigent circumstances)
No members of the public participated in the meeting. No regulatory decisions were made at this meeting.
Please direct any inquiries to me at 301-415-2855, or Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES JULY 31, 2023, PUBLIC MEETING WITH I&M DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 PLANNED LICENSE AMENDMENT REQUEST RELATED TO OPERATING POWER SOURCES Name Organization Scott Wall Nuclear Regulatory Commission (NRC)
Jeff Whited NRC Brian Wittick NRC Diana Woodyatt NRC Andrew Mihalik NRC Fred Forsaty NRC Khadijah West NRC Shivani Mehta NRC Charles Moulton NRC Steve Wyman NRC Khoi Nguyen NRC Paul Zurawski NRC Helen L Levendosky Indiana Michigan Power Company (I&M)
Joe Tanko I&M Keith Steinmetz I&M Aaron Noga I&M James Salliotte I&M Scott Schneider I&M Chris Peckat I&M Dan Billings I&M Rod Foster I&M Lucas Shelton I&M John Soethe I&M Erick Hengy I&M Mike Allee I&M Terry Beilman I&M Kevin Dalton I&M Sam Falvo Jensen Hughes Richard Sanchez Sargent Lundy
ML23215A166 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME SWall SRohrer JWhited SWall DATE 08/14/2023 08/15/2023 08/16/2023 08/17/2023