ML24115A215

LTR: CNP Non-Acceptance with Opportunity TS 3-8-1

ML24115A215
Person / Time
Site:	Cook
Issue date:	05/07/2024
From:	Scott Wall Plant Licensing Branch III
To:	Lies Q Indiana Michigan Power Co
References
EPID L-2024-LLA-0040
Download: ML24115A215 (1)

Text

May 7, 2024

Q. Shane Lies Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106

SUBJECT:

DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 -

SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF LICENSE AMENDMENT REQUEST TO REVISE TE CHNICAL SPECIFICATION 3.8.1 (EPID NO. L-2024-LLA-0040)

Dear Q. Shane Lies:

By letter dated April 3, 2024 (Agencywide Documents and Access Management System Accession No. ML24094A288), Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) for the Donald C. Cook Nuclear Plant (CNP), Units Nos. 1 and 2 (CNP). The proposed LAR would revise Technical Specification (TS) 3.8.1, AC Sources

- Operating, by adding a footnote for TS 3.8.1, Required Action A.3 to allow a one-time completion time (CT) extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> to support the replacement of the 12AB (Train B) Loop Feed Enclosure (LFE) and associated bus for the Train B reserve feed preferred power source.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an application for an amendment to a license (including the technical specifications) or construction permit must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements and the protection of public health and safety and the environment.

Q. S. Lies

To make the application complete, the NRC staff requests that licensee supplement the application to address the information requested in the Enclosure by May 17, 2024. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will c ease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.

The information requested in this letter was provided to Michael Scarpello on April 25, 2024, and the associated response time frame was discussed with Helen Levendosky on May 2, 2024.

If you have any questions, please contact me at 301-415-2855, or at 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:

Supplemental Information Needed

cc: Listserv

SUPPLEMENTAL INFORMATION NEEDED

LICENSE AMENDMENT REQUEST

INDIANA MICHIGAN POWER COMPANY

DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2

DOCKET NOS. 50-315 AND 50-316

By letter dated April 3, 2024 (Agencywide Documents and Access Management System Accession No. ML24094A288), Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) for the Donald C. Cook Nuclear Plant (CNP), Units Nos. 1 and 2 (CNP). The proposed LAR would revise Technical Specification (TS) 3.8.1, AC Sources

- Operating, by adding a footnote for TS 3.8.1, Required Action A.3 to allow a one-time completion time (CT) extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> to support the replacement of the 12AB (Train B) Loop Feed Enclosure (LFE) and associated bus for the Train B reserve feed preferred power source.

Regulatory Basis:

The U.S. Nuclear Regulatory Commission (NRC) st affs guidance for the review of TSs is provided in chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ML100351425). The NRC staff uses Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions (ML113640138), to evaluate LARs for one-time or permanent (completion time) extensions for the emergency diesel generators (EDGs) and offsite power sources.

The SRP is not a substitute for the NRC's regulations, and compliance with it is not required.

However, a licensee is required to identify differences between the design features, analytical techniques, and procedural measures proposed for its facility and the SRP acceptance criteria and evaluate how the proposed alternatives to the SRP acceptance criteria provide an acceptable method of complying with the NRC regulations.

The NRC staff identified several BTP-related items that were not found in the LAR. Please provide information that addresses the topics below in order for the staff to begin its detailed technical review:

EEEB-1. A supplemental alternating current (AC) power source needed. This source should be available as a backup to the inoperable EDG or offsite power source, to maintain the defense-in-depth philosophy of the electrical system to meet its intended function. The supplemental AC power source must have capacity to bring a unit to safe shutdown (cold shutdown) in case of a loss of offsite power (LOOP) concurrent with a single failure during plant operation (Mode 1) as supported by the risk-informed and deterministic evaluation.

Note: Multi-unit sites that have installed a single supplemental AC power source for station blackout (SBO) cannot substitute it for the inoperable diesel when requesting

Enclosure

CT extensions unless the supplemental AC power source has enough capacity to carry all LOOP loads to bring the unit to a cold shutdown as a substitute for the EDG in an extended CT and carry all SBO loads for the unit that has an SBO event without any load shedding.

EEEB-2. The time to make the supplemental AC power source available, including accomplishing the cross-connection, should be approximately one hour to enable restoration of battery chargers and control reactor coolant system inventory.

Note: To support the one-hour time for making this power source available, plants must assess their ability to cope with loss of all AC power (SBO) for one hour independent of a supplemental AC power source. The plant should have formal engineering calculations for equipment sizing and protection and have approved procedures for connecting the supplemental AC power source to the safety buses.

EEEB-3. The availability of supplemental AC power source should be verified within the last 30 days before entering extended CT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational.

EEEB-4. The availability of supplemental AC power source shall be checked every 8-12 hours (once per shift). If the supplemental AC power source becomes unavailable any time during extended CT, the unit shall enter the LCO and start shutting down within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This 24-hour period will be allowed only once within any given extended CT for the restoration of the offsite power.

EEEB-5. The six regulatory commitments listed on page 8-8-5 of BTP 8-8.

ML24115A215 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DEX/EEEB/BC NAME Swall SRohrer WMorton DATE 04/24/2024 04/25/2024 05/06/2024 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME JWhited SWall DATE 05/06/2024 05/07/2024