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=Text=
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{{#Wiki_filter:NRR-DRMAPEm Resource From:                              Kuntz, Robert Sent:                              Tuesday, July 23, 2019 5:32 AM To:                                Helen L Levendosky Cc:                                Joe Tanko (jmtanko@aep.com)
 
==Subject:==
RE: D.C. Cook Nuclear Plant Unit Nos. 1 and 2 - Request for Additional Information related to Unit 2 Leak Before Break Analysis and Deletion of Containment Humidity Monitors for Unit Nos. 1 and 2 (EPID: L-2018-LLA-0726)
By letter dated November 20, 2018 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML18334A267), Indiana Michigan Power (I&M, the licensee), requested an amendment which would revise Donald C. Cook Nuclear Plant (CNP),Units 1 and 2 TS 3.4.15, RCS [Reactor Coolant System]
Leakage Detection Instrumentation, and delete the containment humidity monitor from the Limiting Condition of Operations statement and application of leak-before-break (LBB) methodology for CNP, Unit 2.
The U.S. Nuclear Regulatory Commission staff has reviewed the submittal and determined that additional information is required in order to complete the review. Therefore, included in this e-mail is a requested for additional information (RAI). During a teleconference held on July 22, 2019, which was held for the NRC staff to provided clarification on the included RAI, a 30-day response to the request was agreed upon. Therefore, the NRC staff expects a response within 30 days of this message which is on or before August 23, 2019.
Sincerely, Robert F. Kuntz, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation DRAFT REQUEST FOR ADDITIONAL INFORMATION DONALD C. COOK NUCLEAR PLANT (CNP), UNITS 1 AND 2 LICENSE AMENDMENT REQUEST TO CHANGE TECHNICAL SPECIFICATION 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION, DELETION OF CONTAINMENT HUMIDITY MONITOR AND APPLICATION OF LEAK-BEFORE BREAK FOR CNP, UNIT 2 (EPID: L-2018-LLA-0726)
RAI - 1 The license amendment request provided by letter dated November 20, 2018 requested, in part, application of LBB methodology for CNP, Unit 2. As noted in the November 20, 2018 amendment request, I&M had requested application LBB methodology for CNP, Unit 1 by letter dated March 7, 2018.
Subsequent to the November 20, 2018 amendment request, the CNP, Unit 1, LBB methodology was supplemented by letters dated November 27, 2018, and May 6, 2019, to revise the LBB analysis.
Request:
: a. Revise the LBB analysis for CNP, Unit 2, as necessary, to address the supplements to the CNP, Unit 1 LBB analysis.
: b. Table 7-1 of the WCAP-18295 and WCAP-18309 reports addresses the critical locations of CNP, Unit 2 in the elastic-plastic fracture mechanics (EPFM) analysis. Given that the scope of the LBB 1
 
analysis may be revised, please clarify whether the EPFM analysis is still used in the CNP, Unit 2, LBB analysis. If so, describe the method used to calculate the applied J-integral values in the fracture mechanics analysis (e.g., how the applied J-integral values are derived from the applied loads and associated plastic deformation). Alternatively, provide relevant references. In addition, clarify whether the applied tearing modulus values are also calculated and used in the analysis.
RAI - 2 From the license amendment request letter dated November 20, 2018, Enclosure 14 (page 3), it states:
Liquid Inventory in the Process Systems and in the Containment Sump For CNP Units 1 and 2, an increase in the amount of coolant make-up water, which is required to maintain normal level in the pressurizer, will be indicated by an increase in charging flow or change in volume control tank level. Gross RCS leakage will be indicated by a rise in normal containment sump level and* periodic operation of containment sump pumps. A run time meter is provided to monitor the frequency of operation and running time of each containment sump pump.
From the license amendment request letter dated November 20, 2018, Enclosures 18 (TS B 3.4.15 for Unit 1, Unit 2 TS B 3.4.15 is identical), it states:
The containment sump is used to collect unidentified LEAKAGE. The containment sump consists of three sumps - the lower containment sump, the reactor cavity sump, and the pipe tunnel sump. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in all three sumps. The monitor for the containment sump detects the operating frequency of a pump and is instrumented to detect when there is an increase above the normal value by 1 gpm [gallon per minute]. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment sump and it may take longer than four hours to detect a 1 gpm increase in unidentified LEAKAGE, depending on the* origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.
NRC Guidance:
NUREG-0800, Standard Review Plan, Section 5.2.5, Reactor Coolant Pressure Boundary Leakage Detection, Revision 2 - March 2007, ADAMS Accession No. ML070610277.
Regulatory Guide (RG) 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973 - Revision 0, ADAMS Accession No. ML003740113.
Request:
Provide additional details related to the Liquid Inventory in the Process Systems and in the Containment Sump monitors available in the main control room, such that their reliance would be just as or more effective than the containment humidity monitors. For example, charging flow and volume control tank level indication, record, and alarm functions; containment sump pump flow and/or containment sump level indication, timers, record, and alarm function, for three total sumps. Similar detail was provided in the LAR letter for other TS 3.4.15 monitors.
2
 
Hearing Identifier:      NRR_DRMA Email Number:            132 Mail Envelope Properties      (BL0PR0901MB4131A7CFBCBF33C3848FA87999C70)
 
==Subject:==
RE: D.C. Cook Nuclear Plant Unit Nos. 1 and 2 - Request for Additional Information related to Unit 2 Leak Before Break Analysis and Deletion of Containment Humidity Monitors for Unit Nos. 1 and 2 (EPID: L-2018-LLA-0726)
Sent Date:              7/23/2019 5:32:29 AM Received Date:          7/23/2019 5:32:00 AM From:                    Kuntz, Robert Created By:              Robert.Kuntz@nrc.gov Recipients:
"Joe Tanko (jmtanko@aep.com)" <jmtanko@aep.com>
Tracking Status: None "Helen L Levendosky" <hllevendosky@aep.com>
Tracking Status: None Post Office:            BL0PR0901MB4131.namprd09.prod.outlook.com Files                            Size                      Date & Time MESSAGE                          5437                      7/23/2019 5:32:00 AM Options Priority:                        Standard Return Notification:            No Reply Requested:                No Sensitivity:                    Normal Expiration Date:
Recipients Received:}}

Revision as of 15:18, 19 October 2019

Request for Additional Information Related to Unit 2 Leak Before Break Analysis and Deletion of Containment Humidity Monitors for Unit Nos. 1 and 2
ML19204A096
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 07/23/2019
From: Robert Kuntz
Plant Licensing Branch III
To: Levendosky H
Indiana & Michigan Electric Co
References
L-2018-LLA-0726
Download: ML19204A096 (3)
v • d • e


Text

NRR-DRMAPEm Resource From: Kuntz, Robert Sent: Tuesday, July 23, 2019 5:32 AM To: Helen L Levendosky Cc: Joe Tanko (jmtanko@aep.com)

Subject:

RE: D.C. Cook Nuclear Plant Unit Nos. 1 and 2 - Request for Additional Information related to Unit 2 Leak Before Break Analysis and Deletion of Containment Humidity Monitors for Unit Nos. 1 and 2 (EPID: L-2018-LLA-0726)

By letter dated November 20, 2018 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML18334A267), Indiana Michigan Power (I&M, the licensee), requested an amendment which would revise Donald C. Cook Nuclear Plant (CNP),Units 1 and 2 TS 3.4.15, RCS [Reactor Coolant System]

Leakage Detection Instrumentation, and delete the containment humidity monitor from the Limiting Condition of Operations statement and application of leak-before-break (LBB) methodology for CNP, Unit 2.

The U.S. Nuclear Regulatory Commission staff has reviewed the submittal and determined that additional information is required in order to complete the review. Therefore, included in this e-mail is a requested for additional information (RAI). During a teleconference held on July 22, 2019, which was held for the NRC staff to provided clarification on the included RAI, a 30-day response to the request was agreed upon. Therefore, the NRC staff expects a response within 30 days of this message which is on or before August 23, 2019.

Sincerely, Robert F. Kuntz, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation DRAFT REQUEST FOR ADDITIONAL INFORMATION DONALD C. COOK NUCLEAR PLANT (CNP), UNITS 1 AND 2 LICENSE AMENDMENT REQUEST TO CHANGE TECHNICAL SPECIFICATION 3.4.15, RCS LEAKAGE DETECTION INSTRUMENTATION, DELETION OF CONTAINMENT HUMIDITY MONITOR AND APPLICATION OF LEAK-BEFORE BREAK FOR CNP, UNIT 2 (EPID: L-2018-LLA-0726)

RAI - 1 The license amendment request provided by letter dated November 20, 2018 requested, in part, application of LBB methodology for CNP, Unit 2. As noted in the November 20, 2018 amendment request, I&M had requested application LBB methodology for CNP, Unit 1 by letter dated March 7, 2018.

Subsequent to the November 20, 2018 amendment request, the CNP, Unit 1, LBB methodology was supplemented by letters dated November 27, 2018, and May 6, 2019, to revise the LBB analysis.

Request:

a. Revise the LBB analysis for CNP, Unit 2, as necessary, to address the supplements to the CNP, Unit 1 LBB analysis.
b. Table 7-1 of the WCAP-18295 and WCAP-18309 reports addresses the critical locations of CNP, Unit 2 in the elastic-plastic fracture mechanics (EPFM) analysis. Given that the scope of the LBB 1

analysis may be revised, please clarify whether the EPFM analysis is still used in the CNP, Unit 2, LBB analysis. If so, describe the method used to calculate the applied J-integral values in the fracture mechanics analysis (e.g., how the applied J-integral values are derived from the applied loads and associated plastic deformation). Alternatively, provide relevant references. In addition, clarify whether the applied tearing modulus values are also calculated and used in the analysis.

RAI - 2 From the license amendment request letter dated November 20, 2018, Enclosure 14 (page 3), it states:

Liquid Inventory in the Process Systems and in the Containment Sump For CNP Units 1 and 2, an increase in the amount of coolant make-up water, which is required to maintain normal level in the pressurizer, will be indicated by an increase in charging flow or change in volume control tank level. Gross RCS leakage will be indicated by a rise in normal containment sump level and* periodic operation of containment sump pumps. A run time meter is provided to monitor the frequency of operation and running time of each containment sump pump.

From the license amendment request letter dated November 20, 2018, Enclosures 18 (TS B 3.4.15 for Unit 1, Unit 2 TS B 3.4.15 is identical), it states:

The containment sump is used to collect unidentified LEAKAGE. The containment sump consists of three sumps - the lower containment sump, the reactor cavity sump, and the pipe tunnel sump. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in all three sumps. The monitor for the containment sump detects the operating frequency of a pump and is instrumented to detect when there is an increase above the normal value by 1 gpm [gallon per minute]. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment sump and it may take longer than four hours to detect a 1 gpm increase in unidentified LEAKAGE, depending on the* origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

NRC Guidance:

NUREG-0800, Standard Review Plan, Section 5.2.5, Reactor Coolant Pressure Boundary Leakage Detection, Revision 2 - March 2007, ADAMS Accession No. ML070610277.

Regulatory Guide (RG) 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973 - Revision 0, ADAMS Accession No. ML003740113.

Request:

Provide additional details related to the Liquid Inventory in the Process Systems and in the Containment Sump monitors available in the main control room, such that their reliance would be just as or more effective than the containment humidity monitors. For example, charging flow and volume control tank level indication, record, and alarm functions; containment sump pump flow and/or containment sump level indication, timers, record, and alarm function, for three total sumps. Similar detail was provided in the LAR letter for other TS 3.4.15 monitors.

2

Hearing Identifier: NRR_DRMA Email Number: 132 Mail Envelope Properties (BL0PR0901MB4131A7CFBCBF33C3848FA87999C70)

Subject:

RE: D.C. Cook Nuclear Plant Unit Nos. 1 and 2 - Request for Additional Information related to Unit 2 Leak Before Break Analysis and Deletion of Containment Humidity Monitors for Unit Nos. 1 and 2 (EPID: L-2018-LLA-0726)

Sent Date: 7/23/2019 5:32:29 AM Received Date: 7/23/2019 5:32:00 AM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients:

"Joe Tanko (jmtanko@aep.com)" <jmtanko@aep.com>

Tracking Status: None "Helen L Levendosky" <hllevendosky@aep.com>

Tracking Status: None Post Office: BL0PR0901MB4131.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5437 7/23/2019 5:32:00 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

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