ML15342A049

NRR E-mail Capture - D.C. Cook Units 1 and 2 - Arcb RAI Concerning LAR to Adopt TSTF-490 and Implement Full Scope AST (MF5184 and MF5185)

ML15342A049
Person / Time
Site:	Cook
Issue date:	12/07/2015
From:	Dietrich A Plant Licensing Branch III
To:	Kish H Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co)
References
MF5184, MF5185
Download: ML15342A049 (3)

Text

NRR-PMDAPEm Resource From: Dietrich, Allison Sent: Monday, December 07, 2015 4:25 PM To: hlkish@aep.com Cc: Terry L Curtiss (tlcurtiss@aep.com); Pelton, David; Shoop, Undine; Dickson, Elijah

Subject:

D.C. COOK UNITS 1 AND 2 - ARCB RAI CONCERNING LAR TO ADOPT TSTF-490 AND IMPLEMENT FULL SCOPE AST (MF5184 AND MF5185)

Attachments: ARCB RAI 9 regarding Alternate Source Term MF5184 MF5185.pdf By letter dated November 14, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML14324A209), as supplemented by letter dated February 12, 2015 (ADAMS Accession No. ML15050A247), Indiana Michigan Power Company (I&M) submitted a license amendment request for the Donald C. Cook Nuclear Plant, Units 1 and 2. The proposed amendment consists of adoption of Technical Specifications Task Force (TSTF)-490, Revision 0, and implementation of a full scope alternate source term radiological analysis methodology.

The U.S. Nuclear Regulatory Commission (NRC) staff in the Radiation Protection and Consequence Branch of the Office of Nuclear Reactor Regulation is currently reviewing your submittal, as supplemented. The staff has determined that additional information is needed in order to complete the review, as described in the attached Request for Additional Information (RAI). The draft RAI was sent to I&M via electronic mail on November 10, 2015. Please provide your response by January 7, 2016.

Please let me know if you have any questions or concerns.

Sincerely, Allison W. Dietrich, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-2846 1

Hearing Identifier: NRR_PMDA Email Number: 2537 Mail Envelope Properties (Allison.Dietrich@nrc.gov20151207162400)

Subject:

D.C. COOK UNITS 1 AND 2 - ARCB RAI CONCERNING LAR TO ADOPT TSTF-490 AND IMPLEMENT FULL SCOPE AST (MF5184 AND MF5185)

Sent Date: 12/7/2015 4:24:41 PM Received Date: 12/7/2015 4:24:00 PM From: Dietrich, Allison Created By: Allison.Dietrich@nrc.gov Recipients:

"Terry L Curtiss (tlcurtiss@aep.com)" <tlcurtiss@aep.com>

Tracking Status: None "Pelton, David" <David.Pelton@nrc.gov>

Tracking Status: None "Shoop, Undine" <Undine.Shoop@nrc.gov>

Tracking Status: None "Dickson, Elijah" <Elijah.Dickson@nrc.gov>

Tracking Status: None "hlkish@aep.com" <hlkish@aep.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1273 12/7/2015 4:24:00 PM ARCB RAI 9 regarding Alternate Source Term MF5184 MF5185.pdf 94954 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING ADOPTION OF TSTF-490, REVISION 0 AND IMPLEMENTATION OF FULL-SCOPE ALTERNATE SOURCE TERM DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 CAC NOS. MF5184 AND MF5185 RAI-ARCB-9 The Donald C. Cook Nuclear Plant (CNP) licensing basis includes analyses for the radiological consequences of a ruptured gas decay tank and a ruptured volume control tank. Regulatory Guide (RG) 1.183 does not provide any guidance relative to either accident. Guidelines for the waste gas decay tank and volume control tank rupture analyses are given in Branch Technical Position 11-5 (BTP 11-5) of NUREG-0800, Standard Review Plan (SRP), with additional guidance contained in Regulatory Issue Summary (RIS) 2006-04.

Item 11 of RIS 2006-04 states the following:

As part of full AST [alternative source term] implementation, some licensees have included an accident involving a release from their off-gas or waste gas system. For this accident, they have proposed acceptance criteria of 500 millirem (mrem) total effective dose equivalent (TEDE).

The acceptance criteria for this event is that associated with the dose to an individual member of the public as described in 10 CFR [Title 10 of the Code of Federal Regulations] Part 20 , Standards for Protection Against Radiation.

When the NRC revised 10 CFR Part 20 to incorporate a TEDE dose, the offsite dose to an individual member of the public was changed from 500 mrem whole body to 100 mrem TEDE. Therefore, any licensee who chooses to implement AST for an off-gas or waste gas system release should base its acceptance criteria on 100 mrem TEDE. Licensees may also choose not to implement AST for this accident and continue with their existing analysis and acceptance criteria of 500 mrem whole body.

The licensee has proposed that these event-types be evaluated against the existing 500 mrem acceptance criterion for both the exclusion area boundary (EAB) and low population zone (LPZ). Item 11 of RIS-2006-04 only allows the use of the existing current licensing basis acceptance criterion of 500 mrem whole body at the EAB when these types of events are not submitted as part of the AST implementation. Since the licensee has submitted these event-types as part of the full AST implementation, the results of both accidents should be evaluated against the revised 100 mrem acceptance criterion for both the EAB and LPZ.

x Revise the waste gas decay tank rupture and volume control tank rupture analyses in accordance with the guidance provided in RIS-2006-04, which states that dose evaluations at the EAB and LPZ should be evaluated against the revised 100 mrem TEDE acceptance criterion.

NRR-PMDAPEm Resource From: Dietrich, Allison Sent: Monday, December 07, 2015 4:25 PM To: hlkish@aep.com Cc: Terry L Curtiss (tlcurtiss@aep.com); Pelton, David; Shoop, Undine; Dickson, Elijah

Subject:

D.C. COOK UNITS 1 AND 2 - ARCB RAI CONCERNING LAR TO ADOPT TSTF-490 AND IMPLEMENT FULL SCOPE AST (MF5184 AND MF5185)

Attachments: ARCB RAI 9 regarding Alternate Source Term MF5184 MF5185.pdf By letter dated November 14, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No.

ML14324A209), as supplemented by letter dated February 12, 2015 (ADAMS Accession No. ML15050A247), Indiana Michigan Power Company (I&M) submitted a license amendment request for the Donald C. Cook Nuclear Plant, Units 1 and 2. The proposed amendment consists of adoption of Technical Specifications Task Force (TSTF)-490, Revision 0, and implementation of a full scope alternate source term radiological analysis methodology.

The U.S. Nuclear Regulatory Commission (NRC) staff in the Radiation Protection and Consequence Branch of the Office of Nuclear Reactor Regulation is currently reviewing your submittal, as supplemented. The staff has determined that additional information is needed in order to complete the review, as described in the attached Request for Additional Information (RAI). The draft RAI was sent to I&M via electronic mail on November 10, 2015. Please provide your response by January 7, 2016.

Please let me know if you have any questions or concerns.

Sincerely, Allison W. Dietrich, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-2846 1

Hearing Identifier: NRR_PMDA Email Number: 2537 Mail Envelope Properties (Allison.Dietrich@nrc.gov20151207162400)

Subject:

D.C. COOK UNITS 1 AND 2 - ARCB RAI CONCERNING LAR TO ADOPT TSTF-490 AND IMPLEMENT FULL SCOPE AST (MF5184 AND MF5185)

Sent Date: 12/7/2015 4:24:41 PM Received Date: 12/7/2015 4:24:00 PM From: Dietrich, Allison Created By: Allison.Dietrich@nrc.gov Recipients:

"Terry L Curtiss (tlcurtiss@aep.com)" <tlcurtiss@aep.com>

Tracking Status: None "Pelton, David" <David.Pelton@nrc.gov>

Tracking Status: None "Shoop, Undine" <Undine.Shoop@nrc.gov>

Tracking Status: None "Dickson, Elijah" <Elijah.Dickson@nrc.gov>

Tracking Status: None "hlkish@aep.com" <hlkish@aep.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 1273 12/7/2015 4:24:00 PM ARCB RAI 9 regarding Alternate Source Term MF5184 MF5185.pdf 94954 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REGARDING ADOPTION OF TSTF-490, REVISION 0 AND IMPLEMENTATION OF FULL-SCOPE ALTERNATE SOURCE TERM DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 CAC NOS. MF5184 AND MF5185 RAI-ARCB-9 The Donald C. Cook Nuclear Plant (CNP) licensing basis includes analyses for the radiological consequences of a ruptured gas decay tank and a ruptured volume control tank. Regulatory Guide (RG) 1.183 does not provide any guidance relative to either accident. Guidelines for the waste gas decay tank and volume control tank rupture analyses are given in Branch Technical Position 11-5 (BTP 11-5) of NUREG-0800, Standard Review Plan (SRP), with additional guidance contained in Regulatory Issue Summary (RIS) 2006-04.

Item 11 of RIS 2006-04 states the following:

As part of full AST [alternative source term] implementation, some licensees have included an accident involving a release from their off-gas or waste gas system. For this accident, they have proposed acceptance criteria of 500 millirem (mrem) total effective dose equivalent (TEDE).

The acceptance criteria for this event is that associated with the dose to an individual member of the public as described in 10 CFR [Title 10 of the Code of Federal Regulations] Part 20 , Standards for Protection Against Radiation.

When the NRC revised 10 CFR Part 20 to incorporate a TEDE dose, the offsite dose to an individual member of the public was changed from 500 mrem whole body to 100 mrem TEDE. Therefore, any licensee who chooses to implement AST for an off-gas or waste gas system release should base its acceptance criteria on 100 mrem TEDE. Licensees may also choose not to implement AST for this accident and continue with their existing analysis and acceptance criteria of 500 mrem whole body.

The licensee has proposed that these event-types be evaluated against the existing 500 mrem acceptance criterion for both the exclusion area boundary (EAB) and low population zone (LPZ). Item 11 of RIS-2006-04 only allows the use of the existing current licensing basis acceptance criterion of 500 mrem whole body at the EAB when these types of events are not submitted as part of the AST implementation. Since the licensee has submitted these event-types as part of the full AST implementation, the results of both accidents should be evaluated against the revised 100 mrem acceptance criterion for both the EAB and LPZ.

x Revise the waste gas decay tank rupture and volume control tank rupture analyses in accordance with the guidance provided in RIS-2006-04, which states that dose evaluations at the EAB and LPZ should be evaluated against the revised 100 mrem TEDE acceptance criterion.