ML13213A447: Difference between revisions

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| number = ML13213A447
| number = ML13213A447
| issue date = 07/11/2013
| issue date = 07/11/2013
| title = 2013/07/11 NRR E-mail Capture - DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)
| title = NRR E-mail Capture - DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses
| author name = Wengert T J
| author name = Wengert T
| author affiliation = NRC/NRR/DORL/LPLIII-1
| author affiliation = NRC/NRR/DORL/LPLIII-1
| addressee name = Etheridge H L
| addressee name = Etheridge H
| addressee affiliation = Indiana & Michigan Electric Co
| addressee affiliation = Indiana & Michigan Electric Co
| docket = 05000315, 05000316
| docket = 05000315, 05000316
Line 13: Line 13:
| document type = E-Mail
| document type = E-Mail
| page count = 3
| page count = 3
| project = TAC:MF1308, TAC:MF1309
| stage = Draft RAI
}}
}}
=Text=
{{#Wiki_filter:NRR-PMDAPEm Resource From:                      Wengert, Thomas Sent:                      Thursday, July 11, 2013 1:42 PM To:                        hletheridge@aep.com Cc:                        'mkscarpello@aep.com' (mkscarpello@aep.com)
==Subject:==
DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)
Attachments:                DC Cook - Draft RAI Concerning LR Commitment Change 7-11-13.pdf
: Helen, Attached is a draft Request for Additional Information (RAI) concerning AEPs March 1, 2013, letter (ADAMS Accession No. ML13073A110) concerning a revision to Regulatory Commitments associated with application for Renewed Operating Licenses. Please review this draft RAI and let me know if you would like to have a conference call with the NRC staff to clarify this request.
Also, lets discuss the timing of your response.
: Regards, Tom Wengert Project Manager - DC Cook USNRC NRR/DORL/LPL3-1 (301) 415-4037 1
Hearing Identifier:    NRR_PMDA Email Number:          784 Mail Envelope Properties      (Thomas.Wengert@nrc.gov20130711134100)
==Subject:==
DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)
Sent Date:              7/11/2013 1:41:39 PM Received Date:          7/11/2013 1:41:00 PM From:                  Wengert, Thomas Created By:            Thomas.Wengert@nrc.gov Recipients:
"'mkscarpello@aep.com' (mkscarpello@aep.com)" <mkscarpello@aep.com>
Tracking Status: None "hletheridge@aep.com" <hletheridge@aep.com>
Tracking Status: None Post Office:
Files                            Size                  Date & Time MESSAGE                          562                    7/11/2013 1:41:00 PM DC Cook - Draft RAI Concerning LR Commitment Change 7-11-13.pdf                    79494 Options Priority:                        Standard Return Notification:            No Reply Requested:                No Sensitivity:                    Normal Expiration Date:
Recipients Received:
DRAFT REQUEST FOR ADDITIONAL INFORMATION REVISION TO REGULATORY COMMITMENTS ASSOCIATED WITH APPLICATION FOR RENEWED OPERATING LICENSES DONALD C. COOK NUCLEAR PLANT (CNP), UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 By letter AEP-NRC-2013-15, dated March 1, 2013 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML13073A110), Indiana Michigan Power Company (I&M) submitted a notification of a change to a portion of Commitment No. 23 of Appendix A of NUREG-1831 (ADAMS Accession No. ML051510092), Safety Evaluation Report Related to the License Renewal of the Donald C. Cook Nuclear Plant, Units 1 and 2.
Commitment No. 23 states, in part, that the licensee will enhance the Structures Monitoring Program to include the security diesel generator room prior to October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2. In its March 1, 2013 letter, the licensee stated that it is changing this commitment to remove the security diesel generator room from inclusion to the Structures Monitoring aging management program (AMP) because the security diesel generator does not meet the scoping requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 54.4 since the security diesel generator does not perform a safety function and the security diesel is not credited for outside lighting for either the 10 CFR Appendix R or National Fire Protection Association Standard 805 (NFPA 805) Fire Protection Programs. The Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete the review.
Table 2.4.4-1 of the CNP license renewal application (LRA) listed the security diesel generator room as a yard structure with a license renewal function of shelter and support for the security diesel generator, which provides lighting required for 10 CFR 50.48, in accordance with the scoping criteria in 10 CFR 54.4(a)(3). LRA Section 2.3.3.6 also states that the function of the security diesel is to provide power for emergency lighting for access to nitrogen regulator valves and that the security diesel is required to support the Appendix R safe shutdown analysis.
However, I&M letter AEP-NRC-2013-15 indicates that the security diesel generator is not credited in the Appendix R or NFPA 805 fire protection programs. The NRC staff is requesting clarification on the contradictory information about the function of the security diesel generator and the equipment used in the Appendix R safe shutdown analysis, with respect to the scope of license renewal aging management consideration.
RAI-01:          Indicate specifically what equipment, relative to the function stated above, is credited in the Appendix R safe shutdown analysis.
RAI-02:          If equipment other than the security diesel is used to perform the stated function, state whether the equipment and supporting or sheltering structures or components are in scope of the Structures Monitoring AMP. If those structures or components are not in the Structures Monitoring AMP, provide technical basis for excluding them from the program.}}

Latest revision as of 03:51, 20 March 2020

NRR E-mail Capture - DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses
ML13213A447
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 07/11/2013
From: Thomas Wengert
Plant Licensing Branch III
To: Etheridge H
Indiana & Michigan Electric Co
References
TAC MF1308, TAC MF1309
Download: ML13213A447 (3)


Text

NRR-PMDAPEm Resource From: Wengert, Thomas Sent: Thursday, July 11, 2013 1:42 PM To: hletheridge@aep.com Cc: 'mkscarpello@aep.com' (mkscarpello@aep.com)

Subject:

DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)

Attachments: DC Cook - Draft RAI Concerning LR Commitment Change 7-11-13.pdf

Helen, Attached is a draft Request for Additional Information (RAI) concerning AEPs March 1, 2013, letter (ADAMS Accession No. ML13073A110) concerning a revision to Regulatory Commitments associated with application for Renewed Operating Licenses. Please review this draft RAI and let me know if you would like to have a conference call with the NRC staff to clarify this request.

Also, lets discuss the timing of your response.

Regards, Tom Wengert Project Manager - DC Cook USNRC NRR/DORL/LPL3-1 (301) 415-4037 1

Hearing Identifier: NRR_PMDA Email Number: 784 Mail Envelope Properties (Thomas.Wengert@nrc.gov20130711134100)

Subject:

DC Cook - Draft RAI Concerning Revision to Regulatory Commitments Associated with Application for Renewed Operating Licenses (TAC Nos. MF1308 and MF1309)

Sent Date: 7/11/2013 1:41:39 PM Received Date: 7/11/2013 1:41:00 PM From: Wengert, Thomas Created By: Thomas.Wengert@nrc.gov Recipients:

"'mkscarpello@aep.com' (mkscarpello@aep.com)" <mkscarpello@aep.com>

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

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 562 7/11/2013 1:41:00 PM DC Cook - Draft RAI Concerning LR Commitment Change 7-11-13.pdf 79494 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION REVISION TO REGULATORY COMMITMENTS ASSOCIATED WITH APPLICATION FOR RENEWED OPERATING LICENSES DONALD C. COOK NUCLEAR PLANT (CNP), UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316 By letter AEP-NRC-2013-15, dated March 1, 2013 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML13073A110), Indiana Michigan Power Company (I&M) submitted a notification of a change to a portion of Commitment No. 23 of Appendix A of NUREG-1831 (ADAMS Accession No. ML051510092), Safety Evaluation Report Related to the License Renewal of the Donald C. Cook Nuclear Plant, Units 1 and 2.

Commitment No. 23 states, in part, that the licensee will enhance the Structures Monitoring Program to include the security diesel generator room prior to October 25, 2014, for Unit 1 and December 23, 2017, for Unit 2. In its March 1, 2013 letter, the licensee stated that it is changing this commitment to remove the security diesel generator room from inclusion to the Structures Monitoring aging management program (AMP) because the security diesel generator does not meet the scoping requirements specified in Title 10 of the Code of Federal Regulations (10 CFR) Section 54.4 since the security diesel generator does not perform a safety function and the security diesel is not credited for outside lighting for either the 10 CFR Appendix R or National Fire Protection Association Standard 805 (NFPA 805) Fire Protection Programs. The Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed to complete the review.

Table 2.4.4-1 of the CNP license renewal application (LRA) listed the security diesel generator room as a yard structure with a license renewal function of shelter and support for the security diesel generator, which provides lighting required for 10 CFR 50.48, in accordance with the scoping criteria in 10 CFR 54.4(a)(3). LRA Section 2.3.3.6 also states that the function of the security diesel is to provide power for emergency lighting for access to nitrogen regulator valves and that the security diesel is required to support the Appendix R safe shutdown analysis.

However, I&M letter AEP-NRC-2013-15 indicates that the security diesel generator is not credited in the Appendix R or NFPA 805 fire protection programs. The NRC staff is requesting clarification on the contradictory information about the function of the security diesel generator and the equipment used in the Appendix R safe shutdown analysis, with respect to the scope of license renewal aging management consideration.

RAI-01: Indicate specifically what equipment, relative to the function stated above, is credited in the Appendix R safe shutdown analysis.

RAI-02: If equipment other than the security diesel is used to perform the stated function, state whether the equipment and supporting or sheltering structures or components are in scope of the Structures Monitoring AMP. If those structures or components are not in the Structures Monitoring AMP, provide technical basis for excluding them from the program.