ML14167A374

Donald C. Cook Units 1 and 2, Response to a Request for Additional Information Regarding the License Amendment Request Regarding Containment Divider Barrier Seal

ML14167A374
Person / Time
Site:	Cook
Issue date:	06/13/2014
From:	Gebbie J P Indiana Michigan Power Co
To:
References
AEP-NRC-2014-31, TAC MF3052, TAC MF3053
Download: ML14167A374 (6)

Text

zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear Plant19111 ERQ One Cook PlaceBridgman, MI 49106A unit ofAmerican Electric Power IndianaMichiganPower.com June 13, 2014 AEP-NRC-2014-31 10 CFR 50.90Docket Nos.: 50-31550-316U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, D. C. 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2Response to a Request for Additional Information Regarding the License Amendment RequestRegarding Containment Divider Barrier Seal

References:

1. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC), "Donald C. Cook Nuclear Plant Unit 1 and Unit 2, License Amendment Request Regarding Containment Divider Barrier Seal," AEP-NRC-2013-50, datedNovember 6, 2013, Agencywide Documents Access and Management System (ADAMS)Accession No. ML13312A006.

2. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1and 2 -Request for Additional Information Concerning the Containment Divider Barrier SealLicense Amendment Request (TAC Nos. MF3052 and MF3053),"

dated May 15, 2014, ADAMSAccession No. ML14127A470.

This letter provides Indiana Michigan Power Company's (I&M), licensee for Donald C. Cook NuclearPlant Units 1 and 2, response to Requests for Additional Information (RAI) by the U. S. NuclearRegulatory Commission (NRC) regarding a license amendment request regarding the containment divider barrier seal.By Reference 1, I&M submitted a request to amend the Technical Specifications (TS) to FacilityOperating Licenses DPR-58 and DPR-74. I&M proposes to change TS 3.6.13, Divider BarrierIntegrity, Surveillance Requirement 3.6.13.5 for the divider barrier seal inspection.

By Reference 2,the NRC transmitted RAIs regarding the proposed amendment.

This letter provides I&M's responseto Reference 2.Enclosure 1 to this letter provides an affirmation statement.

Enclosure 2 to this letter providesI&M's response to the NRC's RAIs.

U. S. Nuclear Regulatory Commission AEP-NRC-2014-31 Page 2Copies of this letter and its enclosures are being transmitted to the Michigan Public ServiceCommission and Michigan Department of Environmental

Quality, in accordance with therequirements of 10 CFR 50.91. There are no new regulatory commitments associated with thisresponse.

Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely, Joel P. GebbieSite Vice President JMT/amp

Enclosures:

1. Affirmation

2. Response to Request for Additional Information Regarding Containment Divider Barrier SealLicense Amendment Requestc: J. T. King, MPSCMDEQ -RMD/RPSNRC Resident Inspector C. D. Pederson, NRC Region IIIT. J. Wengert, NRC Washington, D.C.A. J. Williamson, AEP Ft. Wayne, w/o attachments Enclosure I to AEP-NRC-2014-31 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana MichiganPower Company (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan Power CompanyJoel P. GebbieSite Vice President SWORN TO AND SUBSCRIBED BEFORE METHIS DAYFOF 2014NotanE p ublic '" -My Cornmission Expires '-,- _-,, _DANIELLE BURGOYNENotary Public, State of MichiganCounty of BerrienMY Commission Expires o -04.2018.

Acting ,n the. County o;f Enclosure 2 to AEP-NRC-2014-31 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION REGARDING CONTAINMENT DIVIDER SEAL LICENSE AMENDMENT REQUESTBy letter dated November 6, 2013 (Agencywide Documents Access and Management System(ADAMS) Accession Number ML13312A006),

Indiana Michigan Power Company (I&M), thelicensee for Donald C. Cook Nuclear Plant (CNP) Unit 1 and Unit 2, submitted a request toamend the Technical Specifications (TS) to Facility Operating Licenses DPR-58 and DPR-74.I&M proposes to change TS 3.6.13, Divider Barrier Integrity, Surveillance Requirement (SR) 3.6.13.5 for the divider barrier seal inspection.

The U. S. Nuclear Regulatory Commission (NRC) staff has reviewed the submittal and requests the following information to complete itsreview.Containment and Ventilation Systems Branch (SCVB)SCVB Request for Additional Information (RAI)-1Please describe the diaphragm floor joint components that the term "connections" would bereferring to as distinguished from just "bolts."

Please identify the plant procedure or document inwhich this list/description would be included.

Response to SCVB RAI-1The connections currently holding the divider barrier seal in place include bolts, screws, weldedstuds, nuts, welds, and concrete anchors.

The controlled design drawings that show theseconnections include but are not limited to 1-2-3207E, 1-2-3207F, and 1-AEQS-226-A.

SCVB RAI-2Please describe the procedural guidance used to determine proper! acceptable installation ofthese connections.

Response to SCVB RAI-2Procedures for performing the divider barrier seal surveillance contain design configuration criteria for the proper/acceptable installation of these connections.

The criteria specified by thesurveillance procedures include:

bolt spacing, edge distances, number of connections, andtightness.

SCVB RAI-3Please provide the NRC approved methodology used to determine that the acceptance criteriafor the bypass area have been met.Response to SCVB RAI-3In case deficient connections are discovered, then the resulting divider barrier bypass would bedetermined, using an accepted

standard, the American Institute of Steel Construction (AISC)

Enclosure 2 to AEP NRC 2014-31Page 2Manual of Steel Construction, (tables for beam diagrams and formulas),

as referenced inUpdated Final Safety Analysis Report (UFSAR) Chapter 5, or using a simplified method that ismore conservative, to determine the deflections of the as found configurations due to apostulated

blowdown, and these deflections would be used to quantify the bypass area. Thetotal bypass area for that unit is then compared against the Allowable Design Basis BypassArea of seven square feet, per UFSAR 5.3.5.15.4.

The assumed Analysis Value is 35 squarefeet, per UFSAR 14.3.4.1.3.1.1.e.

Technical Specifications Branch (STSB)STSB RAI-1Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3),

"Surveillance requirements" states:Surveillance requirements.

Surveillance requirements are requirements relating to test,calibration, or inspection to assure that the necessary quality of systems andcomponents is maintained, that facility operation will be within safety limits, and that thelimiting conditions for operation

[LCO] will be metSR 3,6.13.5 currently states:Visually inspect > 95% of the divider barrier seal length, and verify:a. Seal and seal mounting bolts are properly installed; andb. Seal material shows no evidence of deterioration due to holes, ruptures, chemical attack, abrasion, radiation damage, or changes in physicalappearance.

The above SR 3.6.13.5.a is proposed to be deleted and replaced with the following:

Proposed Insert for SR 3.6.13.5:

a. Seal and seal mounting connections are installed such that the total dividerbarrier bypass area is maintained within design limits; andSTSB RAI-I(a)

Explain how the proposed SR meets the above 10 CFR 50.36 Surveillance Requirement (test, calibration, or inspection) and does not require an Operability determination or other unspecified analysis to determine if the LCO is met.Response to STSB RAI-1 (a)In case deficient connections are discovered, then the resulting divider barrier bypass would bedetermined, using an accepted

standard, the AISC Manual of Steel Construction, (tables forbeam diagrams and formulas),

as referenced in UFSAR Chapter 5, or using a simplified methodthat is more conservative, to determine the deflections of the as found configurations due to apostulated

blowdown, and these deflections would be used to quantify the bypass area. Thetotal bypass area for that unit is then compared against the Allowable Design Basis BypassArea of seven square feet, per UFSAR 5.3.5.15.4.

The assumed Analysis Value is 35 squarefeet, per UFSAR 14.3.4.1.3.1.1.e.

Therefore, the surveillance is a quantification of overall Enclosure 2 to AEP NRC 2014-31Page 3bypass that is compared against the criteria of the total bypass allowed.

Satisfactory results ofthe surveillance demonstrate operability of the containment divider barrier safety function.

STSB RAI-I(b)What is the bypass area "design limit" and why is it not identified in the proposed SR?(i.e., What are the SR acceptance criteria for "... seal mounting connections are installed suchthat the total divider barrier bypass area is maintained within design limits"?)

Response to STSB RAI-I (b)The Allowable Design Basis Bypass Area is seven square feet, per UFSAR 5.3.5.15.4.

Thisvalue will also be added to the TS Bases for this SR as represented in Enclosures 5 and 6 ofthe initial License Amendment Request dated November 6, 2013 (ADAMS Accession No. ML13312A006).

This will be controlled under the Technical Specifications Bases ControlProgram described in TS 5.5.12.STSB RAI-I(c)What constitutes a "seal mounting connection" and where are they identified or described in theCNP updated safety analysis report (USAR)?Response to STSB RAI- (c)Seal mounting connections currently holding the divider barrier seal in place include bolts,screws, welded studs, nuts, welds, and concrete anchors.

These connections are notspecifically described in the UFSAR but are described on various CNP controlled designdrawings, including but not limited to 1-2-3207E, 1-2-3207F, and 1-AEQS-226-A.