ML14031A114
| ML14031A114 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/29/2014 |
| From: | Gebbie J P Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2014-07 | |
| Download: ML14031A114 (6) | |
Text
INDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPOWER fOne Cook PlaceBridgman, MI 49106A unit ofAmerican Electric Power India naMichigan Power.com January 29, 2014 AEP-NRC-2014-07 10 CFR 50.54(f)Docket Nos.: 50-31550-316U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1& 2RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 2.3, FLOODING WALKDOWNS
References:
- 1. R. J. Pascarelli, U. S. Nuclear Regulatory Commission (NRC), to L. J. Weber,Indiana Michigan Power Company (I&M); "Request for Additional Information Associated With Near-Term Task Force Recommendation 2.3, FloodingWalkdowns;"
dated December 23, 2013 (ML13325A891).
- 2. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk; "180-DayResponse to NRC Request for Information Pursuant to 10 CFR 50.54(f)Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term TaskForce Review of Insights from the Fukushima Dai-ichi Accident;"
datedNovember 26, 2012 (ML12340A442).
Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP)Units 1 and 2, is submitting the response to "Request For Additional Information
[RAI] Associated With Near-Term Task Force Recommendation 2.3, Flooding Walkdowns" (Reference 1). The RAI isbased on the I&M letter, "180-Day Response to NRC Request for Information Pursuant to10 CFR 50.54(f)
Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term TaskForce Review of Insights from the Fukushima Dai-ichi Accident" (Reference 2).Enclosure 2 provides the I&M RAI response for CNP Units 1 and 2.There are no new or revised commitments in this letter. Should you have any questions, pleasecontact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Joel P. GebbieSite Vice President JJV/amp U. S. Nuclear Regulatory Commission AEP-NRC-2014-07 Page 2
Enclosures:
- 1. Affirmation
- 2. Response to "Request for Additional Information Associated With Near-Term Task ForceRecommendation 2.3, Flooding Walkdowns;"
dated December 23, 2013c: J. T. King, MPSCS. M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ -RMD/RPSNRC Resident Inspector C. D. Pederson, NRC Region IIIT. J. Wengert, NRC Washington, DC Enclosure 1 to AEP-NRC-2014-07 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan PowerCompany (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth hereinpertaining to I&M are true and correct to the best of my knowledge, information, and belief.Indiana Michigan Power CompanyJoel P. GebbieSite Vice President SWORN TO AND SUBSCRIBED BEFORE METHIS ___+'_DAY OF .L3Cnup ,2014Notary PublicMy Commission Expires Enclosure 2 TO AEP-NRC-2014-07 Donald C. Cook Nuclear Plant Units 1 and 2Response to "Request for Additional Information Associated With Near-Term Task ForceRecommendation 2.3, Flooding Walkdowns;"
dated December 23, 2013Please provide the following:
- 1. Confirmation that the process for evaluating APM was reviewed; Request for Additional Information (RAI) 1 Response:
Indiana Michigan Power has reviewed the process for evaluating available physical margin(APM). Donald C. Cook Nuclear Plant Flooding Walkdown Reports (MD-12-FLOOD-001-S and MD-12-FLOOD-002-S) contain the information described in this RAI regarding theevaluation, determination, and documentation of APM.2. Confirmation that the APM process is now or was always consistent with the guidance inNEI 12-07 and discussed in this RAI;RAI 2 Response:
A flooding walkdown feature list was developed for the performance of the walkdown process.Pre-established small-margin threshold values for the flooding protection features were notdefined and/or documented in the Flooding Walkdown Reports.
The APM for a portion of theflooding protection features were numerically determined by measurement similar to ApproachA. For the flooding protection features where the APM was not numerically determined, thebasis of the "not small" determination does not contain the level of detail described inApproach B. Flooding protection features that were judged to have a small APM were enteredinto the corrective action program (CAP) for evaluation.
The APM process was not consistent with the detailed steps described within the RAI.Although the intent of the flooding walkdown process was met, the level of detail in thewalkdown reports does not support an independent verification of the expected implementation of the process as described in the RAI. Additional evaluation and documentation of APMdeterminations will be performed as described in RAI 4 Response below.3. If changes are necessary, a general description of any process changes to establish thisconsistency; RAI 3 Response:
Additional evaluation and documentation of APM determinations will be performed asdescribed in RAI 4 Response below.
Enclosure 2 to AEP-NRC-2014-07 Page 24. As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, floodgates, etc.) was challenging for some licensees.
Generally, licensees were expected to useeither Approach A orApproach B (described below) to determine the APM for seals:a) If seal pressure ratings were known, the seal ratings were used to determine APM(similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM wasdocumented.
No further action was performed if the APM value was greater than thepre-established small-margin threshold value. If the APM value was small, anassessment of "significant consequences" was performed and the guidance in NEI12-07 Section 5.8 was followed.
b) If the seal pressure rating was not known, the APM for seals in a flood barrier isassumed to be greater than the pre-established small-margin threshold value if thefollowing conditions were met: (1) the APM for the barrier in which the seal islocated is greater than the small-margin threshold value and there is evidence thatthe seals were designed/procured, installed, and controlled as flooding seals inaccordance with the flooding licensing basis. Note that in order to determine thatthe seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control processsince installation.
In this case, the APM for the seal could have been documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part of theinitial walkdowns or as part of actions taken in response to this RAI. No additional actions arenecessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as part ofthe walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry tocapture this issue for multiple seals). CAP disposition of "undetermined" APM values forseals should consider the guidance provided in NEI 12-07, Section 5.8. The CAPdisposition should confirm all seals can perform their intended safety function againstfloods up to the current licensing basis flood height. Disposition may occur as part of theIntegrated Assessment.
If an Integrated Assessment is not performed, determine whetherthere are significant consequences associated with exceeding the capacity of the seals andtake interim action(s),
if necessary, via the CAP processes.
These actions do not need tobe complete prior to the RAI response.
Report the APM as "undetermined" and provide the CAP reference in the RAI response.
RAI 4 Response:
Neither Approach A nor Approach B as described in the RAI was fully implemented during theflooding walkdowns to determine APM for all flood protection
- features, including seals.Portions of Approach A and Approach B were implemented for individual flood protection features during the flooding walkdown process.
Additional actions to implement Approach A orApproach B were not performed during the preparation of this RAI response.
Enclosure 2 to AEP-NRC-2014-07 Page 3CAP Action Request 2014-0120 has been generated to disposition and document the"undetermined" APM values using the clarifications provided in the RAI and directdocumentation of the results in the Flood Hazard Reevaluation Integrated Assessment.