ML18263A154

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2018/09/14 NRR E-mail Capture - D.C. Cook Unit No. 1 - RAI for Leak-Before-Break LAR (EPID L-2018-LLA-0054)
ML18263A154
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 09/14/2018
From: Dietrich A W
Plant Licensing Branch III
To: Levendosky H L
Indiana Michigan Power Co
References
L-2018-LLA-0054
Download: ML18263A154 (3)


Text

REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR APPLICATION OF LEAK-BEFORE-BREAK EVALUATIONS FOR ACCUMULATOR, SAFETY INJECTION, AND RESIDUAL HEAT REMOVAL PIPING DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 DOCKET NO. 50-315 By letter dated March 7, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18072A012), Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) that would allow for the application of leak-before-break (LBB) evaluations for accumulator piping, safety injection (SI) piping, and residual heat removal (RHR) piping at the Donald C. Cook Nuclear Plant (CNP), Unit No. 1. The NRC staff has determined that additional information is necessary in order to complete its review.

Requests for Additional Information (RAIs) 1 through 6 were sent to the licensee on July 19, 2018 (ADAMS Accession No. ML18204A372). RAI 7 is provided below.

RAI 7 The regulatory guidelines in Regulatory Guide 1.45, "Guidance on Monitoring and Responding to Reactor Coolant System Leakage" (ADAMS Accession No. ML073200271) state that "all monitoring systems referenced in the technical specifications should respond to a leakage increase of 1 [gallon per minute (gpm)] (3.8 [liters per minute]) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less."

In its application, the licensee stated, "A CNP leakage detection capability calculation demonstrates the 0.8 gpm leak detection capability is valid for leaks in the Accumulator, RHR, and SI piping. As such, the 0.8 gpm leak detection capability is the basis for LBB evaluation of the Accumulator, RHR, and SI lines with no response time assumed."

The NRC staff considers response time to include both transport response time and detector response time. The application is not clear what is meant by "no response time assumed."

Clarify the assumption of "no response time assumed" in the calculation described above, and its effect on the calculation results and acceptability.