ML19067A048

Summary of Public Teleconference with Indiana Michigan Power Co. (I&M) Review of LAR for Approval of Leak-Before-Break Methodology for Reactor Coolant System Small Diameter Piping (EPID-2019-LLA-0054)

ML19067A048
Person / Time
Site:	Cook
Issue date:	03/12/2019
From:	Haskell R Plant Licensing Branch III
To:	Gebbie J Indiana Michigan Power Co
Haskell R 415-1129
References
EPID-2019-LLA-0054
Download: ML19067A048 (4)

Text

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,, ****i' March 12, 2019 LICENSEE: INDIANA MICHIGAN POWER COMPANY FACILITY: DONALD C. COOK NUCLEAR PLANT, UNIT 1

SUMMARY

OF FEBRUARY 27, 2019, PUBLIC TELECONFERENCE WITH INDIANA MICHIGAN POWER COMPANY (l&M) REGARDING REVIEW OF LICENSE AMENDMENT REQUEST FOR APPROVAL OF LEAK-BEFORE-BREAK METHODOLOGY FOR REACTOR COOLANT SYSTEM SMALL DIAMETER PIPING (EPID-2019-LLA-0054)

On February 27, 2019, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Indiana Michigan Power Company (l&M, the licensee). The teleconference was held at the NRC Headquarters located in Rockville, Maryland. The purpose of the teleconference was to discuss the licensee's proposed license amendment request (LAR) to apply leak-before-break (LBB) methods to certain reactor coolant system (RCS) small diameter branch lines at the Donald C. Cook Nuclear Plant (CNP), Unit 1.

Specifically, the NRC staff requested the licensee to clarify its proposed LBB approach under NUREG-0800, Standard Review Plan (SRP), Section 3.6.31 , by means of Westinghouse LBB methods. The LAR under review, dated March 7, 2018, is available in the NRC's Agencywide Documents Access and Management System (ADAMS) (Accession No. ML18072A012).

SRP 3.6.3 states, in part, that specific areas of review for the NRC staff to consider during performance of an LBB evaluation include, (1) deterministic fracture mechanics, and (2) leak rate evaluation. Regarding the fracture mechanics analysis, the NRC staff informed the licensee that the LAR provided sufficient information for the staff to make a safety determination. Regarding the leak rate evaluation, the NRC staff informed the licensee that additional information was needed. Specifically, the LAR requests NRC approval for LBB on all accumulator, safety injection (SI), and residual heat removal (RHR), piping segments.

Since portions of these piping segments are downstream of check valves, the staff stated it has questions related to RCS leakage detection guidance (i.e., SRP 3.6.3 and Regulatory Guide 1.452 ). The NRC staff and the licensee discussed the following regulatory guidance:

SRP 3.6.3,Section II, "Acceptance Criteria," states, in part:

LBB should only be applied to high energy, ASME Code Class 1 or 2 piping or the equivalent. Applications to other high energy piping will be considered based on an evaluation of the proposed design and in-service inspection requirements as compared to ASME Code Class 1 and 2 requirements.

1 NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," SRP 3.6.3, Revision 1, "Leak-Before-Break Evaluation Procedures," ADAMS Accession No. ML063600396, dated March 2007.

2 Regulatory Guide 1.45, Revision 1, "Guidance on Monitoring and Responding to Reactor Coolant System Leakage,"

ADAMS Accession No. ML0732002701, dated June 2007.

In response, the licensee stated that portions the proposed accumulator, SI, and RHR piping segments (under review) are considered to be moderate energy piping systems (vs. high energy),

and therefore an LBB analysis is not required, for those segments. Furthermore, the licensee stated that the portions of the moderate energy piping segments were not necessary for the evaluation of LBB to proceed. The NRC staff acknowledged this new information from the licensee and suggested for the LAR to be revised. The licensee concurred, and proposed a revision to the LAR which will reflect excluding portions of the accumulator, SI, and RHR piping segments, not meeting the LBB acceptance criteria, as stated above.

The staff informed the licensee that previously distributed RAl-8 and RAl-9 requests 3 would be altered to reflect the new information that had developed during the teleconference. The staff's revised RAls will request information to support the RCS leakage detection portion of the evaluation (i.e., sensitivity analysis, detector calculations, proximity of detector, detector redundancy, etc.). The revised RAls will also request the licensee to verify that the CNP, Unit 1 LBB analysis includes RCS activity related to current nuclear fuel performance.

All feedback or comments expressed by the NRC staff during the meeting does not establish a regulatory position or constitute the acceptability of methodologies or changes discussed. One member of the public was identified on the teleconference. No public meeting feedback forms or comments have been received by the NRC staff.

Please direct any inquiries to me at 301-415-1129 or Russell.Haskell@nrc.gov.

Russell Haskell II, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-315

Enclosure:

List of Attendees cc: Listserv 3 ADAMS Accession No. ML19011A351, dated January 11, 2019.

LIST OF ATTENDEES FEBRUARY 27, 2019, PUBLIC TELECONFERENCE WITH INDIANA MICHIGAN POWER CO.

Name Affiliation Shaun Anderson U.S. Nuclear Regulatory Commission (NRC)

David Wrona NRC Russell Haskell NRC David Nold NRC John Tsao NRC Steve Jones NRC Garry Steven NRC Seung Min NRC Ravinder Grover NRC Khadijah West NRC Gerard Purciarello NRC Raymond Ng NRC John Ellegood NRC Eric Duncan NRC Jeffrey Poehler NRC Jay Wallace NRC Robert Tregoning NRC Patrick Ravnaud NRC Dan Widrevitz NRC Jud Winkler Indian Michigan Power Company (l&M)

Jeff Hudson l&M Ben Horner l&M Greg Hill l&M Michael Scarpello l&M Helen Levendosky l&M Joe Tanko l&M Doug Badgero l&M Eric Johnson l&M Dave Dolby l&M Sara Weindorf Westinahouse Todd Trygier State of Michi!::ian (Dept. of Environmental Quality)

Enclosure

ML19067A048 OFFICE NRR/D0RL/LPL3/PM NRR/D0RL/LPL3/LA NRR/D0RL/LPL3/BC NRR/D0RL/LPL3/PM NAME RHaskell SRohrer DWrona RHaskell DATE 3/7/19 3/7/19 3/12/19 3/12/19