ML15181A256

Donald C. Cook Nuclear Plant Unit 1 and Unit 2 - Commitment Schedule Change Related to Technical Specification Task Force-523

ML15181A256
Person / Time
Site:	Cook
Issue date:	06/24/2015
From:	Gebbie J P Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2015-37
Download: ML15181A256 (4)

Text

INDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantPOIWER One Cook PlaceBridgman, MI 49106A unit ofAmerican Electric Power IndianaMichiganPower.comJune 24, 2015 AEP-NRC-2015-3710 CFR 50.4Docket Nos. 50-31550-316U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Donald C. Cook Nuclear Plant Unit 1 and Unit 2COMMITMENT SCHEDULE CHANGE RELATED TOTECHNICAL SPECIFICATION TASK FORCE-523

References:

1. U. S. Nuclear Regulatory Commission (NRC) Generic Letter 2008-01, Managing GasAccumulation in Emergency Core Cooling, Decay Heat Removal, and Containment SpraySystems, dated January 11, 2008, Agencywide Documents Access and Management System(ADAMS) Accession No. ML072910759.2. Letter from L. J. Weber, Indiana Michigan Power Company (A&M), to NRC, Nine-MonthResponse to NRC Generic Letter 2008-01 issued pursuant to 10 CFR 50.54(f), "ManagingGas Accumulation in Emergency Core Cooling, Decay Heat Removal, and ContainmentSpray Systems," dated October 14, 2008, ADAMS Accession No. ML082950467.3. Letter from J. P. Gebbie, I&M, to NRC, Evaluation of TSTF-523 "Generic Letter 2008-01,Managing Gas Accumulation," dated March 7, 2014, ADAMS Accession No. ML14070A344.4. NRC Memorandum from J. Holonich to A.J. Mendiola re: Minutes From Aug 19, 2014 Meetingon Gas Voids NEI Version, dated October 1, 2014, ADAMS Accession No. ML14266A168.Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP),Units 1 and 2, is providing notification of a change to a regulatory commitment that was documentedin Reference 3. I&M has revised the completion date to submit a license amendment request (LAR)for technical specification (TS) revisions related to Technical Specification Task Force (TSTF)-523,Generic Letter 2008-01, Managing Gas Accumulation.In Reference 1, the U. S. Nuclear Regulatory Commission (NRC) requested information fromlicensees regarding how they protect certain safety systems from the accumulation of air, nitrogen, orother gases that could cause the systems to become inoperable. The Generic Letter (GL) requested U. S. Nuclear Regulatory Commission AEP-NRC-2015-37Page 2licensees to evaluate their emergency core cooling system (ECCS), residual heat removal (RHR),and containment spray (CTS) systems in order to determine how their licensing basis, design, testing,and corrective actions ensure that gas accumulation is maintained less than the amount thatchallenges operability of these systems, and that appropriate action is taken when conditions adverseto quality are identified.In addition, the NRC requested licensees to provide a statement regarding which corrective actionswere completed, the schedule for completing the remaining corrective actions, and the basis for thatschedule. I&M provided a response to Reference 1 for CNP in Reference 2. Reference 2 containedthe following commitment to provide an evaluation of TSTF-523 within 60 days of NRC approval ofTSTF-523:"Evaluate the TSTF Traveler for gas accumulation to either supplement or replace the currentTS requirements."Notice of Availability for adopting TSTF-523 under the Consolidated Line Item Improvement Processwas provided in 79 FR 2700 on January 15, 2014. I&M satisfied the Reference 2 commitment byletter dated March 7, 2014 (Reference 3), which concluded that additional analysis is required todetermine the actions necessary to ensure the ECCS, RHR, and CTS systems are capable ofperforming their specified safety functions and that these systems are in compliance with theirlicensing basis with respect to the concerns outlined in GL 2008-01. As a result, a new commitmentwas made in Reference 3 related to TSTF-523, as stated below:"Conduct additional technical evaluation of Emergency Core Cooling Systems, ResidualHeat Removal System, and Containment Spray System for gas accumulation. Uponcompletion of the evaluation, submit a license amendment request to adopt the appropriateportions of TSTF-523."The commitment change identified in this letter applies only to extension of the completion date.The commitment wording is unchanged and continues to specify TSTF-523 as the basis of theproposed license amendment.In Reference 3, I&M committed to perform additional analysis of gas accumulation issues at CNPand submit a LAR by June 30, 2015. However, as recognized in the memorandum datedOctober 1, 2014, to Licensing Processes Branch Chief Anthony J. Mendiola (Reference 4), there isuncertainty in the industry regarding the NRC endorsed guidance for implementing TSTF-523(i.e., RIS .2013-09 and NEI 09-10 Revision 1a-A). Concurrently, I&M was evaluating bids fromvarious vendors for performing site-specific analysis of the potentially affected systems. Althoughindustry resolution of the uncertainties detailed in Reference 4 has not occurred, I&M hasdetermined that the necessary analysis should be performed notwithstanding the uncertainties.I&M has recently chosen a vendor to perform the analysis and the schedule for completion of theanalysis would not allow for a June 30, 2015, LAR submittal. Therefore, I&M is submitting this letterto notify the NRC that the commitment to submit a LAR has been extended to January 29, 2016, toallow time for additional analysis to be performed prior to implementing TSTF-523.

U. S. Nuclear Regulatory Commission AEP-NRC-2015-37Page 3This letter contains no new regulatory commitments and one revised regulatory commitment duedate, as summarized in the enclosure to this letter. Should you have any questions, please contactMr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Joel P. GebbieSite Vice PresidentTLC/ams

Enclosure:

Donald C. Cook Nuclear Plant Regulatory Commitmentc: A. W. Dietrich, NRC, Washington, D.C.J. T. King -MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC, Region IIIA. J. Williamson, AEP Ft. Wayne, w/o enclosures Enclosure to AEP-NRC-2015-37Donald C. Cook Nuclear PlantRegulatory CommitmentThe following table identifies the action committed to by Indiana Michigan Power Company forimplementation of Technical Specification Task Force (TSTF)-523 at Donald C. Cook NuclearPlant. Any other actions discussed in this submittal represent intended or planned actions byI&M. They are described to the U. S. Nuclear Regulatory Commission (NRC) for the NRC'sinformation and are not regulatory commitments.Commitment Completion DateConduct additional technical evaluation of Emergency CoreCooling Systems, Residual Heat Removal System, andContainment Spray System for gas accumulation. Upon January 29, 2016completion of the evaluation, submit a license amendmentrequest to adopt the appropriate portions of TSTF-523.