AEP-NRC-2014-17, Second Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

Second Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.

ML14063A042
Person / Time
Site:	Cook
Issue date:	02/27/2014
From:	Gebbie J American Electric Power, Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2014-17, EA-12-049
Download: ML14063A042 (12)

Text

INDIANA Indiana Michigan Power MICHIGAN Cook Nuclear Plant PO'IWER6 One Cook Place Bridgman, MI 49106 A unit of American Electric Power Indiana Michiga nPower.com February 27, 2014 AEP-NRC-2014-17 10 CFR 50.54(f)

Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 Second Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. Letter from E. J. Leeds and M. R. Johnson, U. S. Nuclear Regulatory Commission (NRC), to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

dated March 12,

2012, ADAMS Accession'No. ML12054A736.

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External

Events, Revision 0,

dated August 29,

2012, ADAMS Accession No. ML12229A174.

3. Nuclear Energy Institute 12-06, Diverse and Flexible Coping Strategies Implementation Guide, Revision 0, dated August 2012, ADAMS Accession No. ML12242A378.

4. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to NRC, "Donald C. Cook Nuclear Plant, Units 1 and 2, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated October 26, 2012, ADAMS Accession No. ML12312A473.

5. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 27,

2013, ADAMS Accession No. ML13101A381.

U. S. Nuclear Regulatory Commission AEP-NRC-2014-17 Page 2

6. Letter from J. P. Gebbie, I&M, to NRC, "Donald C. Cook Nuclear Plant, Unit 1 and Unit 2, First Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated August 26, 2013, ADAMS Accession No. ML13240A308.

7. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant, Units 1 And 2 - Interim Staff Evaluation Relating To Overall Integrated Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0766 AND MF0767)," dated January 24, 2014, ADAMS Accession No. ML13337A325.

On March 12, 2012, the U. S. Nuclear Regulatory Commission issued Order EA-12-049 (Reference 1) to Indiana Michigan Power Company (I&M), the licensee for the Donald C. Cook Nuclear Plant (CNP) Units 1 and 2. Reference 1 was immediately effective and directed I&M to develop, implement, and maintain guidance and strategies to restore or maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements were outlined in Attachment 2 of the enclosure of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified.

Reference 4 provided the CNP initial status report regarding mitigation strategies. Reference 5 provided the CNP OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP.

Reference 3 provides direction regarding the content of the status reports.

Reference 6 provided the first six-month status report. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, delineating progress made in implementing the requirements of Reference 1. Enclosure 1 to this letter provides an affirmation. Enclosure 2 to this letter provides the second six-month update for the implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation of Strategies for Beyond-Design-Basis External Events," including an update of milestone accomplishments since the initial status report.

There have been no changes to the compliance method as documented in the Interim Staff Evaluation (ISE) (Reference 7); however, some specific methods of implementation have changed.

These changes have resulted in changes to the OIP Open Item list (Enclosure 2). Updated general descriptions of the coping strategies, including station modifications, are posted on the ePortal.

Note: One compliance method change from the OIP was previously reported in Reference 6, prior to issuance of the ISE, and will not be repeated here. There is no change to the final implementation schedule, or need for relief at this time.

U. S. Nuclear Regulatory Commission Page 3 AEP-NRC-2014-17 This letter contains no new or revised regulatory commitments. Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.

Sincerely, Joel P. Gebbie Site Vice President JJV/amp

Enclosures:

1. Affirmation

2. Indiana Michigan Power Implementation of Order Requirements for Mitigation Company's Second Six-Month Status EA-12-049, Order Modifying Licenses Strategies for Beyond-Design-Basis External Report for the with Regard to Events c:

J.T. King, MPSC J. A. Kratchman, NRR/JLD/PMB, NRC S. M. Krawec, AEP Ft. Wayne, w/o enclosure E. J. Leeds, NRR, NRC MDEQ - RMD/RPS NRC Resident Inspector C. D. Pederson, NRC Region III T. J. Wengert, NRC Washington, DC to AEP-NRC-2014-17 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the U. S. Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS."I DAY OF o-, C',

2014

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N~~tary~DANIELLEph BRON Notary Public, Sttre of NE My Corn tY"ofer*ino4 l*h.go Nota jýblic Actin Msso "tPires 0442 My Commission Expires to AEP-NRC-2014-17 Indiana Michigan Power Company's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant (CNP),

developed an Overall Integrated Plan (OIP) (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2.

This attachment provides an update of milestone accomplishments since submittal of the OIP. Although there have been no changes to the compliance method as documented in the Interim Staff Evaluation (ISE) (Reference 3),

some specific methods of implementation have changed. Updated general descriptions of the coping strategies, including station modifications, are posted on the ePortal. These changes have resulted in changes to "Table 2 - OIP Open Items" below. Changes to existing actions are annotated with "strikeout"; open items numbers 29 and 30 are new. Note: One compliance method change from the overall implementation plan was previously reported in Reference 6, prior to issuance of the ISE, and will not be repeated here. There is no change to the final implementation schedule, or need for relief/relaxation at this time.

2. Milestone Accomplishments Table 1 - Milestone Schedule contains the milestone(s) completed since the development of the OIP (Reference 1), and are current as of January 31, 2014.

3. Milestone Schedule Status The following provides an update to Attachment 2 of the OIP. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Table I - Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60-Day Status Report October 2012 Complete Submit OIP February 2013 Complete Submit Six-Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete with this submittal Update 3 August 2014 Not Started Update 4 February 2015 Not Started to AEP-NRC-2014-17 Page 2 Table 1 - Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Walk-throughs or Demonstrations June 2015 Not Started Perform Staffing Analysis June 2014 Not Started Modifications:

Modifications Evaluation December 2013 Complete Unit 1 Design Engineering June 2014 In Progress Unit 1 Implementation Outage November 2014 Not Started Unit 2 Design Engineering December 2014 In Progress Unit 2 Implementation Outage May 2015 Not Started Storage:

Storage Design Engineering December 2013 In Progress March 2014 Storage Implementation November 2014 In Progress FLEX Equipment:

Procure On-Site Equipment June 2014 In Progress July 2014 Develop Strategies with Regional May 2014 Not Started Response Center Install Off-Site Delivery Station (if November 2014 Not Started Necessary)

Procedures:

Pressurized Water Reactor Owners Group issues nuclear steam system November 2014 In Progress supply-specific guidelines Create Site-Specific FLEX Support September 2014 In Progress Guidelines (FSGs) - Unit 1 Create Site-Specific FSGs - Unit 2 September 2014 In Progress February 2015 Create Maintenance Procedures August 2014 Not Started Training:

Develop Training Plan March 2014 In Progress Training Complete September 2014 Not Started Unit 1 FLEX Implementation November 2014 In Progress Unit 2 FLEX Implementation April 2015 Not Started to AEP-NRC-2014-17 Page 3 Table 1 - Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Full Site FLEX Implementation April 2015 Not Started Submit Completion Report August 2015 Not Started

4. Changes to Compliance Method Although there have been no changes to the compliance method as documented in the ISE (Reference 3), some specific methods of implementation have changed.

Updated general descriptions of the coping strategies, including station modifications, are posted on the ePortal.

These changes have resulted in changes to "Table 2 - OIP Open Items" below. Changes to existing actions are annotated with "strikeout"; open items numbers 29 and 30 are new.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation I&M expects to comply with the order implementation date and no relief/relaxation is required at this time.

6. Open Items from OIP and Draft Safety Evaluation The following tables provide a summary of the open items documented in the OIP or the Draft Safety Evaluation (SE) and the status of each item.

Table 2 - QIP Open Items Pending QIP Open Item Status Action 1

Completion of FLEX equipment storage facilities.

In Progress Perform final validation of timing requirement to route 2

alternate suction source to Turbine Driven Auxiliary Feed Not Started Water (TDAFW) pump.

3 Implement administrative controls program for FLEX Not Started related equipment.

A systematic approach to training will be used to evaluate training requirements for station personnel 4

based upon changes to plant equipment, implementation In Progress of FLEX portable equipment, and new or revised procedures that result from implementation of the FLEX strategies.

to AEP-NRC-2014-17 Page 4 Table 2 - 0IP Open Items Pending OIP Open Item Status Action Complete detailed load shedding and battery duration analysis of Train A and Train B 250 Volt (V) direct current batteries to validate final FLEX implementation strategy, including required procedure changes.

Modification to TDAFW pump suction piping from Essential Service Water (ESW) system to provide connection point from the discharge of the fire water In Progress pumps.

Complete detailed load shedding and battery duration analysis of N-Train battery to validate final FLEX implementation strategy, including required procedure changes.

Develop FSGs and associated procedure revisions to In Progress implement FLEX mitigation strategies.

Modify the fire protection header inside the Turbine Building to provide an adequately sized connection to enable transfer of water to Auxiliary Feedwater (AFW) pump suction.

Perm-anent nitrogen bottle racks will be installed near-each SG PORV operating ÷tation with hose and regulators to align for contirol to reimain. apuailable iin the GGtrn-l rO-,-p m,

10 In Progress Permanent nitrogen bottle racks will be installed near each steam generator power operated relief valve operating station with hose and regulators to align for local manual control.

Modification to connect po-rtable'P diesel generator to 600 Vac-bus lIB1 [ 110] and 21B [210D].

11 In Progress Modification to connect portable diesel generator (DG) to 600 Vac bus 11D and 21D.

Modifictio to cnnect porFtable diese~l generator to G-RP-3 12 Modification to connect one 6 kW portable DG to each In Progress control room instrumentation distribution 120 V Instrument Distribution Panel.

Modification to connect portable DG to motor control 13 center (MCC) ABD-B to provide alternate power supply In Progress to N-Train battery charger.

to AEP-NRC-2014-17 Page 5 Table 2 - 0IP Open Items Pending OIP Open Item Status Action hMAo diwfica;;tio en fon-r hoese.o n n ecr-tion onf allI ma in F ee d-. Wa terF line flow nozzle in.pection port flanges located near B.5i.b connection.

14 In Progress Modification to place a new hose connection in the motor driven AFW discharge line in the east main steam stop enclosure.

4160 ac1 bus T1 Al'D (T/2T"D) will be mo*dified, to a*l*w connecfion of external ' 4160Vac three phase portable dieelgenerater.

15 In Progress 4160 V alternating current (AC) bus 1A (2A) will be modified to allow connection of external 4160 VAC three-phase portable DG.

Replace Reactor Coolant Pump (RCP) seals with 16 Westinghouse SHIELD low leakage seals. On Hold pending reevaluation of Generation 3 SHIELD design.

M*d*ific-nation adding connnetionn point fo portable electric pump to the safety related 6-0 Vac-buses (e.g., 11 B and lI D (21 B and 210D)) for the portable boron addition 17 pumP.

In Progress Modification adding a portable boron addition pump powered by a dedicated portable DG.

Modify mon.t*r tankr ins*tllinRg temprrary hose 18 PQAAAA-t0Q.s in P-rogress N/A Modification and strategy not required.

A transfer sw6itNh Will be installpd in the feed-e-r rae hehAVen 60-0 NVa s 1 0 and MCvC, A.B to pvde power to CVCS holdup tank reci rc-u lation pump to 19 faciitate wa;-ter transfers.

In Progress Modification to provide power to middle boric acid evaporator feed pump.

Perform containment analysis to validate that 20 containment integrity can be maintained until In Progress containment cooling can be restored during Phase 3.

to AEP-NRC-2014-17 Page 6 Table 2 - 0IP Open Items Pending QIP Open Item Status Action Modify Chemical and V olumne Control System (CVCS) cross r.tie to alowcn-nect~pnion of portable boron addition 21 Modify Chemical and Volume Control System In Progress reciprocating positive displacement pump discharge flange connection to allow connection of portable boron addition pump.

Modify the fire test header inside the Fire Pump House to allowey~

for th e ho -s e co nnnec Gt io)n.

22 In Progress Strategy changed to use existing hose connections on fire test header at the Fire Pump House.

Modify the bo-ric acid-transfer pump suction header to add-a bhra;;ncrh connection with quick dis~connect fitting-.

23 In Progress Modify boric acid transfer pump (BATP) suction header to add connection points.

Modify the boricu acidd transfer pump discharge header to add a; branch connection wihquick disconnect fittings-.InPors 24 In Progress Modify BATP discharge header to add connection points.

Install st-and-pipe from the 609 ft. elevation in the Auxilir Building crane bay just inside the perSOnnel door near the roll up door through a stairwell to the overhead of the 25 587 ft. eleVation to a location near theP harging pump

-PFrgeGG r-eem-entries.

N/A Modification not required. Strategy revised to use hose connections.

Fuel consumption will be finalized when equipment has Not Stapted been procured and tested.

In Progress Perform calculation to verify time required to establish 27 flow to the Reactor Coolant System (RCS) in MODE 6 In Progress with the Reactor Cavity filled.

Modify vent connection doýn Astrea of the boron ijcintanks for portable PUMP connection.

28 Th-P*egress Modification not required. Strategy changed to use N/A existing Safety Injection Pumps discharge header vents and drains.

to AEP-NRC-2014-17 Page 7 Table 2 - QIP Open Items Pending OIP Open Item Status Action Fabricate a tool to provide large volume Phase 3 raw water tie-in to ESW supporting component cooling water 29 cooling for residual heat remover (RHR).

In Progress Note: New scope to address Phase 3 restoration of RHR.

Modify 600 VAC MCC circuit breakers to provide Phase 2 electrical power connections to close safety injection (SI) accumulator discharge valves.

30 In Progress Note: New scope addresses Phase 2 need to close SI accumulator discharge valves to prevent nitrogen injection from the SI accumulators.

Table 3 - ISE Open Items Draft SE Open Item [ISE (Reference 3)]

Status 3.2.1.8.A - Core Sub-Criticality - Confirm resolution of the generic concern associated with the modeling of the timing and uniformity of Open the mixing of a liquid boric acid solution injected into the RCS under natural circulation conditions potentially involving two-phase flow.

3.2.3.A - Containment Functions Strategies -Verify containment pressure and temperature response based on using conventional Open RCP seals.

3.2.4.7.A - Water Sources-Determine if Lake Township water supply can be used to cope after a tornado event since neither the condensate storage tanks nor the fire water storage tanks are protected against tornado borne missiles. This is an alternate Open approach from the strategies identified in Nuclear Energy Institute 12-06 as it relies on separation distance during a tornado to take credit for a water source. (Significant) 3.2.4.10.B - Battery Duty Cycle - Verify approach used to qualify the Open station batteries duty cycle to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

7. Potential Draft Safety Evaluation Impacts CNP has not yet received a Draft SE; therefore, no potential impacts can be determined.

to AEP-NRC-2014-17 Page 8

8. References The following references support the updates to the OIP described in this attachment.

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, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),"

dated February 27,

2013, ADAMS Accession No. ML13101A381.

2. Letter from E. J. Leeds and M. R. Johnson, (NRC), to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012, ADAMS Accession No. ML12054A736.

3. Letter from J. S. Bowen, NRC, to L. J. Weber, I&M,

Subject:

"Donald C. Cook Nuclear Plant, Units 1 And 2 - Interim Staff Evaluation Relating To Overall Integrated. Plan In Response To Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0766 and MF0767),"

dated January 24, 2014.