ET 13-0026, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

ML13252A238
Person / Time
Site:	Wolf Creek
Issue date:	08/28/2013
From:	Broschak J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ET 13-0026
Download: ML13252A238 (8)

Text

WNLLF CREEK 'NUCLEAR OPERATING CORPORATION John P. Broschak Vice President Engineering August 28, 2013 ET 13-0026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1) Letter dated March 12, 2012, from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation"

2) NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation,"

Revision 0, dated August 29, 2012

3) NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"," Revision 1, dated August 2012

4) Letter ET 12-0028, dated October 29, 2012, from J. P. Broschak, WCNOC, to USNRC

5) Letter WO 13-0015, dated February 28, 2013, from R. A. Smith, WCNOC, to USNRC

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC, Commission) issued an order (Reference 1) to Wolf Creek Nuclear Operating Corporation (WCNOC). Reference 1 was immediately effective and directs WCNOC to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 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 NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 13-0026 Page 2 of 3 Reference 4 provided the WCNOC initial status report regarding mitigation strategies.

Reference 5 provided the WCNOC 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. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the submittal of the OIP, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4085, or Mr. Michael J. Westman at (620) 364-4009.

Sincerely, John P. Broschak JPB/rlt Attachment cc: C. F. Lyon (NRC), w/a N. F. O'Keefe (NRC), w/a S. A. Reynolds (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 13-0026 Page 3 of 3 STATE OF KANSAS

)S COUNTY OF COFFEY John P. Broschak, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Joh-v#. Broschak Vic&President Engineering SUBSCRIBED and sworn to before me this q* day of Avý"ý ,2013.

Notary P blic ublc Ptteof Kansas Ncty

'I['q7 dO16T EXDiration Date I

Attachment to ET 13-0026 Page 1 of 5 Wolf Creek Nuclear Operating Corporation's First Six-Month Status Report for the Implementation of Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation" Wolf Creek Nuclear Operating Corporation (WCNOC) developed an Overall Integrated Plan (OIP) (Reference 1), documenting the modification with regard to Reliable Spent Fuel Pool (SFP) Instrumentation in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments WCNOC has selected and entered into a purchase agreement to procure SFP level instruments that, when installed, will meet criteria designated in the OIP (Reference 1).

Milestone Schedule Status There are no changes to the status of the milestones submitted in the OIP (Reference 1).

Provided is the activity status of each item, and whether the expected completion date has changed. The dates are planning dates and are subject to change as design and implementation details are developed.

Target Revised Milestone Completion Activity Target Dtet Status Completion Date Date Commence Engineering and Design 1Q2013 Complete -

Complete Design 4Q2013 In -

Progress Submit 6 Month Updates:

Update 1 Aug 2013 Complete -

Not Update 2 Feb 2014 Started -

Not Update 3 Aug 2014 Stae Started Not Update 4 Feb 2015 Stat Started Not Receipt of SFP Instruments 3Q2014 Stae Started Complete SFP Instrumentation Procedures & 4Q2014 Not Training Started Not SFP Instruments Operational 1Q2015 Stat Started

ET 13-0026 Page 2 of 5 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

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

Open Request for Additional Information (RAI)

The table below lists the open RAI and the responses from Reference 4 requiring additional information in the February 2014 status update. Italicized text denotes that the RAI response requires further activities.

RAI # Open Request for Additional Response Information RAI-6 Please provide the following: Responses provided in Reference 4:

a) A description of the electrical AC a) A description of the electricalAC power power sources and capacities for sources and capacities for the primary the primary and backup channels, and backup channels will be developed demonstrating that the loss of one as part of the detailed design and more normal AC power supply will not information will be provided in the 6-affect both channels of level month status update in February 2014.

instrumentation. b) Battery sizing is in accordance with b) Since both channels will be powered IEEE 485-2010. Design criteria applied by independent batteries following a are: continuous system operation for 72 loss of AC power, please provide hours following loss of AC power.

the design criteria that will be Calculation of system power applied to size the battery in a consumption is based on the specified manner that ensures, with margin, values listed in component that the channel will be available to manufacturer specifications. A 10%

run reliably and continuously capacity margin is added to battery following the onset of the BDB sizing calculations, following guidelines

[Beyond-Design-Basis] event for the of IEEE 485-2010, Section 6.2.2. The minimum duration needed, time to restore AC power to the primary consistent with the plant mitigation and backup channels will be within 72 strategies for BDB external events hours, and will be established in the (Order EA-12-049). diverse and flexible coping strategies (FLEX) Support Guidelines.

RAI-7 Please provide the following: Responses provided in Reference 4:

a) An estimate of the expected a) The instrument channel accuracy will be instrument channel accuracy established during the design phase.

performance (e.g., in percent of An estimate of the expected instrument span) under both a) normal SFP channel accuracyunder normal and

[Spent Fuel Pool] level conditions BDB conditions will be provided in the 6-(approximately Level 1 or higher) month update in February2014.

ET 13-0026 Page 3 of 5 RAI # Open Request for Additional Response Information Response and b) at the BDB conditions (i.e., b) The calibrationprocedure, and the radiation, temperature, humidity, methodology and basis for establishing post-seismic and post-shock both the criteriaindicating the need for conditions) that would be present if recalibration,and the acceptance the SFP level were at the Level 2 criterion to be used with the procedure, and Level 3 datum points, will be established during the design b) A description of the methodology phase. The methodology for defining that will be used for determining the these criteria will be provided in the 6-maximum allowed deviation from the month status update in February2014.

instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

RAI-8 I Please provide the following: Responses provided in Reference 4:

a) A description of the capability and a) Details of the capabilitiesand provisions provisions the proposed level of the level instrumentationfor periodic sensing equipment will have to calibrationand testing will be enable periodic testing and establishedduring the design phase. A calibration, including how this description of these features and the capability enables the equipment to way they will supportin-situ testing will be tested in-situ. be provided in the 6-month status b) A description of how such testing update in February2014.

and calibration will enable the b) A description of how the defined testing conduct of regular channel checks and calibrationwill enable the conduct of each independent channel of regularchannel checks of each against the other, and against any independent channel against the other, other permanently installed SFP and against any other permanently-level instrumentation. installed SFP level instrumentationwill c) A description of how calibration tests be provided in the 6-month status and functional checks will be update in February 2014.

performed and the frequency at c) Details of functional checks and which they will be conducted. instrument channel calibrationswill be Please discuss how these determined during the design phase. A surveillances will be incorporated descriptionof how functional checks into the plant surveillance program. and calibrationtests will be performed, d) A description what preventative and the frequency at which they will be maintenance tasks are required to conducted, will be provided in the 6-be performed during normal month status update in February2014.

operation, and the planned An explanation of how these maximum surveillance interval that surveillances will be incorporatedinto is necessary to ensure that the the plant surveillance program will be channels are fully conditioned to included.

accurately and reliably perform their d) The preventative maintenance tasks

ET 13-0026 Page 4 of 5 RAI # Open Request for Additional Response Information Response functions when needed, required to be performed during normal operation, and the planned surveillance intervals will be determined during the design phase. A description of these tasks and intervals will be provided in the 6-month status update in February 2014.

RAI-1I Please provide the following: Responses provided in Reference 4:

a) Further information describing the a) Appropriate quality assurancemeasures maintenance and testing program will be applied to the SFPIS [Spent Fuel the licensee will establish and Pool Instrumentation System],

implement to ensure that regular consistent with NEI 12-02, Appendix A-testing and calibration is performed 1, which includes criteria for and verified by inspection and audit procedures,test control, corrective to demonstrate conformance with actions and audit functions. WCNOC design and system readiness will establish and implement procedures requirements. Please include a for control and scheduling for SFPIS description of the licensee's plans maintenance and testing. The new for ensuring that necessary channel procedure(s)will include requirements checks, functional tests, periodic for the necessarytests to be performed, calibration, and maintenance will be frequency of testing and, acceptance conducted for the level criteria. As these procedures are measurement system and its developed, information will be provided supporting equipment. to the NRC in the 6-month status b) A description of how the guidance in update in February2014.

NEI 12-02 Section 4.3 regarding b) WCNOC will implement measures to compensatory actions for one or minimize the possibility of either the both non-functioning channels will primary or backup channel being out of be addressed. service for any extended period.

c) A description of the compensatory Sufficient spare components and actions to be taken in the event that materials will be maintained to enable one of the instrument channels timely repair or replacement of defective cannot be restored to functional components. WCNOC will follow the status within 90 days. NEI 12-02 guidance with regard to the time during which one or more channels may be out of service.

c) If a channel is non-functional, a corrective action document will be initiated and actions taken to correct the deficiency within 90 days as described in NEI 12-02. The technology selected for level instrumentation is easily replaceable, as components are passive and modular. Sufficient spares will be available on-site and the vendor can supply parts in a timely manner.

ET 13-0026 Page 5 of 5 References

1. WCNOC Letter WO 13-0015, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements For Reliable Spent Fuel Pool Instrumentation," February 28, 2013. ADAMS Accession No. ML13071A419.

2. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," March 12, 2012. ADAMS Accession No. ML12056A044.

3. Letter from C. F. Lyon, USNRC to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation' (TAC NO. MF0781)" July 17, 2013. ADAMS Accession No. ML13197A205.

4. WCNOC Letter ET 13-0025, "Wolf Creek Nuclear Operating Corporation's Response to Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation," August 15, 2013.