LIC-16-0009, Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ML16057A060
Person / Time
Site:	Fort Calhoun
Issue date:	02/26/2016
From:	Marik S Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, LIC-16-0009
Download: ML16057A060 (6)

Text

Omaha Public Power District LIC-16-0009 February 26, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Omaha Public Power District's Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

References:

See Page 2 of Enclosure On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was effective immediately and required the Omaha Public Power District (OPPD) to install reliable spent fuel pool (SFP) level instrumentation at Fort Calhoun Station (FCS), Unit No. 1. Specific requirements are described in Attachment 2 of the Order.

Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the Overall Integrated Plan (OIP), which OPPD submitted on February 28, 2013 (Reference 2). In August 2015, OPPD provided the fifth six-month status report (Reference 9) describing progress made in implementing the requirements of the Order; this letter provides the sixth six-month status report.

The OIP (Reference 2) and subsequent six-month status reports (i.e., References 5 through 9) were prepared utilizing NEI guidance (Reference 3) as endorsed with exceptions and clarifications by the NRC in Reference 4. This sixth report provides an update on changes in schedule related to design and installation.

There are no regulatory commitments contained in this letter.

If you should have any questions regarding this report, please contact Mr. Bradley H. Blome at 402-533-7270.

U. S. Nuclear Regulatory Commission LI C-16-0009 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 26, 2016.

Respectfully, Shane M. Marik Site Vice President and CNO SMM/JKG/mle

Enclosure:

Six-Month Status Report for the Implementation of Order EA-12-05 1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager P. J. Bamford , NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector

LI C-16-0009 Enclosure Page 1 Fort Calhoun Station, Unit No. 1 Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction The Omaha Public Power District (OPPD) has developed an Overall Integrated Plan (Reference

2) for Fort Calhoun Station documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI), in response to Reference 1. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the Overall Integrated Plan, and are current as of January 25, 2016.

• Procured the Spent Fuel Pool Instrumentation in July 2013

• Completed Conceptual Design Package in December 2013

• Began Final Design Package in November 2014

• Finalized Final Design Package in August 2015

• Factory Acceptance Test SFPLI in January 2016 3 Milestone Schedule Status This section provides the activity status of each item, and the expected completion date noting any change. The Attachment to this enclosure contains an update to the Milestone Schedule to support the Overall Integrated Plan. The dates are planning dates subject to change as design and implementation details are developed.

The Attachment is formatted to align with the table provided in the Nuclear Energy lnstitute's (NE!) Six-Month Status Report Template and supersedes the initial Milestone Schedule provided in Reference 2 and interim Milestone Schedules provided in References 5, 6, 7, 8, and 9.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

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

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation There are no open items to report at this point in time regarding the Overall Integrated Plan or the Draft Safety Evaluation.

LIC-16-0009 Enclosure Page 2 7 References The following references support the updates to the Overall Integrated Plan described in this submittal.

1. NRG Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012(ML12056A044) (NRC-12-0023)

2. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Fort Calhoun Station Spent Fuel Pool Instrumentation Overall Integrated Plan," dated February 28, 2013, (ML13059A268) (LIC-13-0011)

3. Nuclear Energy Institute (NEI) 12-02, "Industry Guidance for Compliance with NRG Order EA-12-051, to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 2012, (ML12240A307)

4. NRG Interim Staff Guidance, JLD-ISG-2012-03, "Compliance with Order EA-12-051 ,

Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012, (ML12221A339)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 28, 2013, (ML13241A411) (LIC-13-0124)

6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Second Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated February 24, 2014, (ML14055A397) (LIC-14-0023)

7. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Third Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated August 25, 2014(ML14237A574) (LIC-14-0101)

8. Letter from OPPD (Edwin D. Dean) to NRC (Document Control Desk), "Omaha Public Power District's Fourth Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated February 27, 2015(ML15058A738) (LIC-15-0024)

9. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 19, 2015(ML15231A597) (LIC-15-0096)

Attachment:

SFPLI Overall Integrated Implementation Plan Milestone Schedule, Revision 6

LIC-16-0009 Enclosure, Attachment Page 1 Fort Calhoun Station EA-12-051 SFPLI Overall Integrated Implementation Plan Milestone Schedule Revision 6 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in subsequent 6-month status reports.

Revised Target j Activity Target Milestone Completion Date Status Completion I Date I

Submit 60-Day Status Report October 27, 2012 II Complete N/A Submit Overall Integrated Plan February 28, 2013 Complete N/A Submit Six-Month Updates:

Update 1 August 28, 2013 Complete N/A Update 2 February 28, 2014 Complete N/A I

Update 3 August28, 2014 Complete N/A

! Update 4 February 28, 2015 Complete N/A I

! Update 5 August28, 2015 I Complete N/A I

Update 6 February 29, 2016 Complete N/A Update 7 August29, 2016 Not Started N/A Modifications:

t I Conceptual design 402013 Complete N/A I

I Begin detailed design 402014 Complete N/A engineering I

NRC audit Mohr SFPLI system I

202014 Complete N/A I I

~

i Procure SFPLI equipment 302013 Complete I N/A I

Complete and issue SFPLI 302015 Started 102016 modification package Receipt of spent fuel pool (SFP) 102016 Started N/A instruments

LIC-16-0009 Enclosure, Attachment Page 2 Revised f

! Target Activity I Target Milestone Completion Date Status I I

Completion I Date I i i Begin installation, includes 202016 Not Started N/A i I complete functional test of SFP instruments Complete SFPLI installation and 202016 Not Started 302016 put into service, includes SFP instrument operational and training complete

Omaha Public Power District LIC-16-0009 February 26, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Omaha Public Power District's Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

References:

See Page 2 of Enclosure On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was effective immediately and required the Omaha Public Power District (OPPD) to install reliable spent fuel pool (SFP) level instrumentation at Fort Calhoun Station (FCS), Unit No. 1. Specific requirements are described in Attachment 2 of the Order.

Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the Overall Integrated Plan (OIP), which OPPD submitted on February 28, 2013 (Reference 2). In August 2015, OPPD provided the fifth six-month status report (Reference 9) describing progress made in implementing the requirements of the Order; this letter provides the sixth six-month status report.

The OIP (Reference 2) and subsequent six-month status reports (i.e., References 5 through 9) were prepared utilizing NEI guidance (Reference 3) as endorsed with exceptions and clarifications by the NRC in Reference 4. This sixth report provides an update on changes in schedule related to design and installation.

There are no regulatory commitments contained in this letter.

If you should have any questions regarding this report, please contact Mr. Bradley H. Blome at 402-533-7270.

U. S. Nuclear Regulatory Commission LI C-16-0009 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 26, 2016.

Respectfully, Shane M. Marik Site Vice President and CNO SMM/JKG/mle

Enclosure:

Six-Month Status Report for the Implementation of Order EA-12-05 1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager P. J. Bamford , NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector

LI C-16-0009 Enclosure Page 1 Fort Calhoun Station, Unit No. 1 Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction The Omaha Public Power District (OPPD) has developed an Overall Integrated Plan (Reference

2) for Fort Calhoun Station documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI), in response to Reference 1. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the Overall Integrated Plan, and are current as of January 25, 2016.

• Procured the Spent Fuel Pool Instrumentation in July 2013

• Completed Conceptual Design Package in December 2013

• Began Final Design Package in November 2014

• Finalized Final Design Package in August 2015

• Factory Acceptance Test SFPLI in January 2016 3 Milestone Schedule Status This section provides the activity status of each item, and the expected completion date noting any change. The Attachment to this enclosure contains an update to the Milestone Schedule to support the Overall Integrated Plan. The dates are planning dates subject to change as design and implementation details are developed.

The Attachment is formatted to align with the table provided in the Nuclear Energy lnstitute's (NE!) Six-Month Status Report Template and supersedes the initial Milestone Schedule provided in Reference 2 and interim Milestone Schedules provided in References 5, 6, 7, 8, and 9.

4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

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

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation There are no open items to report at this point in time regarding the Overall Integrated Plan or the Draft Safety Evaluation.

LIC-16-0009 Enclosure Page 2 7 References The following references support the updates to the Overall Integrated Plan described in this submittal.

1. NRG Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012(ML12056A044) (NRC-12-0023)

2. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Fort Calhoun Station Spent Fuel Pool Instrumentation Overall Integrated Plan," dated February 28, 2013, (ML13059A268) (LIC-13-0011)

3. Nuclear Energy Institute (NEI) 12-02, "Industry Guidance for Compliance with NRG Order EA-12-051, to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 2012, (ML12240A307)

4. NRG Interim Staff Guidance, JLD-ISG-2012-03, "Compliance with Order EA-12-051 ,

Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012, (ML12221A339)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 28, 2013, (ML13241A411) (LIC-13-0124)

6. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Second Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated February 24, 2014, (ML14055A397) (LIC-14-0023)

7. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Third Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated August 25, 2014(ML14237A574) (LIC-14-0101)

8. Letter from OPPD (Edwin D. Dean) to NRC (Document Control Desk), "Omaha Public Power District's Fourth Six-Month Status Report for the Implementation of Order EA 051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

dated February 27, 2015(ML15058A738) (LIC-15-0024)

9. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 19, 2015(ML15231A597) (LIC-15-0096)

Attachment:

SFPLI Overall Integrated Implementation Plan Milestone Schedule, Revision 6

LIC-16-0009 Enclosure, Attachment Page 1 Fort Calhoun Station EA-12-051 SFPLI Overall Integrated Implementation Plan Milestone Schedule Revision 6 The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in subsequent 6-month status reports.

Revised Target j Activity Target Milestone Completion Date Status Completion I Date I

Submit 60-Day Status Report October 27, 2012 II Complete N/A Submit Overall Integrated Plan February 28, 2013 Complete N/A Submit Six-Month Updates:

Update 1 August 28, 2013 Complete N/A Update 2 February 28, 2014 Complete N/A I

Update 3 August28, 2014 Complete N/A

! Update 4 February 28, 2015 Complete N/A I

! Update 5 August28, 2015 I Complete N/A I

Update 6 February 29, 2016 Complete N/A Update 7 August29, 2016 Not Started N/A Modifications:

t I Conceptual design 402013 Complete N/A I

I Begin detailed design 402014 Complete N/A engineering I

NRC audit Mohr SFPLI system I

202014 Complete N/A I I

~

i Procure SFPLI equipment 302013 Complete I N/A I

Complete and issue SFPLI 302015 Started 102016 modification package Receipt of spent fuel pool (SFP) 102016 Started N/A instruments

LIC-16-0009 Enclosure, Attachment Page 2 Revised f

! Target Activity I Target Milestone Completion Date Status I I

Completion I Date I i i Begin installation, includes 202016 Not Started N/A i I complete functional test of SFP instruments Complete SFPLI installation and 202016 Not Started 302016 put into service, includes SFP instrument operational and training complete