ET 13-0027, Operating Corporation'S First 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

Operating Corporation'S First 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

ML13247A277
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-12-049, ET 13-0027
Download: ML13247A277 (7)

Text

W6LF CREEK 'NUCLEAR OPERATING CORPORATION John P. Broschak Vice President Engineering August 28, 2013 ET 13-0027 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 Mitigation Strategies for Beyond-Design-Basis External Events"

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, August 29, 2012

3) NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)

Implementation Guide," Revision 0, August 2012

4) Letter ET 12-0029, dated October 29, 2012, from J. P. Broschak, WCNOC, to USNRC

5) Letter WO 13-0014, 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 for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 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 develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET 151 mg4

ET 13-0027 Page 2 of 3 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 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2.

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 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 13-0027 Page 3 of 3 STATE OF KANSAS )

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.

Jo0 Broschak IVidresident Engineering SUBSCRIBED and sworn to before me this 2 day of ,2013.

Notary F~blic GAYLE SHEPHEARD1 E Notary Public - State of Kansas My Appt. Expires r) AIC Expiration Date `11,ý40,0 15-

Attachment to ET 13-0027 Page 1 of 4 Wolf Creek Nuclear Operating Corporation's (WCNOC) First Six-Month Status Report for the Implementation of Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" WCNOC 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, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments The following milestones have been completed since the development of the OIP (Reference 1), and are current as of July 31, 2013.

" FLEX Strategy Evaluation - Complete

" Modifications Evaluation - Complete

• Procedures - Pressurized Water Reactor Owners Group (PWROG) issues Nuclear Steam Supply System (NSSS)-specific guidelines - Complete 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 and are subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Italicized text denotes that either a Milestone was updated or was not in the original OIP.

Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date Submit 60-Day Status Report Oct 2012 Complete _

Submit Overall Integrated Plan Feb 2013 Complete Submit 6-Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started FLEX Strategy Evaluation Apr 2013 Complete Walk- Throughs or Demonstrations Sep 2014 Not Started -

Perform Staffing Analysis Dec 2013 On-Going Oct 2014

Attachment to ET 13-0027 Page 2 of 4 Target Revised Milestone Completion Activity Target Date Status Completion Date Modifications:

Modifications Evaluation Apr 2013 Complete N-1 Walkdown Apr 2014 Not Started Design Engineering Jan 2014 On-Going Implementation Outage Feb 2015 As Scheduled FLEX Equipment:

Procure On-Site Equipment Dec 2014 On-Going Develop Strategies with Regional Nov 2013 Started Aug 2014 Response Center (RRC)

Install Off-Site Delivery Station (if Sep 2014 Not Started necessary)

Procedures:

PWROG issues NSSS-specific Jun 2013 Complete guidelines Create Wolf Creek Flex Support Jun 2014 On-Going Aug 2014 Guidelines (FSG)

Create Maintenance Procedures Jul 2014 Not Started Training:

Develop Training Plan Jul 2014 Not Started Training Complete Feb 2015 Not Started Submit Completion Report Mar 2015 Not Started Apr 2015 Changes to Compliance Method While WCNOC has begun to prepare modification packages, at this time there are no finalized changes to the compliance method as documented in the OIP (Reference 1).

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

Attachment to ET 13-0027 Page 3 of 4 Open Items from Overall Integrated Plan The following table provides a summary of the open items documented in the OIP and the status of each item.

Open Item # Overall Integrated Plan Open Item Status Finalize the location of the FLEX Started. The location of the two FLEX storage building. The deployment storage buildings has been selected.

Oi 1 routes, distances, and times provided WCNOC is now working to confirm the in this report are bounded for the deployment routes, distances, and times currently proposed locations but will presented in the OIP bound these be updated as necessary. locations.

Perform containment evaluation, Started. The GOTHIC analysis work is using Generation of Thermal in progress. Once the results of the Hydraulic Information for Containment evaluation are known required actions

[GOTHIC], based on the boundary will be developed.

conditions described in Section 2 of NEI 12-06. Based on the results of this evaluation, required actions to ensure maintenance of containment integrity and required instrument function will be developed.

The current Condensate Storage Started. When WCNOC receives the Tank [CST] and CST pipe chase are updated Ground Motion Response non-seismic. Therefore, WCNOC is Spectrum (GMRS) results a final currently pursuing two options; the decision to harden the existing tank or qualification and hardening of the construct a new tank will be made.

01 3 existing CST, or the construction of a new 670,000 gallon seismically qualified and missile protected CST.

One of these options must be completed before the volume of the CST can be credited.

Modify the Refueling Water Storage Started. When WCNOC receives the Tank [RWST] to protect it from updated GMRS results the modifications tornado missiles or identify a borated required for the RWST will be finalized.

01 4 source that is protected for tornados and can be utilized to provide core cooling when steam generators are not available.

For non-Class 1E instrumentation that Not started.

will be repowered using a temporary 01 5 battery, an analysis will need to be performed to determine battery life and frequency of replacing battery.

Attachment to ET 13-0027 Page 4 of 4 Open Overall Integrated Plan Open Item Item # Status The method for isolating Started. This is still an open item accumulators during Reactor Coolant however, it was confirmed that the 01 6 System [RCS] inventory control has accumulator isolation valves are on a not been finalized, bus that is being re-powered for the primary FLEX strategy.

The method for repowering the SFP Closed. Powering a Spent Fuel Pool 01 7 cooling pumps has not been finalized. (SFP) cooling pump is a Phase 3 action.

The pump will be re-powered by a 4160V generator provided by the RRC.

References

1. WCNOC Letter WO 13-0014, "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," February 28, 2013. ADAMS Accession No. ML13070A026.

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 Mitigation Strategies for Beyond-Design-Basis External Events," March 12, 2012. ADAMS Accession No. ML12054A735.