ET 14-0010, Operating Corporation'S Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

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

ML14064A184
Person / Time
Site:	Wolf Creek
Issue date:	02/26/2014
From:	Broschak J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ET 14-0010
Download: ML14064A184 (6)

Text

W$LFCREEK NUCLEAR OPERATING CORPORATION John P. Broschak Vice President Engineering February 26, 2014 ET 14-0010 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 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

6) Letter ET 13-0026, dated August 28, 2013, from J. P. Broschak, WCNOC, to USNRC

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's Second Six-Month Status Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (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.

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

ET 14-0010 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 12-02, Revision 1 (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 6 provided the first six-month status report for the implementation of Order EA-1 2-051.

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 second 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 Reference 6, including any changes to the compliance method, schedule, or need for relief and the basis for requests for relief, 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: M. L. Dapas (NRC), w/a C. F. Lyon (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 14-0010 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.

Jo . Broschak Vi President Engineering SUBSCRIBED and sworn to before me this 2z-V day of re ,2014.

GAYLE SHEPHEARD Notaryaublio Z Notary Public - State of Kansas My Appt. Expires Q A,-.L Expiration Date I

'A/2L/~T/

Attachment ET 14-0010 Page 1 of 3 Wolf Creek Nuclear Operating Corporation's Second 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 first six-month status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

1. 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).

2. 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 Status Target Date Completion Date Commence Engineering and Design 1 Q2013 Complete Complete Design 4Q2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Receipt of SFP Instruments 3Q2014 Not Started Complete SFP Instrumentation Procedures 4Q2014 Not Started

& Training SFP Instruments Operational 1Q2015 Not Started

Attachment ET 14-0010 Page 2 of 3

3. Changes to Compliance Method WCNOC will no longer pursue installation of a wireless spent fuel pool level indication (SFPLI) system and will instead install a wired SFPLI system. The overall operation and layout of the system remains the same however, the level signal is now provided via installed robust cabling to the readout panels.

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

5. Open Request for Additional Information (RAI)

Reference 4 provided WCNOC's responses to an NRC RAI (Reference 3). In Reference 4, WCNOC indicated that additional information would be provided in the February 2014 6-month status update report. Subsequently, the NRC issued the Interim Staff Evaluation (Reference 6) which was based, in part, on information provided in References 4 and 5. As noted in Reference 6, new RAI questions were developed based on the information provided in References 4 and 5. Reference 6 indicated that responses to the RAI questions should be provided in the 6-month status updates, as the information becomes available. WCNOC is still developing the information for responding to the RAI questions identified in Reference 6 and will provide the information no later than the requested date of July 31, 2014.

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.

5. WCNOC Letter ET 13-0026, "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)," August 28, 2013.

ADAMS Accession No. ML13252A238.

Attachment ET 14-0010 Page 3 of 3

6. Letter from C. F. Lyon, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Interim Staff Evaluation and Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Instrumentation (TAC NO. MF0781)," October 29, 2013. ADAMS Accession No. ML13295A681.