ET 14-0024, Third 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

Third 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

ML14246A191
Person / Time
Site:	Wolf Creek
Issue date:	08/28/2014
From:	Reasoner C Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, ET 14-0024
Download: ML14246A191 (10)

Text

W LF CREEK 'NUCLEAR OPERATING CORPORATION Cleveland Reasoner Vice President Engineering August 28, 2014 ET 14-0024 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

6) Letter ET 13-0027, dated August 28, 2013, from J. P. Broschak, WCNOC, to USNRC

7) Letter ET 14-0011, dated February 26, 2014, from J. P. Broschak, WCNOC, to USNRC

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's Third 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) issued Order EA-12-049 (Reference 1) to Wolf Creek Nuclear Operating Corporation (WCNOC). Reference 1 was immediately effective and directs WCNOC to develop, implement, and maintain guidance and P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET f J

ET 14-0024 Page 2 of 3 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.

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

(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. References 6 and 7 provided the first and second six-month status report for the implementation of Order EA-12-049, respectively.

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 third 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 Reference 7, 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) 364-4171, or Mr. Steven R. Koenig at (620) 364-4041.

Sincerely, Cleveland Reasoner COR/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 14-0024 Page 3 of 3 STATE OF KANSAS SS COUNTY OF COFFEY Cleveland 0. Reasoner, 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.

By P itg n Cleveland Reason-er Vice President Engineering SUBSCRIBED and sworn to before me th I oib A*. ,.4 is L_.u, Iday of t_1 - ,2014.

t j~GAYLESHEPHEARD1 Notary Public, -State of Kansas' Notary P Iic

'My Appt. Expires 1 Expiration Date - -= It1 -*=r

Attachment to ET 14-0024 Page 1 of 7 Wolf Creek Nuclear Operating Corporation's (WCNOC) Third Six-Month Status Report for the Implementation of Order EA-1 2-049, "Order to Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"

1. Introduction 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.

2. Milestone Accomplishments The following milestones have been completed since the submittal of the last six-month status report (Reference 3), and are current as of July 31, 2014.

0 Design Engineering (FLEX Modifications) - Complete

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 and are subject to change as design and implementation details are developed.

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

Italicized text denotes that a Milestone was updated since the second six-month status update.

Target Revised Milestone Completion Activity Status Target Date Completion 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 Complete -

Update 3 Aug 2014 Complete -

Update 4 Feb 2015 Not Started -

Update 5 Aug 2015 Not Started -

FLEX Strategy Evaluation Apr 2013 Complete -

Walk-Throughs or Demonstrations Sep 2014 Not Started Sep 2015 Perform Staffing Analysis Dec 2013 On-Going May 2016

Attachment to ET 14-0024 Page 2 of 7 Modifications:

Modifications Evaluation Apr 2013 Complete N-1 Walkdown Apr 2014 Not Started Sept 2015 Design Engineering Jan 2014 Complete Implementation Outage Feb 2015 As Scheduled Sep 2016 FLEX Equipment:

Procure On-Site Equipment Dec 2014 On-Going -

Develop Strategies with Regional Nov 2013 Started Jun 2015 Response Center (RRC)

Install Off-Site Delivery Station (if Sep 2014 On-Going Dec 2014 necessary)

Procedures:

Pressurized Water Reactor Owners Group (PWROG) issues NSSS- Jun 2013 Complete -

specific guidelines Create WCGS FLEX Support Jun 2014 On-Going Mar 2015 Guidelines (FSG)

Create Maintenance Procedures Jul 2014 Started Jul 2015 Training:

Develop Training Plan Jul 2014 On-Going Mar 2015 Training Complete Feb 2015 Not Started Sep 2016 Submit Completion Report* Mar 2015 Not Started Jan 2017

• The report will be submitted 90 days after the completion of Refueling Outage 21.

4. Changes to Compliance Method No changes have been made to the compliance method since the submittal of Reference 3.

5. Need for RelieflRelaxation and Basis for the Relief/Relaxation WCNOC requested (Reference 4) relaxation for the implementation of Order EA-12-049. The Wolf Creek Generating Station (WCGS) FLEX strategies rely on the low leakage Reactor Coolant Pump (RCP) seals and a seismic and missile protected Condensate Storage Tank (CST). Compliance with the original Order EA-12-049 schedule requirement for full completion and implementation of mitigation strategies would have resulted in hardship or unusual difficulty without a compensating increase in the level of safety.

An extension of one additional refueling cycle was requested in Reference 4. Reference 10 approved the relaxation of the order implementation date. This moves the implementation date to completion of the fall 2016 refueling outage, which is still within the maximum allowed timeframe of December 2016.

Attachment to ET 14-0024 Page 3 of 7

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation 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 locations of the two FLEX storage building. The deployment storage buildings have been selected.

routes, distances, and times provided Construction of both buildings has begun in this report are bounded for the and the deployment routes and distances Oi 1 currently proposed locations but will have been confirmed. The verification be updated as necessary. and validation process (Milestone: Walk throughs or Demonstrations) will confirm that deployment times are consistent with analysis values.

Perform containment evaluation, Closed - The Generation of Thermal using GOTHIC, based on the Hydraulic Information for Containment boundary conditions described in (GOTHIC) analysis has been completed.

Section 2 of NEI 12-06. Based on the The containment structure and 01 2 results of this evaluation, required instrumentation inside containment actions to ensure maintenance of critical to coping with an Extended Loss containment integrity and required of ac Power (ELAP) event are shown to instrument function will be developed, be acceptable following a 7-day duration (Reference 5).

The current CST and CST pipe chase Started - An evaluation was performed are non-seismic. Therefore, WCNOC to show that the existing CST met is currently pursuing two options; the current licensing basis for seismic and qualification and hardening of the tornado missile hazards (References 6, 7 existing CST, or the construction of a and 9).

new 670,000 gallon seismically The CST can withstand an Operating qualified and missile protected CST. Basis Earthquake (OBE) but will require One of these options must be reinforcement in order to withstand a completed before the volume of the Safe Shutdown Earthquake (SSE).

CST can be credited.

013 Evaluation and design activities, ensuring the CST can be credited for all of the required FLEX strategies, are ongoing. Final evaluations and necessary modification work will be complete by the end of RF21.

The CST pipe chase has been evaluated and can withstand the current licensing basis for seismic and tornado missile hazards (Reference 12).

Attachment to ET 14-0024 Page 4 of 7 Modify the RWST to protect it from Started - Evaluation and design tornado missiles or identify a borated activities, ensuring the RWST can be source that is protected for tornados credited for all of the required FLEX 01 4 and can be utilized to provide core strategies, are ongoing. Final cooling when steam generators are evaluations and necessary modification not available, work will be complete by the end of RF21 (References 6, 8, and 11).

For non-Class 1 E instrumentation that Closed - The final plant strategies do not will be repowered using a temporary rely on any equipment that is not 01 5 battery, an analysis will need to be powered by a Class 1 E source.

performed to determine battery life and frequency of replacing battery.

The method for isolating Closed - It was confirmed that the accumulators during Reactor Coolant accumulator isolation valves are on a System [RCS] inventory control has bus that is being re-powered for the 01 6 not been finalized, primary electrical FLEX strategy.

For the alternate electrical FLEX strategy, nitrogen injection will be prevented by venting the accumulators.

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.

Attachment to ET 14-0024 Page 5 of 7 The following table provides a summary of the open items documented in the Interim Staff Evaluation Report (Reference 15) and the status of each item.

Open Item # ISE Open Item Status Verify that the potential for Not Started - A review of the FLEX liquefaction considerations to impede deployment paths will be completed.

3.1.1.2.A movement of FLEX equipment following a severe seismic event at Wolf Creek are evaluated.

Verify that power that might be Closed - The deployment of FLEX required to deploy equipment, such equipment will not require external 3.1.1.2.B as power to open roll up doors at a power. Equipment such as roll up doors, storage location, is evaluated, will have provisions to be opened manually.

Verify resolution of the generic Closed - WCNOC will conform to the concern associated with the modeling position expressed by the NRC staff in of the timing and uniformity of the the letter dated January 8, 2014 to the mixing of a liquid boric acid solution PWROG (Reference 13). The NRC injected into the RCS under natural letter states that the NRC staff has 3.2.1.8.A conditions potentially involving two- reviewed the information submitted to phase flow. date and concluded that use of the industry approach in PWROG letter OG-13-284 dated August 19, 2013 (Reference 14) is acceptable with clarifications listed in the letter.

Verify that instrumentation that will be Not Started used to monitor portable/FLEX electrical power equipment ensures that: 1) the electrical equipment remains protected (from an electrical 3.2.4.8.B power standpoint - e.g., power fluctuations) and, 2) the operator is provided with accurate information to maintain core cooling, containment, and spent fuel cooling strategies.

Verify the licensee has fully Started - When finalized, a copy of the addressed considerations (2) through RRC playbook will be provided to the (10) of NEI 12-06, Section 12.2, NRC for review.

Minimum Capability of Off-Site 3.4.A Resources, which requires each site to establish a means to ensure the necessary resources will be available from off-site.

Attachment to ET 14-0024 Page 6 of 7 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.

3. WCNOC Letter ET 14-0011, "Wolf Creek Nuclear Operating Corporation'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," February 28, 2014. ADAMS Accession No. ML14064A190.

4. WCNOC Letter WO 14-0023, "Request for Schedule Relaxation of NRC Order EA-12-049, Requirement IV.A.2, at Wolf Creek Generating Station," March 31, 2014. ADAMS Accession No. ML14097A072.

5. CN-OA-13-7, Revision 1, "Wolf Creek ELAP Containment Heat-Up," June 16, 2014.

6. 020542.13.01-C-001, Revision 0, "Condensate Storage Tank and Refueling Water Storage Tanks Tornado Missile Impact Analyses," November 2013.

7. 020542.13.01-C-002, Revision 0, "Structural Analysis of Condensate Storage Tank,"

November 2013.

8. 020542.13.01-C-003, Revision 0, "Condensate Storage Tank Valve House and Refueling Water Storage Tank Valve House Missile Impact and Seismic Analysis," December 2013.

9. 020542.13.01-C-004, Revision 0, "Condensate Storage Tank Pipe Stress Analysis,"

December 2013.

10. Letter from E. J. Leeds, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," May 20, 2014. ADAMS Accession No. ML14104A029.

11. 020542.13.01-C-008, Revision 0, "Refueling Water Storage Tank Pipe Stress Analysis,"

December 2013.

12. 020542.13.01-C-009, Revision 0, "Condensate Storage Tank Pipe Tunnel Evaluation,"

December 2013.

13. Letter from J. Davis, USNRC, to N. J. Stringfellow, PWROG, January 8, 2013. ADAMS Accession No. ML13276A183.

Attachment to ET 14-0024 Page 7 of 7

14. PWROG Letter OG 13-284, "Submittal of LTR-FSE-13-46, Revision 0, P-Attachment, "Westinghouse Response to NRC Generic Request for Additional Information (RAI) on Boron Mixing in Support of the Pressurized Water Reactor Owners Group (PWROG)"

(Proprietary) (PA-ASC-1 184)," August 19, 2013.

15. Letter from J. S. Bowen, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station, Unit 1 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)(TAC NO. MF0788)," February 6, 2014.

ADAMS Accession No. ML14002A190.