NLS2013078, Nebraska Public Power District'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 Number EA-12-051)

Nebraska Public Power District'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 Number EA-12-051)

ML13247A281
Person / Time
Site:	Cooper
Issue date:	08/27/2013
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NLS2013078
Download: ML13247A281 (6)

Text

N Nebraska Public Power District Always there when you need us NLS2013078 August 27, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Nebraska Public Power District'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 Number EA- 12-05 1)

Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

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. Nebraska Public Power District's Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 26, 2012 (NLS20121 11)

5. Cooper Nuclear Station's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 I), dated February 28, 2013 (NLS2013026)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission issued an Order (Reference 1) to Nebraska Public Power District (NPPD). Reference 1 was immediately effective and directs NPPD to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2013078 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 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 NPPD's initial status report for Cooper Nuclear Station (CNS) regarding reliable spent fuel pool instrumentation. Reference 5 provided CNS' overall integrated plan.

Reference I requires submission of a status report at six-month intervals following submittal of the overall integrated plan. 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 last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. Should you have any questions regarding this report, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: -7"/

Sincere(~

Vice 4President - 1uclear and Chief Nuclear Officer

/bk

Attachment:

Cooper Nuclear Station'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 cc: Regional Administrator, w/attachment USNRC - Region IV Director, w/attachment USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC - NRR Project Directorate IV- 1

NLS2013078 Page 3 of 3 Senior Resident Inspector, w/attachment USNRC - CNS NPG Distribution, w/attachment CNS Records, w/attachment

NLS2013078 Attachment Page 1 of 3 Attachment Cooper Nuclear Station'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 Introduction Nebraska Public Power District (NPPD) developed an overall integrated plan for Cooper Nuclear Station (Reference 1), documenting the requirements to install reliable spent fuel pool level instrumentation, in response to Reference 2. This attachment 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.

Milestone Accomplishments The following milestone(s) have been completed since the development of the overall integrated plan (Reference 1), and are current as of July 30, 2013:

S A preliminary Scoping Study was completed on February 15, 2013.

0 Purchase order 4500161756 for supply of the reliable spent fuel pool instrumentation system material was issued to Mohr Test and Measurement, LLC on July 15, 2013.

Milestone Schedule Status The following provides an update to the milestone schedule to support the overall integrated plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

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 I Aug 2013 Complete Update 2 Feb 2014 Not Started Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started

NLS2013078 Attachment Page 2 of 3 Revised Target Target Milestone Completion Activity Status Completion Date Date Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started Modifications:

Complete Scoping Study Feb 2013 Complete Generate Detailed Design Oct 2014 Not Started Complete Refueling 28 Outage Nov 2014 Not Started Walkdowns Complete Procurement of Parts Dec 2014 Started Complete Detailed Design Oct 2015 Not Started Complete Installation Outage Oct 2016 Not Started Complete Installation/Testing Outage Nov 2016 Not Started In-service/Mod Complete Nov 2016 Not Started Procedures:

Create Procedures June 2016 Not Started Training:

Develop Training Plan Aug 2016 Not Started Training Complete Oct 2016 Not Started Changes to Compliance Method Section 4.1 of the overall integrated plan submitted on February 28, 2013, described the measurement range of the system from one foot above normal level of the pool to one foot below the top of the fuel rack. In discussion with the system supplier, it has been determined that extension of the level system below the top of the fuel rack could create the risk of physical contact between the system probe and the rack. For this reason, the system probe will stop approximately six inches above the top of the rack. This will still allow the system to conservatively measure to level three within + 12 inch accuracy required by NEI 12-02, Industry Guidance for Compliance with Nuclear Regulatory Commission (NRC) Order EA- 12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."

NLS2013078 Attachment Page 3 of 3 Section 6.5 of the overall integrated plan submitted on February 28, 2013, described the various power supply options for the primary and backup instrument channels, including an internal battery for each channel that will supply power for between four and twenty-four hours, and an external battery that will provide power up to seven days. During the system development process, Mohr has eliminated the internal battery, but the seven day external battery remains for each channel.

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

Open Items from Overall Integrated Plan and Draft Safety Evaluation None.

Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

References The following references support the updates to the overall integrated plan described in this attachment.

1. Cooper Nuclear Station's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-051)," dated February 28, 2013.

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.