NLS2016068, Nebraska Public Power District - Fifth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
| ML17006A005 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/28/2016 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-13-109, NLS2016068 | |
| Download: ML17006A005 (12) | |
Text
H Nebraska Public Power District Always there when you need us NLS2016068 December 28, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Nebraska Public Power District's Fifth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)
Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013
- 2. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capab.le of
- Operation Under Severe Accident Conditions (Order Number EA-13-109),"
dated June 30, 2014 (NLS2014057)
- 3. NPPD letter to NRC, "Nebraska Public Power District's First Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 19, 2014 (NLS2014101)
- 4. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 and Phase 2 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated December 21, 2015 (NLS2015137)
On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109 (Reference
- 1) to Nebraska Public Power District (NPPD). Reference 1 was immediately effective and directs NPPD to take certain actions to ensure that Cooper Nuclear Station (CNS) has a Hardened Containment Vent System to remove decay heat from the containment, and maintain control of containment pressure within acceptable limits following events that result in loss of active containment heat removal capability while maintaining the capability to operate under severe
- accident conditions resulting from an Extended Loss of AC Power. 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
NLS2016068 Page 2 of2 Reference 1 required submission of a Phase 1 overall integrated plan (OIP) pursuant to Section IV, Condition D, and status reports at six-month intervals thereafter. NPPD submitted an initial OIP for CNS by letter dated June 30, 2014 (Reference 2), Revision 1 to the OIP by letter dated December 19, 2014 (Reference 3), and Revision 2 which provided a combined Phase 1 and Phase
- 2) OIP (Reference 4).
The purpose of this letter is to provide the fifth six-month update for both Phase 1 and Phase 2 OIP implementation pursuant to Section IV, Condition D.3, of Reference 1.
This letter contains no new regulatory commitments. Should you have any questions concerning the content of this letter, please contact Jim Shaw, Licensing Manager, at (402) 825-2788.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: ~2 - z.. B- I Co
/bk
Attachment:
Nebraska Public Power District's Fifth Six-Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" cc: Regional Administrator, w/attachment USNRC - Region IV Director, w/attachment USNRC - Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC - NRR Plant Licensing Branch IV Senior Resident Inspector, w/attachment USNRC-CNS NPG Distribution, w/o attachment CNS Records, w/attachment
NLS2016068 Attachment Page 1of10 Attachment Nebraska Public Power District's Fifth Six-Month Status Report for the Implementation of Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" Introduction Nebraska Public Power District (NPPD) developed an Overall Integrated Plan (OIP) for Cooper Nuclear Station (CNS) (Reference 1), documenting the installation of a Hardened Containment Vent System (HCVS) that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2. Updates of milestone accomplishments are based on the combined Phase 1and2 OIP (Reference 4).
NPPD developed an updated and combined Phase 1 and 2 OIP (Reference 4) in accordance with the guidance contained in Reference 3, documenting:
- 1. The installation of a HCVS that provides a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris, in response to Reference 2.
- 2. An alternative venting strategy that makes it unlikely that a drywell vent is needed to protect the containment from overpressure related failure under severe accident conditions, including those that involve a breach of the reactor vessel by molten core debris, in response to Reference 2.
This attachment provides an update of milestone accomplishments since submittal of the June 2016 status report (Reference 6) including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
Milestone Accomplishments Phase 1 specific milestones are complete.
Milestone Schedule Status The following tables provide an update to Attachment 2 of the combined Phase 1 and 2 OIP.
They provide the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
NLS2016068 Attachment Page 2of10 Phase 1 and 2 HCVS Milestone Table Target Comments Activity Milestone Completion (Include date Status Date changes)
Submit Phase 1 OIP June 2014 Complete Submit Six-Month Updates: -- --
Update 1 December 2014 Complete Update 2 June 2015 Complete Update 3 with Phase 2 OIP December 2015 Complete Update 4 June 2016 Complete December 2016 Complete Update 5 with this submittal Update 6 June 2017 Not Started Update 7 December 2017 Not Started Update 8 June 2018 Not Started Phase 1 Specific Milestones.
Target Comments Activity Milestone Completion (Include date Status Date changes)
Hold preliminary/conceptual design June 2014 Complete meeting Design Engineering On-site/Complete September 2015 . Complete Operations Procedure Changes August2016 Complete Developed Site Specific Maintenance Procedure August 2016 Complete Developed Training Complete September 2016 Complete Procedure Changes Active November 2016 Complete Walk Through November 2016 Complete Demonstration/Functional Test
NLS2016068 Attachment Page 3of10 Phase 2 Specific Milestones Target Comments Activity Milestone Completion (Include date Status Date changes)
Hold preliminary/conceptual design December 2015 Complete meeting Design Engineering On-site/Complete October 2017 In Progress Operations Procedure Changes Developed May2018 In Progress Site Specific Maintenance Procedure May2018 In Progress Developed Training Complete June 2018 In Progress Implementation Outage October 2018 Not Started Walk Through Demonstration/Functional October 2018 Not Started Test Procedure Changes Active October 2018 Not Started Submit Completion Report (60 days after January 2019 Not Started full site compliance)
Changes to Compliance Method There are no changes to the compliance method as documented in the combined Phase 1 and 2 OIP.
Need for Relief/Relaxation and Basis for the Relief/Relaxation NPPD has completed implementation of the Phase 1 Order requirements.
NPPD expects to comply with the Phase 2 Order implementation date and no relief/relaxation is required at this time.
Open Items from Combined Phase 1 and 2 Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the combined Phase 1 and 2 OIP, the Interim Staff Evaluations (ISE) for Phase 1 and Phase 2 (References 5 and 7), and the status of each item.
NLS2016068 Attachment Page 4of10 Combined Phase 1 and 2 OIP Open Items Phase 1 Open Items OIPOpen Action Status/Comment ,/
~
Item# /
Determine location ofHCVS ROS. Closed. !'
1 \
Response provided in Reference 6.
Evaluate accessibility of the Closed. "' \
Mechanical ROS for radiological and environmental conditions. Address Response provided in Reference 6.
dose and temperature items for the 2
Mechanical ROS and non-MCR locations. FAQ-HCVS-01 (Reference 14) will be used as guidance.
Determine the location of the Closed.
3 Dedicated HCVS Battery transfer switch. Response provided in Reference 6.
Determine the location of backup Closed.
nitrogen bottles and evaluate the 4 effects of radiological and Response provided in Reference 6.
temperature constraints on their deployment.
Evaluate the location of the Portable Closed.
5 DG for accessibility under Severe Accident HCVS use. Response provided in Reference 6.
Confirm suppression pool heat Closed.
6 capacity.
Response provided in Reference 6.
Determine which approach or Closed.
combination of approaches Cooper Nuclear Station (CNS) will take to Response provided in Reference 6.
7 address the control of flammable gases, clearly demarcating the segments of vent system to which an approach applies.
Identify qualification method used Closed.
8 for HCVS instruments.
Response provided in Reference 6.
Evaluate HCVS monitoring location Closed.
for accessibility, habitability, staffing 9 sufficiency, and communication Response provided in Reference 6.
capability with vent-use decision makers.
NLS2016068 Attachment Page 5of10 Combined Phase 1 and 2 OIP Open Items Phase 1 Open Items OIPOpen Action Status/Comment Item#
Determine the number of required Closed.
valve cycles during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
10 Response provided in Reference 6.
Size the electrical and pneumatic supplies accordingly.
Evaluate the impact of SA Closed.
environmental conditions for post-24 11 hour actions supporting the Response provided in Reference 6.
implementation of power and pneumatic supplies.
Determine the control document for Closed.
HCVS out of service time criteria.
12 The out-of-service time criteria for HCVS will be maintained in the Technical Requirements Manual.
.Phase 2 Open items None.
Phase l Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
Make available for NRC staff audit Complete.
analyses demonstrating that HCVS has the capacity to vent the steam/energy Response provided in Reference 6.
equivalent of one percent of licensed/rated thermal power (unless a lower value is justified), and that the suppression pool and the HCVS 1 together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
Sections 3 .2.2.1, 3 .2.2.2
NLS2016068 Attachment Page 6of10 Phase 1 Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
Make available for NRC staff audit the Complete.
seismic and tornado missile final 2 Response provided in Reference 6.
design criteria for the HCVS stack.
Section 3.2.2.3 Make available for NRC staff audit Complete.
descriptions of all instrumentation and controls (existing and planned) Response provided in Reference 6.
3 necessary to implement this order including qualification methods.
Section 3 .2.2.10 Make available for NRC staff audit a Complete.
determination of the number of 4 required valve cycles during the first 24 Response provided in Reference 6.
hours.
Section 3.2.3.l Make available for NRC audit the Complete.
control document for HCVS out of 5 service time criteria. The out-of-service time criteria for HCVS Section 3.4.1 will be maintained in the Technical Requirements Manual.
Make available for NRC staff to audit, Complete.
an evaluation verifying the existing containment isolation valves, relied The HCVS operational temperature has been upon for the HCVS, will open under updated to 310° F per NEDC 15-023, "Owner the maximum expected differential Acceptance ofTetraTech Calculation pressure during severe accident wetwell CNSOOl-194-4933-004 - Calculation of the venting. Pressure Gradient Across the HCVS Line Section 3.2.2.9 and HCVS Maximum Operation Temperature." Change Notice #28 to CED 6036742, "Reliable Hardened Containment 6 Venting System," authorized corresponding changes to the following air operated valve (AOV) and motor operated valve (MOV) related calculations to address HCVS flow rate and temperature increase:
NEDC 91-242, "Review ofERIN's System Level Design Basis Review for the Primary Containment System MOV's," Revision 2Cl
NLS2016068 Attachment Page 7of10 Phase 1 Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
NEDC 96-025B, "Review of ADVENT LCA Calculation 96007TR-41 B, Rev. 1 for PC-MOV-232MV and -233MV," Revision lCl NEDC 95-003, "Determination of Allowable Operating Parameters for CNS MOY Program MOVs," Revision 31Cl NEDC 00-110, "MOY Program Valve Margin Determination," Revision 1OC1 NEDC 00-065, "Functional and MEDP Evaluation for PC-AOV-237AV," Revision 1C2 NEDC 05-013, "AOV Component Level Calculation for PC-AOV-237AV," Revision lCl Make available for NRC staff audit Complete.
documentation that demonstrates adequate communication between the Response provided in Reference 6.
7 remote HCVS operation locations and HCVS decision makers during ELAP and severe accident conditions.
Section 3.2.2.5 Make available for NRC staff audit an Complete.
evaluation of temperature and radiological conditions to ensure that Response provided in Reference 6.
operating personnel can safely access 8
and operate controls and support equipment.
Sections 3.2.1, 3.2.2.3, 3.2.2.4, 3.2.2.5, 3 .2.2.10, 3 .2.4.1, 3 .2.4.2, 3 .2.5 .2, 3 .2.6 Make available for NRC staff audit the Complete.
final sizing evaluation for HCVS batteries/battery charger and Response provided in Reference 6.
9 incorporate into FLEX DG loading calculation.
Sections 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 3.2.4.2, 3.2.5.1, 3.2.5.2, 3.2.6
NLS2016068 Attachment Page 8of10 Phase 1 Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
Make available for NRC staff audit Complete.
documentation of the HCVS nitrogen pneumatic system design including Response provided in Reference 6.
10 sizing and location.
Sections 3.2.1, 3.2.2.4, 3.2.3.1, 3.2.3.2, 3.2.4.1, 3.2.4.2, 3.2.5.1, 3.2.5.2, 3.2.6 Make available for NRC staff audit the Complete.
descriptions of local conditions (temperature, radiation and humidity) Response provided in Reference 6.
anticipated during ELAP and severe accident for the components (valves, instrumentation, sensors, transmitters, indicators, electronics, control devices, 11 and etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
Sections 3.2.2.3, 3.2.2.5, 3.2.2.9, 3.2.2.10 Phase 2 Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
Licensee to demonstrate that Complete.
containment failure as a result of overpressure can be prevented without ER 1252, "NRC Order EA-13-109 Phase 2 a drywell vent during severe accident Reliable Hardened Containment Vent conditions. Engineering Study," evaluated Phase 2 Order Section 3.3.3 requirements. In this ER, CNS referred to the MAAP analysis that was performed for 1 the reference Mark I plant (Peach Bottom).
An evaluation of the plant parameters between CNS and Peach Bottom was performed to ensure that the MAAP analysis for Peach Bottom would be a bounding evaluation for CNS and confirms that the Severe Accident Water Addition/Severe
NLS2016068 Attachment Page 9of10 Phase 2 Interim Staff Evaluation Open Items ISE Open Action I ISE Section Reference Status Item#
Accident Water Management strategy endorsed by the nuclear industry (NRC, Nuclear Energy Institute and Boiling Water Reactor Owner's Group) would preserve the use of a wetwell vent path to ensure containment integrity.
Calculation NEDC 15-020, "Owner Acceptance of TetraTech Calculation CNSOOl-194-4933-001 - Calculation of HCVS Flow Rate and Vent Size," performs the analysis to ensure that the wetwell vent can achieve the required capacity to vent the steam/energy equivalent of 1% of the licensed/rated thermal power.
Licensee to demonstrate that there is Complete.
adequate communication between the MCR and the operator at the FLEX The Main Control Room (MCR) is the pump during severe accident normal monitoring and operating location for conditions. HCVS. Hand held radios will be used for Section 3.3.3.4 communications between the MCR and the operator at the FLEX pump.
Base station repeaters (Base 1 and Base 2) were upgraded to 24-hour battery life. Both 2
bases are capable of being powered via FLEX generator and one base station will be powered from a FLEX generator after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The communications assessment performed in response to Near Term Task Force Recommendation 9.3 (NLS2013028) documented the acceptability of this communications channel.
Licensee to demonstrate the SAWM In Progress.
flow instrumentation qualification for 3
the expected environmental conditions.
Section 3.3.3.4
NLS2016068 Attachment Page 10of10 Interim Staff Evaluation Impacts There are no potential impacts to the ISEs identified at this time.
References
- 1. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2014
- 2. NRC Order Number EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" dated June 6, 2013
- 3. NEI 13-02, "Industry Guidance for Compliance with NRC Order EA-13-109, 'To Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 1, dated April 2015
- 4. Nebraska Public Power District's Phase 1 and Phase 2 Overall Integrated Plan in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 21, 2015
- 5. NRC letter to NPPD, "Cooper Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC NO. MF4384)," dated February 11, 2015
- 6. NPPD letter to NRC, "Nebraska Public Power District's Fourth Six-Month Status Report in Response to June 6, 2013, Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)," dated June 30, 2016
- 7. NRC letter to NPPD, "Cooper Nuclear Station - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC NO. MF4384)," dated September 29, 2016