NLS2017055, Nebraska Public Power District'S Sixth 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 (Orde

Nebraska Public Power District'S Sixth 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

ML17177A091
Person / Time
Site:	Cooper
Issue date:	06/19/2017
From:	Higginbotham K Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NLS2017055
Download: ML17177A091 (8)

Text

H Nebraska Public Power District Always there when you need us NLS2017055 June 19, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC20555-0001

Subject:

Nebraska Public Power District's Sixth 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 lp.tegrated 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 (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)

5. NPPD letter to NRC, "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)," dated December 28, 2016 COOPER NUCLEAR STATION P.O. Box 98 /Brownville, NE 68327-0098 Telephone: (402) 825-3817 /Fax: (402) 825-5217 www.nppd.com

NLS2017055 Page 2 of2 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.

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). In Reference 5, NPPD reported that CNS had completed implementation of Phase 1 Order requirements.

The purpose ofthis letter is to provide the sixth six-month update 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: t; /; 9

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Attachment:

Nebraska Public Power District's Sixth 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 Senior Resident Inspector, w/attachment USNRC - Region IV USNRC-CNS Director, w/attachment NPG Distribution, w/o attachment USNRC - Office of Nuclear Reactor Regulation CNS Records, w/attachment Cooper Project Manager, w/attachment USNRC - NRR Plant Licensing Branch IV

NLS2017055 Attachment Page 1of6 Attachment Nebraska Public Power District's Sixth 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 1 and 2 OIP (Reference 4).

NPPD developed 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 December 2016 status report (Reference 8) including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

Milestone Accomplishments There has been no change in Phase 2 milestone status since the last status update.

Milestone Schedule Status The following tables provide an update to Attachment 2 of Reference 4. 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.

NLS2017055 Attachment Page 2 of6 Phase 1and2 HCVS Milestone Table Milestone Target Completion Date Activity Status 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 Update 5 December 2016 Complete Update 6 June 2017 Complete with this submittal Update 7 December 2017 Not Started Update 8 June 2018 Not Started Phase i Specific Milestones Milestone Activity Status Hold preliminary/conceptual design meeting Complete Design Engineering On-site/Complete Complete Operations Procedure Changes Developed Complete Site Specific Maintenance Procedure Developed Complete Training Complete Complete Procedure Changes Active Complete Walk Through Demonstration/Functional Test Complete fhase 2 .Specific Milestones

• Target Activity Commentsillate Milestone Completion Date Status Changes Hold preliminary/conceptual design December 2015 Complete meeting Design Engineering On-site/Complete October 2017 In Progress Operations Procedure Changes May2018 In Progress Developed 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)

NLS2017055 Attachment Page 3of6 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 completed implementation of Phase 1 Order requirements prior to CNS entering Mode 2 (Startup) on November 6, 2016.

NPPD expects to comply with the Phase 2 Order implementation date and no relieflrelaxation 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.

Status/Comment 1 Closed. Response provided in Reference 6.

2 Closed. Response provided in Reference 6.

3 Closed. Response rovided in Reference 6.

4 Closed. Response rovided in Reference 6.

5 Closed. Response provided in Reference 6.

6 Closed. Response provided in Reference 6.

7 8 Closed. Response provided in Reference 6.

9 Closed. Response rovided in Reference 6.

10 Closed. Response rovided in Reference 6.

11 Closed. Response rovided in Reference 6.

12 Closed. Response provided in Reference 8.

• Phase 2 Open Items ..

None.

NLS2017055 Attachment Page 4of6

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ISE Open Item # Status 1 Response provided in Reference 6.

2 3

4 Response provided in Reference 6.

5 Response provided in Reference 8.

6 Response provided in Reference 8.

7 8

9 10 Complete. Response provided in Reference 6.

11 Complete.

ISE Open Action I ISE Section Reference Status Item#

Licensee to demonstrate that Complete.

containment failure as a result of Response provided in Reference 8.

overpressure can be prevented without 1 a drywell vent during severe accident conditions.

Section 3.3.3 Licensee to demonstrate that there is Complete.

adequate communication between the Response provided in Reference 8.

MCR and the operator at the FLEX 2

pump during severe accident conditions.

Section 3.3.3.4 Complete.

Per CNS' Final Integrated Plan for Order EA-12-049, the following environmental conditions exist:

Licensee to demonstrate the SAWM flow instrumentation qualification for

• Snow, ice, and extreme cold 3 the expected environmental (minus 5 degrees Fahrenheit) conditions.

• Extreme heat (97 degrees Section 3.3.3.4 Fahrenheit)

The severe accident water management (SAWM) pump that will be used to provide make-up water for

NLS2017055 Attachment Page 5of6 ISE Open Action I ISE Section Reference Status Item#

HCVS Phase 2 actions is rated for 925 gpm and 3 78 feet of discharge head.

As such, the pump's maximum discharge pressure is approximately 165 psig.

The selected flow meter is normally supplied with polyvinyl chloride (PVC) piping; however, for this application, CNS will use chlorinated polyvinyl chloride (CPVC) piping.

CPCV material (4-inch diameter, schedule 80) has a pressure rating of approximately 320 psig. However, this pressure rating is reduced when accounting for elevated temperatures.

An operating temperature of 100 degrees Fahrenheit has a derating factor of 0.82. Therefore, the selected CPVC material has a pressure rating of approximately 260 psig which exceeds the maximum discharge pressure of the SAWM pump.

The selected flow meter has a listed operating ambient temperature range of 0-150 degrees Fahrenheit, although the vendor confirmed that the meter will function and provide accurate readings at the required minus 5 degrees Fahrenheit.

Additionally, the selected flow meter is listed for applications such as lake or river water, potable water, de-ionized water, etc. These types of fluids meet the applications that CNS may be pumping through the flow meter.

NLS2017055 Attachment Page 6of6 Interim Staff Evaluation Impacts There are no potential impacts to the ISE 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: BWR Mark I and II 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

8. NPPD letter to NRC, "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)," dated December 28, 2016