ML15189A047

Nebraska Public Power District'S Second 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 (EA-13

ML15189A047
Person / Time
Site:	Cooper
Issue date:	06/30/2015
From:	Limpias O A Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-13-109, NLS2015079
Download: ML15189A047 (7)

Text

NNebraska Public Power DistrictAlways there when you need usNLS2015079June 30, 2015U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Subject:

Nebraska Public Power District's Second Six-Month Status Report in Response toJune 6, 2013, Commission Order Modifying Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe AccidentConditions (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 toReliable Hardened Containment Vents Capable of Operation Under SevereAccident Conditions," dated June 6, 20132. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable HardenedContainment Vents Capable of Operation Under Severe Accident Conditions,"Revision 0, dated November 14, 2013 (Accession No. ML13304B836)3. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109BWR Mark I & II Reliable Hardened Containment Vents Capable of OperationUnder Severe Accident Conditions," Revision 0, dated November 20134. NPPD letter to NRC, "Nebraska Public Power District's Phase 1 OverallIntegrated Plan in Response to June 6, 2013, Commission Order ModifyingLicenses with Regard to Reliable Hardened Containment Vents Capable ofOperation Under Severe Accident Conditions (Order Number EA-13-109),"dated June 30, 2014 (NLS2014057)5. NPPD letter to NRC, "Nebraska Public Power District's First Six-Month StatusReport in Response to June 6, 2013, Commission Order Modifying Licenseswith Regard to Reliable Hardened Containment Vents Capable of OperationUnder Severe Accident Conditions (Order Number EA- 13-109)," datedDecember 19, 2014 (NLS2014101)COOPER NUCLEAR STATIONPI0. Box 98 / Brownville, NE 68321-0098.Telephone: (402) 825-3811 / Fax: (402) 825-5211ww.nppd .com NLS2015079Page 2 of 3

Dear Sir or Madam:

On June 6, 2013, the Nuclear Regulatory Commission issued an Order (Reference 1) to NebraskaPublic Power District (NPPD). Reference I was immediately effective and directs NPPD to installa reliable hardened venting capability at Cooper Nuclear Station (CNS) for pre-core damage andunder severe accident conditions, including those involving a breach of the reactor vessel bymolten core debris. Specific requirements are outlined in Attachment 2 of Reference 1.Reference I required submission of a Phase 1 Overall Integrated Plan (OIP) pursuant to Section IV,Condition D. Reference 2 endorses industry guidance document NEI 13-02, Revision 0 (Reference3) with clarifications and exceptions identified in Reference 2. Reference 4 provided NPPD'sinitial OIP and Reference 5 provided a revised OIP for CNS.Reference 1 requires submission of a status report at six-month intervals following submittal of theOIP. Reference 3 provides direction regarding the content of the status reports. The purpose ofthis letter is to provide the second six-month status report pursuant to Section IV, Condition D, ofReference 1, that delineates progress made in implementing the requirements of Reference 1.The attachment provides an update of milestone accomplishments including any changes to thecompliance method, schedule, or need for relief and the basis, if any.This letter contains no new regulatory commitments.If you have any questions regarding this report, 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: (P o50ISincerec .L~impiasVice President -Nuclear andChief Nuclear Officer/bk

Attachment:

Nebraska Public Power District's Second Six-Month Status Report in Response toJune 6, 2013, Commission Order Modifying Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe AccidentConditions (Order Number EA- 13-109)

NLS2015079Page 3 of 3cc: Regional Administrator, w/attachmentUSNRC -Region IVDirector, w/attachmentUSNRC -Office of Nuclear Reactor RegulationCooper Project Manager, w/attachmentUSNRC -NRR Project Directorate IV- 1Senior Resident Inspector, w/attachmentUSNRC -CNSNPG Distribution, w/o attachmentCNS Records, w/attachment NLS2015079AttachmentPage 1 of 4AttachmentNebraska Public Power District's Second Six-Month Status Report in Response to June 6, 2013,Commission Order Modifying Licenses with Regard to Reliable Hardened Containment VentsCapable of Operation Under Severe Accident Conditions (Order Number EA-13-109)IntroductionNebraska Public Power District (NPPD) developed an Overall Integrated Plan (OIP) (Reference1) in accordance with the guidance contained in References 3 and 4. This OIP documents theinstallation of a Hardened Containment Vent System (HCVS) at Cooper Nuclear Station (CNS)that provides a reliable hardened venting capability for pre-core damage and under severeaccident conditions, including those involving a breach of the reactor vessel by molten coredebris, in response to Reference 2.As part of the first six-month status report, NPPD reported a change in the method of compliancewith regard to the design of the wetwell vent due to increasing complexity of the design neededto support using existing underground piping. NPPD submitted a revised OIP with that statusreport (Reference 5).This attachment provides an update of milestone accomplishments including changes to thecompliance method, schedule, or need for relief/relaxation and the basis, if any.Milestone AccomplishmentsThe following milestone(s) have been completed since last status update and are current as ofJune 15, 2015:* None.Milestone Schedule StatusThe following table provides an update to the milestones contained in the OIP. It provides theactivity status of each item, and whether the expected completion date has changed. The datesare planning dates subject to change as design and implementation details are developed.Target Completion Activity Revised TargetMilestone Date Status Completion Date/CommentsHold preliminary/conceptual design June 2014 CompletemeetingSubmit Overall Integrated June 2014 CompleteImplementation PlanSubmit 6 Month Status Report December 2014 Complete NLS2015079AttachmentPage 2 of 4Target Completion Activity Revised TargeteDate Status Completion Date/CommentsSubmit 6 Month Status Report June 2015 CompleteDesign Engineering On-site/Complete September 2015 StartedSubmit 6 Month Status Report December 2015 Not Started Simultaneous withPhase 2 GIPSubmit 6 Month Status Report June 2016 Not StartedOperations Procedure Changes August 2016 Not StartedDevelopedSite Specific Maintenance Procedure August 2016 Not StartedDevelopedTraining Complete September 2016 Not StartedImplementation Outage October 2016 Not StartedProcedure Changes Active November 2016 Not StartedWalk Through November 2016 Not StartedDemonstration/Functional TestSubmit Completion Report November 2016 Not Started January 2017(60 days after fullcompliance)Changes to Compliance MethodNone to report since the December 2014 update.Need for Relief/Relaxation and Basis for the Relief/RelaxationNPPD expects to comply with the Order implementation date and no relief/relaxation is requiredat this time.Open Items from Interim Staff EvaluationIn Reference 6, the Nuclear Regulatory Commission (NRC) issued an interim staff evaluation(ISE) for CNS. The following table provides a status of the open items documented in ISE.Open Item Action Status1 Make available for NRC staff audit analyses demonstrating In progressthat HCVS has the capacity to vent the steam/energyequivalent of one percent of licensed/rated thermal power(unless a lower value is justified), and that the suppression NLS2015079AttachmentPage 3 of 4pool and the HCVS together are able to absorb and rejectdecay heat, such that following a reactor shutdown from fullpower containment pressure is restored and then maintainedbelow the primary containment design pressure and theprimary containment pressure limit.2 Make available for NRC staff audit the seismic and tornado In progressmissile final design criteria for the HCVS stack.3 Make available for NRC staff audit descriptions of all In progressinstrumentation and controls (existing and planned)necessary to implement this order including qualificationmethods.4 Make available for NRC staff audit a determination of the In progressnumber of required 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 />.5 Make available for NRC audit the control document for In progressHCVS out of service time criteria6 Make available for NRC staff to audit, an evaluation In progressverifying the existing containment isolation valves, reliedupon for the HCVS, will open under the maximum expecteddifferential pressure during severe accident wetwell venting.8 Make available for NRC staff audit documentation that In progressdemonstrates adequate communication between the remoteHCVS operation locations and HCVS decision makersduring ELAP and severe accident conditions.8 Make available for NRC staff audit an evaluation of In progresstemperature and radiological conditions to ensure thatoperating personnel can safely access and operate controlsand support equipment.9 Make available for NRC staff audit the final sizing In progressevaluation for HCVS batteries/battery charger andincorporate into FLEX DG loading calculation.10 Make available for NRC staff audit documentation of the In progressHCVS nitrogen pneumatic system design including sizingand location.11 Make available for NRC staff audit the descriptions of local In progressconditions (temperature, radiation and humidity) anticipatedduring ELAP and severe accident for the components(valves, instrumentation, sensors, transmitters, indicators,electronics, control devices, and etc.) required for HCVSventing including confirmation that the components arecapable of performing their functions during ELAP andsevere accident conditions.

I k INLS2015079AttachmentPage 4 of 4Interim Staff Evaluation ImpactsThere are no potential impacts to the ISE identified at this time.ReferencesThe following references support the updates to the Phase 1 OIP described in this attachment.1. NPPD letter to NRC, "Nebraska Public Power District's Phase I Overall Integrated Plan inResponse to June 6, 2013, Commission Order Modifying Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe Accident Conditions(Order Number EA-13-109)," dated June 30, 2014 (NLS2014057)2. NRC Order Number EA- 13-109, "Order Modifying Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe Accident Conditions,"dated June 6, 20133. NEI 13-02, "Industry Guidance for Compliance with Order EA-13-109 BWR Mark I & IIReliable Hardened Containment Vents Capable of Operation Under Severe AccidentConditions," Revision 0, dated November 20134. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA- 13-109,Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capableof Operation Under Severe Accident Conditions," Revision 0, dated November 14, 2013(Accession No. ML13304B836)5. NPPD letter to NRC, "Nebraska Public Power District's First Six-Month Status Report inResponse to June 6, 2013, Commission Order Modifying Licenses with Regard to ReliableHardened Containment Vents Capable of Operation Under Severe Accident Conditions(Order Number EA- 13-109)," dated December 19, 2014 (NLS2014101)6. NRC letter to NPPD, "Cooper Nuclear Station -Interim Staff Evaluation Relating toOverall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe AccidentCapable Hardened Vents) (TAC NO. MF4384)," dated February 11, 2015