NLS2016006, Sixth 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)

Sixth 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)

ML16054A798
Person / Time
Site:	Cooper
Issue date:	02/16/2016
From:	Limpias O Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NLS2016006
Download: ML16054A798 (6)

Text

N Nebraska PubliC Power District Always there when you need us NLS201 6006 February 16, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-000 1

Subject:

Nebraska Public Power District's Sixth 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)

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 BA- 12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"...

Revision 1, dated August 2012

4. NPPD Letter, "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, 201 2 (NLS20121 11)

5. NPPD Letter, "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 1)," dated February 28, 2013 (NLS201 3026)

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 pooi level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

P.O. Box 98 / Brownviile, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211__ j .

wvww.nppd. corn, ]

NLS2016006 Page 2 of 2 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 pooi instrumentation.

Reference 5 provided CNS' overall integrated plan.

Reference 1 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 sixth 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 Jim Shaw, Licensing Manager, at (402) 825-2788.

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

Executed on: 0 I/1Ic 1,o Vice President - Nuclear and Chief Nuclear Officer

/bk

Attachment:

Nebraska Public Power District's Sixth Six-Month Status Report for the Implementation of Order BA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: Regional Administrator, w/attachment Senior Resident Inspector, w/attachment USNRC - Region IV USNRC - CNS Director, w/attachment NPG Distribution, w/attachment USNRC - Office of Nuclear Reactor Regulation CNS Records, w/attachment Cooper Project Manager, w/attachment USNRC - NRR Plant Licensing Branch IV-2

NLS201 6006 Attachment Page 1 of 4 Attachment Nebraska Public Power District's Sixth 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 (CNS) (Reference 2), documenting the requirements to install reliable spent fuel pool level instrumentation, in response to Nuclear Regulatory Commission (NRC) Order Number EA-12-051 (Reference 1). This attachment provides an update of milestone accomplishments since the last status report (Reference 5), 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 and are current as of February 1, 2016:

• Installation complete

• Testing complete

• Equipment is in service and modification complete Milestone Schedule Status The following table provides an update to the milestone schedule to support the overall integrated plan. The table 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.

TargetRevised Milestone Completion Activity Status Completio Date 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 Complete

NLS20 16006 Attachment Page 2 of 4 Target Revised Milestone Completion Activity Status Target Date Completion Date Update 5 Aug 2015 Complete _______

Update 6 Feb 2016 Complete _______

Update 7 Aug 2016 Not Started Modifications:

Complete Scoping Study Feb 2013 Complete Generate Detailed Design Oct 2014 Complete Complete Refueling 28 OutageNo204Cmlt WalkdownsNo204Cmet Complete Procurement of Parts Dec 2014 Complete Complete Final Detailed Design Oct 2015 Complete Complete Installation Outage Oct 2016 Complete Complete Installation/Testing Outage Nov 2016 Complete In-service/Mod Complete Nov 2016 Complete Procedures:

Create Procedures June 2016 Started Training:

Develop Training Plan Aug 2016 Started Training Complete Oct 2016 Started Changes to Compliance Method None other than those previously identified.

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.

Requests for Additional Information (RAI)

In Reference 3, the NRC issued the interim staff evaluation (ISE) for CNS. In a public meeting on November 26, 2013 (Reference 4), the NRC clarified that questions contained in the ISE supersede any previous requests for information issued by the Staff concerning the spent fuel

NLS20 16006 Attachment Page 3 of 4 pooi instrumentation. In CNS' ISE, the NRC requested that information be provided by May 31, 2016, to ensure any issues are resolved prior to the date by which NPPD must complete full implementation of the Order. The following table lists the open RAIs from the ISE and status of each item.

Interim Staff Evaluation - Open RAIs ISE RAI #I ISE Section Description Status RAL #1 Spent Fuel Pool Water Levels Response provided on ePortal RAI #2 a,b Design Features - Arrangement Response provided on ePortal RAI #3 a,b,c Design Features - Mounting Response provided on ePortal RAI #4 Design Features - Mounting Response provided on ePortal RAJ #5 Design Features - Mounting Response provided on ePortal RAI #6 Qualification and Reliability Response provided on ePortal RAI #7 Qualification and Reliability Response provided on ePortal RAI #8 a,b Design Features - Independence Response provided on ePortal RAI #9 a,b Design Features - Power Supplies Response provided on ePortal RAI # 10 Number not used N/A RAI #11 a,b Design Features - Accuracy Response provided on ePortal RAI #12 a,b,c,d Design Features - Testing Response provided on ePortal RAI #13 a,b Design Features - Display Response provided on ePortal

NLS2016006 Attachment Page 4 of 4 RAI #14 Programmatic Controls - Procedures Response provided on ePortal RAL #15 a,b,c Programmatic Controls - Testing and Calibration Response provided on ePortal Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

References

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

2. NPPD Letter, "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

3. NRC Letter, "Cooper Nuclear Station - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF097 1)," dated December 4, 2013

4. NRC Memorandum, "Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," dated December 26, 2013

5. NPPD Letter, "Nebraska Public Power District's Fifth 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)," dated August 27, 2015

N Nebraska PubliC Power District Always there when you need us NLS201 6006 February 16, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-000 1

Subject:

Nebraska Public Power District's Sixth 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)

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 BA- 12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"...

Revision 1, dated August 2012

4. NPPD Letter, "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, 201 2 (NLS20121 11)

5. NPPD Letter, "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 1)," dated February 28, 2013 (NLS201 3026)

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 pooi level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

P.O. Box 98 / Brownviile, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211__ j .

wvww.nppd. corn, ]

NLS2016006 Page 2 of 2 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 pooi instrumentation.

Reference 5 provided CNS' overall integrated plan.

Reference 1 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 sixth 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 Jim Shaw, Licensing Manager, at (402) 825-2788.

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

Executed on: 0 I/1Ic 1,o Vice President - Nuclear and Chief Nuclear Officer

/bk

Attachment:

Nebraska Public Power District's Sixth Six-Month Status Report for the Implementation of Order BA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: Regional Administrator, w/attachment Senior Resident Inspector, w/attachment USNRC - Region IV USNRC - CNS Director, w/attachment NPG Distribution, w/attachment USNRC - Office of Nuclear Reactor Regulation CNS Records, w/attachment Cooper Project Manager, w/attachment USNRC - NRR Plant Licensing Branch IV-2

NLS201 6006 Attachment Page 1 of 4 Attachment Nebraska Public Power District's Sixth 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 (CNS) (Reference 2), documenting the requirements to install reliable spent fuel pool level instrumentation, in response to Nuclear Regulatory Commission (NRC) Order Number EA-12-051 (Reference 1). This attachment provides an update of milestone accomplishments since the last status report (Reference 5), 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 and are current as of February 1, 2016:

• Installation complete

• Testing complete

• Equipment is in service and modification complete Milestone Schedule Status The following table provides an update to the milestone schedule to support the overall integrated plan. The table 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.

TargetRevised Milestone Completion Activity Status Completio Date 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 Complete

NLS20 16006 Attachment Page 2 of 4 Target Revised Milestone Completion Activity Status Target Date Completion Date Update 5 Aug 2015 Complete _______

Update 6 Feb 2016 Complete _______

Update 7 Aug 2016 Not Started Modifications:

Complete Scoping Study Feb 2013 Complete Generate Detailed Design Oct 2014 Complete Complete Refueling 28 OutageNo204Cmlt WalkdownsNo204Cmet Complete Procurement of Parts Dec 2014 Complete Complete Final Detailed Design Oct 2015 Complete Complete Installation Outage Oct 2016 Complete Complete Installation/Testing Outage Nov 2016 Complete In-service/Mod Complete Nov 2016 Complete Procedures:

Create Procedures June 2016 Started Training:

Develop Training Plan Aug 2016 Started Training Complete Oct 2016 Started Changes to Compliance Method None other than those previously identified.

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.

Requests for Additional Information (RAI)

In Reference 3, the NRC issued the interim staff evaluation (ISE) for CNS. In a public meeting on November 26, 2013 (Reference 4), the NRC clarified that questions contained in the ISE supersede any previous requests for information issued by the Staff concerning the spent fuel

NLS20 16006 Attachment Page 3 of 4 pooi instrumentation. In CNS' ISE, the NRC requested that information be provided by May 31, 2016, to ensure any issues are resolved prior to the date by which NPPD must complete full implementation of the Order. The following table lists the open RAIs from the ISE and status of each item.

Interim Staff Evaluation - Open RAIs ISE RAI #I ISE Section Description Status RAL #1 Spent Fuel Pool Water Levels Response provided on ePortal RAI #2 a,b Design Features - Arrangement Response provided on ePortal RAI #3 a,b,c Design Features - Mounting Response provided on ePortal RAI #4 Design Features - Mounting Response provided on ePortal RAJ #5 Design Features - Mounting Response provided on ePortal RAI #6 Qualification and Reliability Response provided on ePortal RAI #7 Qualification and Reliability Response provided on ePortal RAI #8 a,b Design Features - Independence Response provided on ePortal RAI #9 a,b Design Features - Power Supplies Response provided on ePortal RAI # 10 Number not used N/A RAI #11 a,b Design Features - Accuracy Response provided on ePortal RAI #12 a,b,c,d Design Features - Testing Response provided on ePortal RAI #13 a,b Design Features - Display Response provided on ePortal

NLS2016006 Attachment Page 4 of 4 RAI #14 Programmatic Controls - Procedures Response provided on ePortal RAL #15 a,b,c Programmatic Controls - Testing and Calibration Response provided on ePortal Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

References

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

2. NPPD Letter, "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

3. NRC Letter, "Cooper Nuclear Station - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF097 1)," dated December 4, 2013

4. NRC Memorandum, "Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," dated December 26, 2013

5. NPPD Letter, "Nebraska Public Power District's Fifth 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)," dated August 27, 2015