ML14055A412

Omaha Public Power District'S Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML14055A412
Person / Time
Site:	Fort Calhoun
Issue date:	02/24/2014
From:	Cortopassi L P Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, LlC-14-0021
Download: ML14055A412 (10)

Text

fjjjjjfj ----Omaha Public Power Oistrict 444 South 1fih Street Mall Omaha, NE 68102-2247 LlC-14-0021 February 24, 2014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No.1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Omaha Public Power District's Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

References:

See Page 3 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference

1) to all power reactor licensees and holders of construction permits in active or deferred status. The Order was effective immediately and requires the Omaha Public Power District (OPPD) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Specific requirements are described in Attachment 2 of the Order. Pursuant to Section IV, Condition C.2 of the Order, licensees are to provide a status report at six-month intervals following submittal of the Overall Integrated Plan (OIP), which OPPD submitted on February 28, 2013 (Reference 4). In August 2013, OPPD provided the first six-month status report (Reference

5) describing progress made in implementing the requirements of the Order; this letter provides the second six-month status report. The OIP (Reference

4) and subsequent six-month status reports were prepared utilizing NEI guidance (Reference

2) as endorsed with exceptions and clarifications by the NRC in Reference

3. There are no regulatory commitments contained in this submittal.

If you should have any questions regarding this submittal, please contact Mr. Bill R. Hansher at (402) 533-6894. Employment with Equal Opportunity U. S. Nuclear Regulatory Commission LlC-14-0021 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 24, 2014. ouis P. Cortopassi Site Vice President and CNO

Enclosure:

Second Six-Month Status Report for the Implementation of Order EA-12-049 c: E. J. Leeds, Director of Office of Nuclear Reactor Regulation M. L. Dapas, NRC Regional Administrator, Region IV J. M. Sebrosky, NRC Senior Project Manager J. C. Kirkland, NRC Senior Resident Inspector U. S. Nuclear Regulatory Commission LlC-14-0021 Page 3 References

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012 (ML12054A736) (NRC-12-0020)

2. Nuclear Energy Institute (NEI) 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012 (ML 12242A378)

3. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012 (ML12229A174)

4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (ML 13064A298) (LlC-13-0019)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," dated August 28, 2013 (ML 13268A075) (LlC-13-0123)

LlC-14-0021 Enclosure Page 1 Fort Calhoun Station, Unit No.1 Second Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events 1 Introduction The Omaha Public Power District (OPPD) developed an Overall Integrated Plan (Reference 2), documenting the diverse and flexible strategies (FLEX), in response to Reference

1. This enclosure 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. 2 Milestone Accomplishments

• NSSS Specific FLEX Support Guidelines have been issued.

• Modifications and Storage Design Engineering has started. 3 Milestone Schedule Status Attachment 1 contains an update to the Milestone Schedule (Reference 2, Enclosure, Attachment

2) provided with the Overall Integrated Plan. The status of each milestone is shown, as are revised completion dates. The dates are planning dates subject to change as design and implementation details are developed.

Attachment 1 is formatted to align with the table provided in the Nuclear Energy Institute's (NEI) Six-Month Status Report Template and supersedes the Milestone Schedule provided by Reference

2. Due to delays in the restart of Fort Calhoun Station, the planned refueling outage dates have changed from the fall of 2014 and spring of 2016 to the spring of 2015 and the fall of 2016, which resulted in several changes to some of the original milestone dates provided in the Overall Integrated Plan (Reference 2). In this update, those changes have been incorporated into the Target Completion Date" column. Thus, the "Revised Target Completion Date" column reflects only those changes that have occurred over the last 6 months (i.e., since the previous six-month update). Evaluations of FLEX strategy and modifications are largely complete.

However, the completion dates have been revised to accommodate development of modification packages and supporting analyses to the point where OPPD is assured that no significant changes in FLEX strategies will be necessary.

Thus, the target completion dates for those milestones were revised. Based on industry operating experience on the timing of FLEX storage building design and construction time windows, the target completion date for storage design engineering was extended to allow prioritization of resources for the development of FLEX modifications.

Nuclear steam system supplier (NSSS)-specific FLEX Support Guidelines are complete; however, additional documentation is being prepared by the Pressurized Water Reactor Owners Group (PWROG) relating to basis documentation and non-power operations.

Therefore, the FLEX Support Guidelines (FSG) milestone has been extended to allow for issuance of supporting documentation.

The revised milestone target completion dates do not impact the implementation date of the Order.

LI C-14-0021 Enclosure Page 2 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Fort Calhoun Station Overall Integrated Plan (Reference 2). However, two clarifications are being provided:

1. Additional information was provided in Action 12 , "Power for the DC Bus with 10 kW FLEX DG" (Reference 2, Enclosure, Appendix B, Page B-21) regarding alternate monitoring locations and strategies in the event that DC power cannot be restored to critical monitoring instruments, or flooding causes the failure of instrument signals to the Main Control Room indications.

2. Action 14, "Provide Temporary Main Control Room Ventilation and Lighting" (Reference 2, Enclosure, Appendix B, Page B-24) was revised to include information about the use of temporary Main Control Room (MCR) lighting in the event that the preferred means of re-powering the MCR lighting panel cannot be accomplished before the emergency lighting batteries are depleted.

Attachment 2 provides pages superseding Reference 2, Enclosure, Appendix B, Pages B-21, and B-24. Revision bars in the right margin denote the location of the revision.

As discussed in the first FCS 6-month update (Reference 3), OPPD has developed an interim strategy to address a flood up to 21 feet above the design basis (Le., elevation 1,035' mean sea level). This strategy is similar to that described in Reference 2, Enclosure, Appendix B, Action 24, but involves a slightly different portable equipment configuration to accommodate issues not yet addressed by FLEX modifications. The current strategy addresses the potential for design-basis (BDB) flooding during Modes 1-4 with the reactor coolant system (RCS) intact, using the steam generators for decay heat removal. The strategy for addressing BDB flooding during Mode 4 with the RCS open and Mode 5 (Refueling) is currently being developed and will be implemented prior to the next scheduled refueling outage in the spring of 2015. Depending on the outcome of the Near Term Task Force Recommendation 2.1 flood re-analysis and detailed design work on FLEX modifications, some or all of the interim equipment and strategies may be incorporated into the FLEX Overall Integrated Plan. OPPD will provide the status of the lower modes BDB flooding strategy and integrating the interim flood strategy into the Overall Integrated Plan in future six-month updates. 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation OPPD expects to comply with the Order's implementation date and no relief/relaxation is required at this time. 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference

2) or the Draft Safety Evaluation (SE) and the status of each item. Overall Integrated Plan Open Item Status 1. Communicate exceptions related to Site Security Not Started Plan or Other License requirements

2. Complete Control Room Heatup Calculation Started 3. Complete Reactor Coolant System (RCS) Makeup Not Started LI C-14-0021 Enclosure Page 3 Evaluation with Reactor Coolant Pump (RCP) Controlled Bleed-off (CBO) Modification

4. Develop Playbook 5. Complete Water Chemistry Impact Analysis and review impact on the strategies

6. Complete Core Uncovery Time Evaluation with RCP CSO Isolation. (This is subtask of open item #3.) 7. Evaluate Auxiliary Building Ventilation Requirements with Spent Fuel Pool (SFP) Evaporation

8. Evaluate Environmental Conditions after Extended Loss of AC Power (ELAP) in critical FLEX deployment areas Draft Safet Evaluation 0 en Item Draft SE Not Received as of Februa 24, 2014 7 Potential Draft Safety Evaluation Impacts Started Complete Not Started Started Not Started Status N/A There are no potential impacts to the Draft Safety Evaluation identified at this time. 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML 12054A736), (NRC-12-0020)

2. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's Overall Integrated Plan in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events (Order Number EA-12-049)," dated February 28, 2013 (ML 13064A298), (LlC-13-0019)

3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Omaha Public Power District's First Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Design-Basis External Events," dated August 28,2013 (ML 13268A075), (LlC-13-0123)

Attachments:

1. FLEX Overall Integrated Implementation Plan Milestone Schedule, Revision 2 2. LlC-13-0019, Enclosure, Appendix B, Replacement Pages B-21 and B-24 LI C-14-0021 Enclosure, Attachment 1 Page 1 Fort Calhoun Station EA-12-049 (FLEX) Overall Integrated Implementation Plan Milestone Schedule Revision 2 The following milestone schedule is provided.

The dates are planning dates subject to change as design and implementation details are developed.

Any changes to the following target dates will be reflected in subsequent 6-month status reports. Target Revised Activity Target Milestone Completion Status Completion Date Date Submit 60-Day Status Report Oct. 2012 Complete Submit Overall Integrated Plan Feb. 2013 Complete Submit 6-M onth Updates: Update 1 Aug. 2013 Complete Update 2 Feb. 2014 Update 3 Aug. 2014 Not Started Update 4 Feb. 2015 Not Started Update 5 Aug. 2015 Not Started Update 6 Feb. 2016 Not Started Update 7 Aug. 2016 Not Started FLEX Strategy Evaluation Mar. 2013 Started Nov. 2014 Walk-throughs or Demonstrations Nov. 2016 Not Started Perform Staffing Analysis Sep.2015 Not Started Modifications:

Modifications Evaluation Dec. 2013 Started Jun. 2014 Design Engineering Aug 2015 Started Implementation Oct. 2016 Not Started StoraJle:

Storage Design Engineering Jul. 2014 Started Oct. 2015 Storage Implementation Apr. 2016 Not Started FLEX Equipment:

Procure On-Site Equipment Aug. 2014 Started Develop Strategies with RRC Mar. 2015 Started Install Off-Site Delivery Station (if Not planned at Not planned at Necessary) this time this time Procedures:

PWROG issues NSSS-specific Dec. 2013 Started June 20 1 4 guidelines Create Site-Specific FSGs May 2015 Not Started Create Maintenance Procedures Feb. 2015 Not Started T raining: Develop Training Plan Nov. 2014 Not Started Training Complete Sep.2016 Not Started Full Site FLEX Implementation Oct. 2016 Started Submit Completion Report Dec. 2016 Not Started LlC-14-0021 Enclosure, Attachment 2 Page 1 LlC-13-0019, Enclosure, Appendix 8 Replacement Pages 8-21 and 8-24 LlC-13-0019 Enclosure, Appendix 8 In the event that DC power to the required monitoring instruments is lost, or if flooding renders instrument signals to the Control Room inoperable, alternate monitoring locations are being established.

The alternate locations for monitoring key parameters will include provisions for the use of portable measurement devices to read raw signals from transmitters, and procedural guidance for how to take the readings and convert them to usable parameters.

MODIFICATIONS REQUIRED:

Modification 11: Deployment of 10 kW FOG FLEX EQUIPMENT REQUIRED:

• FLEX 10 kW Diesel Generator

• Power Cabling.

REFERENCES:

1. DWG 1140S-A-6 (File No. 12163), Rev. 87, entitled Primary Plant Ground Floor plan P&ID 2. NRC Order EA-12-0S1, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 8-21 Revision 1 February 2014 LlC-13-0019 Enclosure, Appendix B Action 14 Provide Temporary Main Control Room Ventilation and Lighting OBJECTIVE:

The objective of this action is to provide the necessary temporary ventilation and lighting to the Main Control Room (MCR) in the event of a loss of control room air conditioning or depletion of the control room emergency lighting batteries.

This Action is to be taken if Action 13 is not feasible.

See the objectives of the MCR HVAC/Lighting Control in Action 13. STRATEGY:

FCS Procedure AOP-13 [Ref. 1] provides instructions for establishing temporary ventilation in the MCR under various conditions.

These actions will work in an ELAP scenario if power is provided by a FLEX power source. Temporary portable lights will be provided to supplement MCR lighting until the CR lighting panel can be re-powered by the large FLEX DG. FCS plans to provide a portable generator to support these actions. MODIFICATIONS REQUIRED:

None FLEX EQUIPMENT REQUIRED:

10 kW FLEX DG

REFERENCE:

1. AOP-13, Rev. 09, Loss of Control Room Air Conditioning B-24 Revision 1 February 2014