ML13247A281

Cooper Nuclear Station Nebraska Public Power District'S First 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)

ML13247A281
Person / Time
Site:	Cooper
Issue date:	08/27/2013
From:	Limpias O A Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NLS2013078
Download: ML13247A281 (6)

Text

NNebraska Public Power DistrictAlways there when you need usNLS2013078 August 27, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001

Subject:

Nebraska Public Power District's First Six-Month Status Report in Response toMarch 12, 2012, Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA- 12-05 1)Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation,"

dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with OrderEA- 12-051, Reliable Spent Fuel Pool Instrumentation,"

Revision 0, datedAugust 29, 20123. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA- 12-051,"To Modify Licenses with Regard to Reliable Spent Fuel PoolInstrumentation,""

Revision 1, dated August 20124. Nebraska Public Power District's Initial Status Report in Response to March12, 2012, Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051),

dated October26, 2012 (NLS20121 11)5. Cooper Nuclear Station's Overall Integrated Plan in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Reliable SpentFuel Pool Instrumentation (Order Number EA- 12-05 I), dated February 28,2013 (NLS2013026)

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission issued an Order (Reference

1) toNebraska Public Power District (NPPD). Reference 1 was immediately effective and directsNPPD to install reliable spent fuel pool level instrumentation.

Specific requirements are outlinedin Attachment 2 of Reference 1.COOPER NUCLEAR STATIONP.O. Box 98 /Brownville, NE 68321-0098 Telephone:

(402) 825-3811

/ Fax: (402) 825-5211www.nppd.com NLS2013078 Page 2 of 3Reference 1 required submission of an initial status report 60 days following issuance of the finalinterim 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 providedNPPD's initial status report for Cooper Nuclear Station (CNS) regarding reliable spent fuel poolinstrumentation.

Reference 5 provided CNS' overall integrated plan.Reference I requires submission of a status report at six-month intervals following submittal ofthe overall integrated plan. Reference 3 provides direction regarding the content of the statusreports.

The purpose of this letter is to provide the first six-month status report pursuant toSection IV, Condition C.2, of Reference 1, that delineates progress made in implementing therequirements 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 David Van Der Kamp, Licensing

Manager, at (402) 825-2904.

I declare under penalty of perjury that the foregoing is true and correct.Executed on: -7"/Sincere(~

Vice 4President

-1uclear andChief Nuclear Officer/bk

Attachment:

Cooper Nuclear Station's First Six-Month Status Report for theImplementation of Order EA- 12-051, Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation cc: Regional Administrator, w/attachment USNRC -Region IVDirector, w/attachment USNRC -Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC -NRR Project Directorate IV- 1 NLS2013078 Page 3 of 3Senior Resident Inspector, w/attachment USNRC -CNSNPG Distribution, w/attachment CNS Records, w/attachment NLS2013078 Attachment Page 1 of 3Attachment Cooper Nuclear Station's First Six-Month Status Report for theImplementation of Order EA-12-051, Order Modifying Licenses withRegard to Reliable Spent Fuel Pool Instrumentation Introduction Nebraska Public Power District (NPPD) developed an overall integrated plan for Cooper NuclearStation (Reference 1), documenting the requirements to install reliable spent fuel pool levelinstrumentation, in response to Reference

2. This attachment provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to thecompliance method, schedule, or need for relief/relaxation and the basis, if any.Milestone Accomplishments The following milestone(s) have been completed since the development of the overall integrated plan (Reference 1), and are current as of July 30, 2013:S0A preliminary Scoping Study was completed on February 15, 2013.Purchase order 4500161756 for supply of the reliable spent fuel pool instrumentation system material was issued to Mohr Test and Measurement, LLC on July 15, 2013.Milestone Schedule StatusThe following provides an update to the milestone schedule to support the overall integrated plan. This section provides the activity status of each item, and the expected completion datenoting any change. The dates are planning dates subject to change as design and implementation details are developed.

Target RevisedMilestone Completion Activity Status TargetDate Completion DateSubmit 60 Day Status Report Oct 2012 CompleteSubmit Overall Integrated Plan Feb 2013 CompleteSubmit 6 Month Updates:Update I Aug 2013 CompleteUpdate 2 Feb 2014 Not StartedUpdate 3 Aug 2014 Not StartedUpdate 4 Feb 2015 Not StartedUpdate 5 Aug 2015 Not Started NLS2013078 Attachment Page 2 of 3RevisedTarget TargetMilestone Completion Activity Status Completion Date DateUpdate 6 Feb 2016 Not StartedUpdate 7 Aug 2016 Not StartedModifications:

Complete Scoping Study Feb 2013 CompleteGenerate Detailed Design Oct 2014 Not StartedComplete Refueling 28 Outage Nov 2014 Not StartedWalkdowns Complete Procurement of Parts Dec 2014 StartedComplete Detailed Design Oct 2015 Not StartedComplete Installation Outage Oct 2016 Not StartedComplete Installation/Testing Outage Nov 2016 Not StartedIn-service/Mod Complete Nov 2016 Not StartedProcedures:

Create Procedures June 2016 Not StartedTraining:

Develop Training Plan Aug 2016 Not StartedTraining Complete Oct 2016 Not StartedChanges to Compliance MethodSection 4.1 of the overall integrated plan submitted on February 28, 2013, described themeasurement range of the system from one foot above normal level of the pool to one foot belowthe top of the fuel rack. In discussion with the system supplier, it has been determined thatextension of the level system below the top of the fuel rack could create the risk of physicalcontact between the system probe and the rack. For this reason, the system probe will stopapproximately six inches above the top of the rack. This will still allow the system toconservatively measure to level three within + 12 inch accuracy required by NEI 12-02, IndustryGuidance for Compliance with Nuclear Regulatory Commission (NRC) Order EA- 12-051, "ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation."

NLS2013078 Attachment Page 3 of 3Section 6.5 of the overall integrated plan submitted on February 28, 2013, described the variouspower supply options for the primary and backup instrument

channels, including an internalbattery for each channel that will supply power for between four and twenty-four hours, and anexternal battery that will provide power up to seven days. During the system development

process, Mohr has eliminated the internal

battery, but the seven day external battery remains foreach channel.Need for Relief/Relaxation and Basis for the Relief/Relaxation NPPD expects to comply with the Order implementation date and no relief/relaxation is requiredat this time.Open Items from Overall Integrated Plan and Draft Safety Evaluation None.Potential Draft Safety Evaluation ImpactsThere are no potential impacts to the Draft Safety Evaluation identified at this time.References The following references support the updates to the overall integrated plan described in thisattachment.

1. Cooper Nuclear Station's Overall Integrated Plan in Response to March 12, 2012,Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA- 12-051),"

dated February 28, 2013.2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable SpentFuel Pool Instrumentation,"

dated March 12, 2012.