ET 15-0006, Operating Corporation, Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

Operating Corporation, Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

ML15063A030
Person / Time
Site:	Wolf Creek
Issue date:	02/24/2015
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ET 15-0006
Download: ML15063A030 (5)

Text

W0LF CREEK NUCLEAR OPERATING CORPORATION Jaime H. McCoy February 24, 2015 Vice President Engineering ET 15-0006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1) Letter dated March 12, 2012, from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation"

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 EA 051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"," Revision 1, dated August 2012

4) Letter ET 12-0028, dated October 29, 2012, from J. P. Broschak, WCNOC, to USNRC

5) Letter WO 13-0015, dated February 28, 2013, from R. A. Smith, WCNOC, to USNRC

6) Letter ET 13-0026, dated August 28, 2013, from J. P. Broschak, WCNOC, to USNRC

7) Letter ET 14-0010, dated February 26, 2014, from J. P. Broschak, WCNOC, to USNRC

8) Letter ET 14-0025, dated August 21, 2014, from C. 0. Reasoner, WCNOC, to USNRC

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's Fourth Six-Month Status Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" fVoOI P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 15-0006 Page 2 of 3 Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Wolf Creek Nuclear Operating Corporation (WCNOC): Reference 1 was immediately effective and directs WCNOC to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

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 (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the WCNOC initial status report regarding mitigation strategies.

Reference 5 provided the WCNOC OIP. References 6, 7, and 8 provided the first, second and third six-month status report for the implementation of Order EA-1 2-051, respectively.

Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the fourth 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 submittal of Reference 8, including changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Mr. Steven R. Koenig at (620) 364-4041.

Sincerely, Jaime H. McCoy JHM/rlt Attachment cc: M. L. Dapas (NRC), w/a C. F. Lyon (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 15-0006 Page 3 of 3 STATE OF KANSAS )

SS COUNTY OF COFFEY )

Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

JaimeeH. cCoy Vice Pre ient Engineering SUBSCRIBED and sworn to before me this 2 ;day of ,2015.

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Attachment to ET 15-0006 Page 1 of 2 Wolf Creek Nuclear Operating Corporation's Fourth Six-Month Status Report for the Implementation of Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation"

1. Introduction Wolf Creek Nuclear Operating Corporation (WCNOC) developed an Overall Integrated Plan (OIP) (Reference 1), documenting the modification with regard to Reliable Spent Fuel Pool (SFP) Instrumentation in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the third six-month status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments WCNOC has issued the design change package and begun the installation process.

3. Milestone Schedule Status There are no changes to the status of the milestones submitted in the OIP (Reference 1).

Provided is the activity status of each item, and whether the expected completion date has changed. The dates are planning dates and are subject to change as design and implementation details are developed.

Italicized text denotes that a Milestone was updated since the third six-month status update.

Target Revised Milestone Completion Activity Status Target Date Completion Date Commence Engineering and Design 1Q2013 Complete -

Complete Generic Design 4Q2013 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 -

Receipt of SFP Instruments 3Q2014 Complete -

Complete Site Specific Design 3Q2014 Complete -

Complete SFP InstrumentationProcedures 4Q2014 Complete

& Training SFP Instruments Operational 1Q2015 Started -

Attachment to ET 15-0006 Page 2 of 2

4. Changes to Compliance Method No changes to the compliance method have been made since the previous update (Reference 3).

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation WCNOC expects to comply with the order implementation date and no relief/relaxation is required at this time.

6. Open Request for Additional Information (RAI)

Subsequently, the NRC issued an Interim Staff Evaluation and RAI (Reference 4) on October 29, 2013. Reference 5 announced the transition to an audit based review process, and notified each licensee participating in the audit not to formally submit their RAI responses on the docket but instead, put their responses and any other supporting information on their ePortals by the date identified in their Interim Staff Evaluations to support the staffs review process. WCNOC supports the use of the audit process for responding to the staff's questions pertaining to Order EA-12-051.

References

1. WCNOC Letter WO 13-0015, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements For Reliable Spent Fuel Pool Instrumentation," February 28, 2013. ADAMS Accession No. ML13071A419.

2. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," March 12, 2012. ADAMS Accession No. ML12056A044.

3. WCNOC Letter ET 14-0010, "Wolf Creek Nuclear Operating Corporation's Third Six Month Status Report for the Implementation of Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," August 21, 2014.

ADAMS Accession No. ML14246A189.

4. Letter from C. F. Lyon, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0781)," October 29, 2013. ADAMS Accession No. MLI13295A681.

5. Letter from J. R. Davis, USNRC, to A. C. Heflin, WCNOC, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051," March 26, 2014. ADAMS Accession No. ML14083A620.