CNS-15-013, Fourth 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)

Fourth 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)

ML15051A366
Person / Time
Site:	Catawba
Issue date:	02/16/2015
From:	Henderson K Duke Energy Carolinas, Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNS-15-013, EA-12-051
Download: ML15051A366 (7)

Text

Kelvin Henderson Vice President Catawba Nuclear Station

~ENERGY.

Duke Energy CN01VP I 4800 Concord Road York, SC 29745 CNS-15-013 o: 803.701.4251 f: 803.701.3221 February 16, 2015 U.S. Nuclear Regulatory Commission (USNRC)

Attention: Document Control Desk Washington, D.C. 20555-0001 Duke Energy Carolinas, LLC (Duke Energy) 10 CFR 50.4 Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Renewed License Numbers NPF-35 and NPF-52

Subject:

Fourth 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)

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession Number ML12054A679

2. NRC Interim Staff Guidance JLD-ISG-20J2-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12221A339

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, ADAMS Accession Number ML12240A307

4. Duke Energy letter, Duke Energy Carolinas,LLC, (Duke Energy)

Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 29, 2012, ADAMS Accession Number ML12307A022

5. Duke Energy letter, Duke Energy Carolinas,LLC, (Duke Energy)

Overall Integrated Plans in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated February 28, 2013, ADAMS Accession Number ML13086A095

6. Duke Energy letter, Duke Energy Carolinas,LLC, (Duke Energy), First Six-Month Status Reports in Response to March 12, 2012 Commission OrderModifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated August 26, 2013, ADAMS Accession Number ML13242A009

7. NRC letter, Catawba Nuclear Station, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regardingthe Overall Integrated Plan for Implementation of Order EA-12-051, Reliable .Spent Fuel Pool Instrumentation, dated October 28, 2013, ADAMS Accession Number ML13281A562 ~A~cO www.duke-energy.com

Document Control Desk Page 2 February 16, 2015

8. Duke Energy letter, Duke Energy Carolinas,LLC, (Duke Energy),

Second 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), dated February 26, 2014, ADAMS Accession Number ML14063A279

9. NRC Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA 051, dated March 26, 2014, ADAMS Accession Number ML14083A620

10. Duke Energy letter, Duke Energy Carolinas,LLC, (Duke Energy),

Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated August 14, 2014, ADAMS Accession Number ML14227A717 On March 12, 2012, the NRC issued Order EA-12-051 (Reference 1) to Duke Energy.

Reference 1 was immediately effective and directed Duke Energy to have a reliable indication of water level in spent fuel storage pools. Specific requirements were 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 pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the Duke Energy initial status report regarding spent fuel pool instrumentation. Reference 5 provided the Duke Energy overall integrated plan.

Reference 1 required submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provided direction regarding the content of the status reports. Reference 6 provided the first six-month status report for Catawba. Reference 8 provided the second six-month status report for Catawba.

Reference 10 provided the third six-month status report for Catawba. 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 enclosure to this letter 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.

In Reference 7, the NRC provided an Interim Staff Evaluation (ISE) which included a Request for Additional Information (RAI) to Catawba. The NRC requested that a response to the RAI be provided in the next six-month status report, with all information provided by September 30, 2014. Reference 9 instructed that responses to the RAI need not be formally submitted on the docket but instead can be placed on the plant-specific ePortal. Catawba did so and the NRC reviewed this information during their onsite audit the week of September 29, 2014.

-1 Document Control Desk Page 3 February 16, 2015 This submittal contains no new regulatory commitments and no revisions to existing regulatory commitments.

Should you have any questions regarding this submittal, please contact L.J. Rudy at (803) 701-3084.

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

Executed on February 16, 2015.

Very truly yours, Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Enclosure

Document Control Desk Page 4 February 16, 2015 xc (with enclosure):

V.M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 G.A. Hutto, III Senior Resident Inspector (Catawba)

U.S. Nuclear Regulatory Commission Catawba Nuclear Station G.E. Miller (addressee only)

NRC Project Manager (Catawba)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 G9A 11555 Rockville Pike Rockville, MD 20852-2738 J. Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453

Enclosure Fourth Six-Month Status Report (Order EA-12-051)

Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Renewed License Numbers NPF-35 and NPF-52 1

Catawba Nuclear Station Fourth Six-Month Status Report for the Implementation of Order EA-12-051 Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation I Introduction Catawba Nuclear Station developed an Overall Integrated Plan (Reference 1 in Section 7),

documenting the requirements to install reliable spent fuel pool level instrumentation in response to NRC Order EA-1 2-051. References 2, 8, and 10 in Section 7 provided the first, second, and third six-month status reports, respectively, for Catawba Nuclear Station. This enclosure provides an update of milestone accomplishments since the submittal of the third six-month update, including any changes to the compliance method, schedule, or the need for relief/relaxation and the basis, if any, that occurred during the period from July 28, 2014 to January 31, 2015 (hereafter referred to as "the update period").

2 Milestone Accomplishments No new milestones were completed during the update period.

3 Milestone Schedule Status There are no changes to the schedule as reported in Reference 1 of Section 7.

4 Changes to Compliance Method No changes were made during the update period.

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

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation There are no open items documented in the Overall Integrated Plan (OIP) or in the Interim Staff Evaluation (ISE). The ISE received (Reference 7 in Section 7) included Requests for Additional Information (RAIs). Reference 9 instructs that responses to the RAIs do not need to be formally submitted on the docket but instead can be placed on the Catawba Nuclear Station ePortal.

Catawba did so and the NRC reviewed this information during their onsite audit the week of September 29, 2014.

7 References The following references support the updates to the OIP described in this enclosure.

1. Duke Energy Letter, Duke Energy Carolinas,LLC, (Duke Energy), Overall Integrated Plans in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051), dated February 28, 2013 2

2. Duke Energy Letter, Duke Energy Carolinas,LLC, (Duke Energy), FirstSix-month Status Reports in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 26, 2013

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

4. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated August 29, 2012

5. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation",Revision 1, dated August 2012

6. Duke Energy Letter, Duke Energy Carolinas,LLC, (Duke Energy), Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1),

dated October 29, 2012

7. NRC Letter, Catawba Nuclear Station, Units I and 2 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall IntegratedPlan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MFI060 and MF1061), dated October 28, 2013

8. Duke Energy Letter, Duke Energy Carolinas,LLC, (Duke Energy), Second 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 February 26, 2014

9. NRC Letter, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014

10. Duke Energy Letter, Duke Energy Carolinas,LLC, (Duke Energy), Third 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 14, 2014 3