GNRO-2014/00013, 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)
| ML14059A083 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/28/2014 |
| From: | Kevin Mulligan Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, GNRO-2014/00013 | |
| Download: ML14059A083 (10) | |
Text
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~Entergy Entergy Operations, Inc.
P. O. Box 756' Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2014/00013 February 28, 2014 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Entergy's 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)
Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
- 1. NRC Order Number EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation, dated March 12,2012 (ML12054A682)
- 2. Entergy* Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 26,2013 (GNRO-2013/00016, ML13064A417)
Dear Sir or Madam:
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Operations, Inc. (Entergy). Reference 1 was immediately effective and directs Entergy to install reliable spent fuel pool level instrumentation.
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). The purpose of this letter is to provide the second 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 submittal, please contact Mr. Jeffery A. Seiter, Acting Regulatory Assurance Manager, at (601) 437-2344.
GNRO-2014/00013 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014.
Sincerely,
~r----
KJM/slw
Attachment:
Grand Gulf Nuclear Station's Second Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation cc: U. S. Nuclear Regulatory Commission AnN: Steven A. Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment to GNRO-2014/00013 Grand Gulf Nuclear Station's Second Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation
Attachment to GNRO-2014/00013 Page 1 of 7 Grand Gulf Nuclear Station's Second Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2 Milestone Accomplishments The following milestone(s) have been completed since August 15, 2013 and are current as of January 31, 2014:
- Respond to NRC RAls (received July 30, 2013)
- Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE) was received November 25, 2013 (Reference 3). The ISE contains 19 requests for additional information (RAls) that are due September 30,2015. NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation (ISE) questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4). Therefore, the RAls dated July 30, 2013 (Reference 5) are considered superseded by the RAls contained in the ISE.
3 Milestone Schedule Status The following provides an update to the schedule identified in Section 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.
Revised Target Activity Target Milestone Completion Status Completion Date Date Spring 2016 Install reliable SFPI Refueling Not started N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013) 2015
Attachment to GNRO-2014/00013 Page 2 of7 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).
5 Need for Relief/Relaxation and Basis for the Relief/Relaxation GGNS 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 As discussed in Section 2, GGNS has received an Interim Staff Evaluation that includes 19 RAls. Responses to the RAls are due by September 30,2015 and are provided in Section 9 of this six-month status report. The following table provides a status of any RAls documented in the Interim Staff Evaluation.
RAI# Response Status 1 In Progress 2 In Progress 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 In Progress 14 In Progress 15 In Progress 16 In Progress 17 In Progress 18 In Progress 19 In Progress 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6.
Attachment to GNRO-2014/00013 Page 3 of7 8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.
- 1. "Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051)," dated February 26,2013 (GNRO-2013/00016, ML13059A316).
- 2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012 (ML12054A735).
- 3. "Grand Gulf Nuclear Station, Unit 1 - Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC NO. MF0955)," dated November 25, 2013 (ML133168986).
- 4. "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 (ML133478030).
- 5. "Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)," dated July 30,2013 (GNRI-2013/00129).
Attachment to GNRO-2014/00013 Page 4 of?
9 Responses to the Interim Staff Evaluation Requests for Addition Information RAI#1 Please provide information on specific procedures controlling irradiated hardware stored in the SFP. Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SPF.
This response will be provided in a future update.
RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room.
This response will be provided in a future update.
RAI#3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
This response will be provided in a future update.
RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of ~he affected structures/equipment.
This response will be provided in a future update.
RAI#5 Please provide further information describing how other material stored in the SFP will not create adverse interaction with the SFP level instruments.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 5 of7 RAI#6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the sensor electronics (including power boxes, signal processors, and display panels) will be exposed. Provide documentation indicating the maximum total integrated dose the sensor electronics can withstand and how it was determined. Discuss the time period over which the analyzed total integrated dose was applied.
This response will be provided in a future update.
RAI#7 Please provide information indicating (a) the temperature ratings and whether the temperature ratings for the system electronics are continuous duty ratings; and (b) the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions, which include no AC power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems.
This response will be provided in a future update.
RAI#8 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under SOB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing required functions under this expected humidity condition.
This response will be provided in a future update.
RAI#9 Please provide a description of the specific method or combination of methods to be applied to demonstrate the reliability of the permanently installed equipment under BOB shock and vibration conditions.
This response will be provided in a future update.
RAI #10 For RAI #9 above, please provide the results for the selected methods, tests, and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 6 of?
RAI #11 Please provide analysis of the vendor analysis and seismic testing results to show that instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at GGNS, has been adequately demonstrated.
This response will be provided in a future update.
RAI #12 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.
This response will be provided in a future update.
RAI #13 Please provide the results of the calculation depicting battery backup duty cycle requirements, demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.
This response will be provided in a future update.
RAI #14 Please provide analysis verifying the proposed instrument performance is consistent with these estimated accuracy normal and 808 values. Demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.
This response will be provided in a future update.
RAI #15 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions. The NRC staff understands this allowed deviation will serve as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 7 of7 RAI #16 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.
This response will be provided in a future update.
RAI #17.
Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credit~d in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.
Additionally, include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event Describe whether personnel are continuously stationed at the display or monitor the display periodically.
This response will be provided in a future update.
RAI #18 Please provide a Ii~t of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
This response will be provided in a future update.
RAI #19 Please provide further information describing the maintenance and testing program the licen$ee will establish and implement to ensure that regular te~ting and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
This response will be provided in a future update.