ML13242A014

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Connecticut, Inc. & Millstone Power Station Units 2 and 3 Six-Month Status Report in Response to Letter Dated March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool
ML13242A014
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 08/23/2013
From: Grecheck E
Dominion Nuclear Connecticut
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051
Download: ML13242A014 (11)


Text

'Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 JiDomnio Web Address: www.dom.com 10 CFR 2.202 August 23, 2013 EA-12-051 Attention: Document Control Desk Serial No.: 12-165C U.S. Nuclear Regulatory Commission NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-336/423 License Nos.: DPR-65 DOMINION NUCLEAR CONNECTICUT, INC. NPF-49 MILLSTONE POWER STATION UNITS 2 AND 3 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
2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012
3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-1 2-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", Revision 1, dated August 2012
4. Dominion Nuclear Connecticut, Inc.'s Initial 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 October 25, 2012 (Serial No. 12-165A)
5. Dominion Nuclear Connecticut, Inc.'s Overall Integrated Plan 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 28, 2013 (Serial No. 12-165B)
6. Dominion Nuclear Connecticut, Inc.'s March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), Request for Additional Information (RAI) Response dated July 26, 2013 (Serial No.13-385)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Dominion Nuclear Connecticut, Inc. (DNC). Reference 1 was immediately effective and directs DNC 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 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 provided DNC's initial status report regarding mitigation strategies, Reference 5 provided DNC's overall integrated plan, and Reference 6 provided a response to a request for additional information (RAI).

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Serial No. 12-165C Docket Nos. 50-336/423 Order EA-1 2-051 Page 2 of 3 Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The six-month status reports (pursuant to Section IV, Condition C.2, of Reference 1),

delineate the progress made in implementing the requirements of Reference 1 and are provided as Attachments 1 and 2 (for Millstone Power Station Units 2 and 3, respectively) to this letter. The attached reports provide an update of milestone accomplishments since the response to the RAI (Reference 6), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Eugene S. Grecheck Vice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President Nuclear Engineering and Development of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this23 roday of Atk,,J tt*_. ,2013.

My Commission Expires:'be-eAwier 3,til;.t, CRAIG D SLY Notary Public IL F commonwealth Reg. # 7518653of Virginia rP/Nota'Public 20/

My Commission Expires December 31,

Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 2100 Renaissance Blvd.

Suite 100 King of Prussia, PA 19406-2713 Mr. J. S. Kim NRC Project Manager Millstone Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 C 2A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 D2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No. 12-165C Docket Nos. 50-336/423 Attachment I 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 Millstone Power Station Unit 2 Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 1, Page 1 of 3 Six Month Status Report for the Implementation of Order EA-12-051 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (Reference 1) documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI), in response to Order EA-12-051 (the Order) (Reference 2). This attachment 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 The following milestones have been completed since the development of the Overall Integrated Plan, and are current as of July 31, 2013.

Submit Overall Integrated Plan 0 Commence Engineering and Design 3 Milestone Schedule Status The following provides an update to milestone schedule to support the Overall Integrated Plan.

This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the Order implementation date for Millstone Power Station Unit 2.

4 Changes to Compliance Method By letter dated February 28, 2013, Serial No. 12-165B, DNC provided an Overall Integrated Plan (OIP) to address reliable SFP level instrumentation at Millstone Power Station Unit 2 as required by the Order. By letter dated June 26, 2013, Serial No.13-385, Mr. James Kim, the NRC Project Manager for Millstone Power Station, provided a Request for Additional

Millstone Power Station Unit 2 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 1, Page 2 of 3 Information (RAI) to Mr. David Heacock, President and Chief Nuclear Officer of Dominion, regarding the Millstone SFP LI system OIP. By letter dated July 26, 2013, Serial No.13-385, Dominion submitted the response to the RAI (Reference 3).

The following are changes to the information provided in the Millstone Unit 2 OIP and supplemented by the Millstone Unit 2 RAI (Reference 3). These changes do not alter Dominion's compliance method with NEI 12-02.

a) The SFP LI system continues to utilize Guided Wave Radar technology; however, the level sensor manufacturer has changed. Accordingly, there are design and installation configuration differences from those originally indicated in the OIP and the RAI response letter. Further details of the probe design and installation will be available upon completion of the final design, scheduled to be completed by December 2013 (see Milestone status table, Section 3), and will be forwarded to the NRC during the February 2014 six month status update. Subsequently, completion of procurement of the SFP instruments has been rescheduled to May 2014.

b) As indicated in the response to RAI l a, the formal calculation performed to verify that adequate water level is available to support net positive suction head (NPSH) has been completed and independently reviewed. Results of the calculation confirm the Level 1 value of 35.8 feet specified in RAI response letter is HIGHER than the minimum NPSH value of 16.75 feet (Reference 4).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DNC 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 Draft Safety Evaluation No update is required since there were no open items identified in the Overall Integrated Plan submittal and the Draft Safety Evaluation has not been issued.

7 Potential Draft Safety Evaluation Impacts 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 attachment:

1. "Dominion Nuclear Connecticut, Inc's Overall Integrated Plan 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 28, 2013.
2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

Millstone Power Station Unit 2 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 1, Page 3 of 3

3. "March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements for Reliable Spent Fuel Pool Instrumentation (Order number EA-12-051) Response to Request for Additional Information (RAI)," Serial No.13-385 dated July 26, 2013.
4. Calculation CALC-MISC-1 1798, Rev. 0, Add 0, "Dominion Fleet Spent Fuel Pool Levels to Provide Adequate NPSH to the Cooling Pumps with a Saturated Pool".

Serial No. 12-165C Docket Nos. 50-336/423 Attachment 2 Six Month Status Report for the Implementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Millstone Power Station Unit 3 Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 3 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 2, Page 1 of 3 Six Month Status Report for the Implementation of Order EA-12-051 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (Reference 1) documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI), in response to Order EA-12-051 (the Order) (Reference 2). This attachment 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 The following milestones have been completed since the development of the Overall Integrated Plan, and are current as of July 31, 2013.

0 Submit Overall Integrated Plan 0 Commence Engineering and Design 3 Milestone Schedule Status The following provides an update to milestone schedule to support the Overall Integrated Plan.

This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

Revised Milestone Completion Activity Target MC et Status Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete Commence Engineering and Design March 2013 Complete Complete Engineering and Design September Started December 2013 2013 Complete Procurement of SFP Instruments December Started May 2014 2013 Commence Installation of SFP Instruments June 2014 St e MStarted Not Level Measurement System Functional September 12014 started The revised milestone target completion dates do not impact the order implementation date for Millstone Power Station Unit 3.

4 Changes to Compliance Method By letter dated February 28, 2013, Serial No. 12-165B, DNC provided an Overall Integrated Plan (OIP) to address reliable SFP level instrumentation at Millstone Power Station Unit 3 as required by the Order. By letter dated June 26, 2013, Serial No.13-385, Mr. James Kim, the NRC Project Manager for Millstone Power Station, provided a Request for Additional

Millstone Power Station Unit 3 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 2, Page 2 of 3 Information (RAI) to Mr. David Heacock, President and Chief Nuclear Officer of Dominion, regarding the Millstone SFP LI system OIP. By letter dated July 26, 2013, Serial No.13-385, Dominion submitted the response to the RAI (Reference 3).

The following are changes to the information provided in the Millstone Unit 3 QIP and supplemented by the Millstone Unit 3 RAI (Reference 3). These changes do not alter Dominion's compliance method with NEI 12-02.

a. The SFP LI system continues to utilize Guided Wave Radar technology; however, the level sensor manufacturer has changed. Accordingly, there are design and installation configuration differences from those originally indicated in the OIP and the RAI response letter. Further details of the probe design and installation will be available upon completion of the final design, scheduled to be completed by December 2013 (see Milestone status table, Section 3), and will be forwarded to the NRC during the February 2014 six month status update. Subsequently, completion of procurement of the SFP instruments has been rescheduled to May 2014.
b. As indicated in the response to RAI 1b, the formal calculation performed to verify that adequate water level is available to support net positive suction head (NPSH) has been completed and independently reviewed. Results of the calculation, confirm the Level 1 value of 46.8 feet specified in RAI response letter is HIGHER than the minimum NPSH value of 46.7 feet (Reference 4).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DNC 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 Draft Safety Evaluation No update is required since there were no open items identified in the Overall Integrated Plan submittal and the Draft Safety Evaluation has not been issued.

7 Potential Draft Safety Evaluation Impacts 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 attachment.

1. "Dominion Nuclear Connecticut, Inc's Overall Integrated Plan 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 28, 2013.
2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

Millstone Power Station Unit 3 Serial No. 12-165C Docket Nos. 50-336/423 Order EA-12-051 Attachment 2, Page 3 of 3

3. "March 12, 2012 Commission Order Modifying Licenses With Regard To Requirements for Reliable Spent Fuel Pool Instrumentation (Order number EA-12-051) Response to Request for Additional Information (RAI)," Serial No.13-385 dated July 26, 2013.
4. Calculation CALC-MISC-11798, Rev. 0, Add 0, "Dominion Fleet Spent Fuel Pool Levels to Provide Adequate NPSH to the Cooling Pumps with a Saturated Pool".