ML13247A412
| ML13247A412 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/28/2013 |
| From: | Dent J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.13.070, EA-12-051 | |
| Download: ML13247A412 (10) | |
Text
SEn tergy Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.
Site Vice President August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Pilgrim Nuclear Power Station'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)
Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35
REFERENCE:
- 1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", dated March 12, 2012 (PNPS Letter 1.12.015) (ADAMS Accession No. ML12054A679)
- 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 (ADAMS Accession No. ML12221A339)
- 3. Nuclear Energy Institute (NEI) 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation",
dated August 2012 (ADAMS Accession No. ML12240A307)
- 4. Pilgrim Nuclear Power Station Letter to NRC, "Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051 )", dated October 29, 2012 (PNPS Letter 2.12.074) (ADAMS Accession No. ML12312A469)
- 5. Pilgrim Nuclear Power Station Letter to NRC, "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 (PNPS Letter 2.13.014) (ADAMS Accession No. ML13063A097)
LETTER NUMBER 2.13.070 Aoc)(0 IIA&
PNPS Letter 2.13.070 Page 2 of 4
Dear Sir or Madam:
On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")
issued an order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy 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 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. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions. Reference 4 provided the Pilgrim Station initial status report regarding spent fuel pool instrumentation. Reference 5 provided the Pilgrim Station Overall Integrated Plan.
The purpose of this letter is to provide the first 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.
Should you have any questions concerning the content of this letter, please contact Mr.
Joseph R. Lynch at (508) 830-8403.
This letter contains no new regulatory commitments.
I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.
Sincerely,
- rll ohn A. Dent Jr.
JAD/rmb
Attachment:
Pilgrim Nuclear Power Station'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)
PNPS Letter 2.13.070 Page 3 of 4 cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-1415 NRC Resident Inspector Pilgrim Nuclear Power Station U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Washington, DC 20555-0001 Mr. Richard V. Guzman, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 Mr. John Giarrusso Jr.
Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 U. S. Nuclear Regulatory Commission Attn: Robert J. Fretz Jr.
OWFN, Mailstop # 4A1 5A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Robert L. Dennig OWFN, Mailstop # 1OE1 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Ms. Lisa M. Regner OWFN, Mailstop # 11 F1 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Blake A. Purnell OWFN, Mailstop # 12D20 11555 Rockville Pike
PNPS Letter 2.13.070 Page 4 of 4 Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission Attn: Mr. Steven R. Jones OWFN, Mailstop # 1OA1 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Jessica A. Kratchman OWFN - Mailstop 9 D2 11555 Rockville Pike Rockville, MD 20852-2378
ATTACHMENT To PNPS Letter 2.13.070 PILGRIM NUCLEAR POWER STATION'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)
Attachment Pilgrim Nuclear Power Station'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) 1 Introduction PNPS developed an Overall Integrated Plan (Reference 1), 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 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 milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013.
None.
However, although not part of the original milestone schedule, NRC requests for additional information (RAIs) were received June 20, 2013 (Reference 3) and responded to on July 19, 2013 (Reference 4). The response to the RAIs was added to the milestone schedule. Any additional RAI responses will be provided in future six-month status reports as necessary. The status of individual RAIs is indicated in the attached RAI table. The addition of this milestone and target completion date does not impact the Order implementation date.
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.
Milestone Target Completion Targ tCopeto ARevised Activity Status Target Completion eDate Date Reliable SFPI Installed Spring 2015 Refueling In Progress Outage NRC RAIs dated June 20, 2013 Submitted (Reference 3) July 19, 2013 July 19, 2013 4 Changes to Compliance Method The current Level 2 elevation is now 111'-3" El. The previous Level 2 elevation was 10 ft.
above the top of the spent fuel rack at 102'-8" El. This differs from the conceptual design PNPS initially submitted to the NRC. The Level 2 elevation is raised to 111 '-3" to account for non-special nuclear material stored above 102'-8" in the Spent Fuel Pool.
Page 2 of 6
PNPS's First Six-Month Status Report for the Implementation of SFPI August 2013 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation PNPS expects to comply with the NRC Order implementation date and no relief/relaxation is required at this time.
6 Open Items from Overall Integrated Plan and Draft Safety Evaluation None.
7 Potential Draft Safety Evaluation Impacts The NRC has not yet issued a Draft Safety Evaluation; therefore, 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. PNPS'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. (ADAMS Accession No. ML13063A097)
- 2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012. (ADAMS Accession No. ML12054A679)
- 3. "Pilgrim Nuclear Power Station - Request for Additional Information RE: Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)(TAC NO. MF0778)",
Dated June 20, 2013. (ADAMS Accession No. ML13165A276)
- 4. Response to Request for Additional Information for the Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Dated July 19, 2013. (ADAMS Accession No. ML13207A142)
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PNPS's First Six-Month Status Report for the Implementation of SFPI August 2013 PNPS RAI Status RAI Topic RAI Status Number Provide sketch depicting the elevation view of the proposed typical mounting arrangements for portions of the instrument RAI-1 .a channel consisting of permanent Completed measurement channel equipment. Indicate datum values and points related to Level 1, 2, and 3.
Describe how level 2 will be adjusted to RAI-1 .b other than the elevation provided in section Completed 2.
Provide Design Criteria that will be used to RAI-2.a estimate total loading on mounting devices. Completed Also describe methodology used to estimate total loading.
Provide description of the manner in which RAI-2.b the level sensor will be attached to the Completed refueling floor or other support structures.
Provide a description of the manner by RAI-2.c which the mechanical connections will attach the level instrument to permanent Completed SFP structures.
Address how other hardware stored in the RAI-2.d SFP will not create adverse interaction with Completed the fixed instrument location(s).
Provide a description of the method(s)
RAI-3.a intended to be applied to demonstrate of the Completed permanently installed equipment.
Provide a description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform RAI-3.b reliably under the worst-case credible design Completed basis loading at the location where the equipment will be mounted.
Provide a description of the specific method RAI-3.c or combination of methods that will confirm Completed the reliability of the permanently installed equipment following seismic conditions.
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PNPS's First Six-Month Status Report for the Implementation of SFPI August 2013 Provide a description of how the two channels of the proposed level RAI-4.a measurement system meet this requirement Completed so that the potential for a common cause event to adversely affect both channels is minimized to the extent practicable.
Provide further information on how each RAI-4.b level measurement system will be designed Completed and installed to address independence.
Provide the design criteria that will be Completed RAI-5 applied to size the battery.
RAI-6.a Provide an estimate of the instrument Completed channel accuracy performance. Completed Provide a description of the methodology RAI-6.b determining the maximum allowed deviation Completed from the instrument channel design.
Provide a description of the capability and provisions the proposed level sensing Completed RAI-7.a equipment will have to enable periodic testing and calibration.
Provide a description of how such testing RAI-7.b and calibration will enable the conduct of Completed regular channel checks.
Provide a description of how functional RAI-7.c checks will be performed and the frequency Completed of which they will be conducted.
Provide a description of what preventative RAI-7.d maintenance tasks are required to be Completed performed during normal operation and the planned maximum surveillance interval.
Provide a description of the standards, guidelines, and/or criteria that will be utilized RAI-8 to develop procedures for inspection, Completed maintenance, repair, operation, abnormal response, and administrative controls.
Provide further information describing the maintenance and testing program the licensee will establish and implement to RAI-9.a ensure that regular testing and calibration is Completed performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
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PNPS's First Six-Month Status Report for the Implementation of SFPI August 2013 Provide a description of how the guidance in RAI-9.b NEI 12-02 Section 4.3 regarding Completec compensatory actions for one or both non-functioning channels will be addressed.
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