RBG-47385, 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)
| ML13247A416 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/28/2013 |
| From: | Olson E Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RBG-47385 | |
| Download: ML13247A416 (8) | |
Text
da Entergy Operations, Inc.
River Bend Station Entergya 5485 U.S. Highway 61N St. Francisville, L.A70775 Tel 225-381-4374 Eric W. Olson Site Vice President RBG-47385 August 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852
SUBJECT:
Entergy'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)
River Bend Station - Unit 1 Docket No. 50-458 License No. NPF-47
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 (Agencywide Document Access and Management System (ADAMS) Accession No. ML12054A682) (RBC-51011)
- 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 (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 (ML12240A307)
- 4. Entergy'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 24, 2012 (RBG-47303) (ML12312A125)
- 5. Entergy letter to NRC, Overall Integrated Plan In Response To March 12, 2012, Commission Order Modifying License With Regard To Reliable SFP Instrumentation (Order Number EA-12-051), dated February 28, 2013 (RBG-47328) (ML13066A509)
Dear Sir or Madam:
On March 12, 2012, the NRC issued an order (Reference 1) to Entergy. Reference 1 was immediately effective and directs Entergy to install reliable spent fuel pool level instrumentation at River Bend Station. Specific requirements are outlined in Attachment 2 of Reference 1.
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RBG-47385 Page 2 of 3 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 also 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 identified in Reference 2. Reference 4 provided the Entergy initial status report regarding spent fuel pool instrumentation. Reference 5 provided the Entergy 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.
This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Joseph Clark, Manager- Licensing, at 225-381-4177.
I declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2013.
Sincerely, EWO/TAE/JAC/wjf
Attachment:
River Bend Station's (RBS) First Six-Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.
Arlington, TX 76011-4511 NRC Resident Inspector R-SB-14 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.
Austin, TX 78711-3326
RBG-47385 Page 3 of 3 cc: (continued)
Mr. Alan Wang, Project Manager U.S. Nuclear Regulatory Commission MS O-8B1 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission ATTN: Robert J. Fretz Jr.
Mail Stop OWFN/4A15A 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Robert L. Dennig Mail Stop OWFN/10E1 11555 Rockville Pike Rockville, MD 20852-2378 Department of Environmental Quality Office of Environmental Compliance Radiological Emergency Planning and Response Section ATTN: JiYoung Wiley P.O. Box 4312 Baton Rouge, LA 70821-4312 U. S. Nuclear Regulatory Commission ATTN: Ms. Lisa M. Regner Mail Stop OWFN/1 1F1 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Mr. Blake A. Purnell Mail Stop OWFN/12D20 11555 Rockville Pike Rockville, MD 20852-2378 U. S. Nuclear Regulatory Commission ATTN: Mr. Steven R. Jones Mail Stop OWFN/10A1 11555 Rockville Pike Rockville, MD 20852-2378
Attachment to RBG-47385 River Bend Station's (RBS) First Six-Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation
Attachment to RBG-47385 Page 1 of 4 River Bend Station's (RBS) First Six-Month Status Report for the Implementation of Order EA-12-051, Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation
- 1. Introduction Entergy developed an Overall Integrated Plan (Reference 1 in Section 8) for River Bend Station (RBS), 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.
Although not part of the original milestone schedule, NRC requests for additional information (RAIs) were received July 10, 2013 (Reference 3) and responded to on July 25, 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.
Revised Target Milestone Date Activity Status Completion Date Reliable SFPI Installed Spring 2015 Refueling In Progress Outage Respond to NRC RAls Dated Jul 26, 2013 See RAI Table July 3, 2013 (Reference 3) y Below
- 4. Changes to Compliance Method The current Level 2 elevation is now 107'-10 5/16" El. The previous Level 2 elevation was 10 ft. above the top of the spent fuel rack at 94'-10 5/16" El. This differs from the conceptual design RBS initially submitted to the NRC. The Level 2 elevation is raised to 107'-10 5/16" to account for non-special nuclear material stored above 94'-10 5/16" in the Spent Fuel Pool.
Attachment to RBG-47385 Page 2 of 4
- 5. Need for Relief/Relaxation and Basis for the Relief/Relaxation RBS 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 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. "River Bend Station 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 (ML13066A509)
- 2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ML12054A682)
- 3. "River Bend Station, Unit 1 - Request for Additional Information Regarding Overall Integrated Plan For Reliable Spent Fuel Pool Instrumentation (Order EA 12-051) (TAC No. MF0953)", dated July 3, 2013 (ML13179A193)
- 4. "Response to Request for Additional Information (RAI) for the Overall Integrated Plan (OIP) in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool (SFP) Instrumentation", dated July 25, 2013 (ML13217A092)
Attachment to RBG-47385 Page 3 of 4 RBS RAI Status RAI RAI Topic RAI Status Number Provide sketch depicting the elevation view of the proposed typical mounting arrangements for portions of the RAI-1 .a instrument channel consisting of permanent measurement Completed channel equipment. Indicate datum values and points related to Level 1, 2, and 3.
RAI-1.b Describe how level 2 will be adjusted to other than the Completed elevation provided in section 2.
Provide a clearly labeled sketch or marked-up plant drawing of the plan-view of the SFP area, depicting the RAI-2 SFP inside dimensions, the planned locations/placement of Open primary and back-up SFP level sensors and the proposed routing of the cables.
Provide Design Criteria that will be used to estimate total RAI-3.a loading on mounting devices. Also describe methodology Completed used to estimate total loading.
Provide description of the manner in which the level sensor RAI-3.b will be attached to the refueling floor or other support Completed structures.
Provide a description of the manner by which the RAI-3.c mechanical connections will attach the level instrument to Completed permanent SFP structures.
Provide a description of the method(s) intended to be RAI-4.a applied to demonstrate the reliability of the permanently Completed installed equipment.
Provide a description of the testing and/or analyses that will be conducted to provide assurance that the equipment will RAI-4.b perform reliably under the worst-case credible design basis Completed loading at the location where the equipment will be mounted.
Provide a description of the specific method or combination of methods that will confirm the reliability of the Completed RAI-4.c permanently installed equipment following seismic conditions.
Provide a description of how the two channels of the RAI-5.a proposed level 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 level measurement RAI-5.b system will be designed and installed to address Completed independence.
RAI-6.a Provide a description of the electrical AC power sources Completed and capacities for the primary and backup channels.
RAI-6.b Provide the design criteria that will be applied to size the Completed Completed
__A_-6.b_ battery.
Attachment to RBG-47385 Page 4 of 4 RAI-7.a Provide an estimate of the instrument channel accuracy Completed performance.
Provide a description of the methodology determining the RAI-7.b maximum allowed deviation from the instrument channel Completed design accuracy.
Provide a description of the capability and provisions the RAI-8.a proposed level sensing equipment will have to enable Completed periodic testing and calibration.
RAI-8.b Provide a description of how such testing and calibration Completed will enable the conduct of regular channel checks.
Provide a description of how functional checks will be RAI-8.c performed and the frequency of which they will be Completed conducted.
Provide a description of what preventative maintenance RAI-8.d tasks are required to be performed during normal operation Completed and the planned maximum surveillance interval.
Provide the specific location for the primary and backup Completed RAI-9.a instrument channel display.
Since both primary and backup display locations are not in RAI-9.b the main control room, please provide a description of the Open location for the primary and backup display.
Provide the reasons justifying why the locations selected RAI-9.c will enable the information from these instruments to be Completed considered "promptly accessible."
Provide a list of the operating procedures, calibration/test RAI-1O.a procedures, maintenance procedures, and inspection Completed procedures.
RAI-1 O.b Provide a brief description of the specific technical Completed objectives to be achieved within each procedure.
Provide further information describing the maintenance and testing program the licensee will establish and implement to RAM-l.a ensure that regular testing and calibration is performed and Completed verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
Provide a description of how the guidance in NEI 12-02 RAI- 1.b Section 4.3 regarding compensatory actions for one or both Completed non-functioning channels will be addressed.
Provide a description of the compensatory actions to be RAI-1 1.c taken in the event that one of the instrument channels Completed cannot be restored to functional status within 90 days.