NOC-AE-13003020, Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation

Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation

ML13249A078
Person / Time
Site:	South Texas
Issue date:	08/27/2013
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NOC-AE-13003020, STI: 33730968, TAC MF0827, TAC MF0828
Download: ML13249A078 (7)

Text

Nuclear Operating Company South Texas ProlectElectric GenemAln$ Stwtion PO. Box 289 Wadsworth, Texas 77483 -

August 27, 2013 NOC-AE-1 3003020 10 CFR 2.202 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Unit 1 & 2 Docket Nos. STN 50-498, STN 50-499 Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828)

References:

1. NRC Letter, Eric Leeds to All Power Reactor Licensees, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (EA-12-051) (AE-NOC-1 2002271) (ML12054A679)

2. Letter, D. L. Koehl to NRC Document Control Desk, "Overall Integrated Plan Regarding Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (NOC-AE-1 3002959) (ML13070A006)

3. NRC letter, "South Texas Project, Units 1 and 2 - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) dated June 7, 2013 (AE-NOC-1 3002439) (ML13149A092)

4. Letter, G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) dated June 25, 2013 (NOC-AE-1 3003008) (ML13190A466)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) modifying licenses with regard to requirements for reliable spent fuel pool instrumentation. On February 28, 2013, STP Nuclear Operating Company (STPNOC) submitted an Overall Integrated Plan (Reference 2) in response to the NRC Order. By letter dated June 25, 2013 (Reference 4), STPNOC provided additional information requested by the NRC (Reference 3) in regard to our Overall Integrated Plan. The purpose of this letter is to provide our six-month status of our Overall Integrated Plan pursuant to Section IV, Condition C.2, of Reference 1.

The STPNOC status report is provided in the attachment. The report provides an update of milestone accomplishments required to implement the Order since submittal of the Overall STI: 33730968

NOC-AE-13003020 Page 2 Integrated Plan, including any changes to the compliance method and schedule. This report also provides an update to information provided under Reference 4.

There are no regulatory commitments in this letter.

If there are any questions, please contact Robyn Savage at 361-972-7438.

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

Executed on: IL,,%-sk z-7'2003 G. T. Powell Site Vice President

Attachment:

Six Month Status Report for the Implementation of Order Number EA-12-051 -

Reliable Spent Fuel Pool Instrumentation rds

NOC-AE-1 3003020 Page 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B13) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pefa P. O. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin U.S. Nuclear Regulatory Commission Richard A. Ratliff Director, Office of Nuclear Reactor Regulation Texas Department of State Health Services One White Flint North (MS 13 H 16M) 11555 Rockville Pike Robert Free Rockville, MD 20852-2738 Texas Department of State Health Services

Attachment NOC-AE-13003020 Page 1 of 4 Six Month Status Report for the Implementation of Order Number EA-12-051 -

Reliable Spent Fuel Pool Instrumentation

References:

1. Letter, D. L. Koehl to NRC Document Control Desk, "Overall Integrated Plan Regarding Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," February 28, 2013 (NOC-AE-1 3002959) (ML13070A006)

2. NRC Letter, Eric Leeds to All Power Reactor Licensees, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (EA-12-051) (AE-NOC-12002271) (ML12054A679)

3. NRC Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29, 2012 (ML12221A339)

4. 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 (ML122400399)

5. Letter, G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828),

June 25, 2013 (ML13190A466)

Reference 1 provided the Overall Integrated Plan which the STP Nuclear Operating Company ("STPNOC") will implement for Units 1 and 2 to comply with the requirements of NRC Order EA-1 2-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Reference 2), NRC Interim Staff Guidance JLD-ISG-2012-003, Revision 0, (Reference 3) and NEI Report 12-02, Revision 1 (Reference 4). This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan. This report also provides an update to information provided in STPNOC's response (Reference 5) to the NRC Request for Information under Reference 4.

The following status is based on information developed to date. Any changes to the following information that occur after completing and approving the final design for reliable spent fuel pool instrumentation will be provided in the periodic 6-month status reports required by Order EA-12-051.

Attachment NOC-AE-13003020 Page 2 of 4 SIX MONTH STATUS REPORT ORDER EA-12-051, RELIABLE SPENT FUEL POOL INSTRUMENTATION STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1. Introduction This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule. As discussed in Reference 1, any changes to the requirements in NRC JLD-ISG-2012-003 or NEI 12-02 may require relief from the requirements and schedule documented in the Overall Integrated Plan.

2. Milestone Accomplishments STPNOC has selected and entered into a purchase agreement to procure Spent Fuel Pool (SFP) level instruments that, when installed, will meet the criteria designated in the integrated response plan submitted on February 28, 2013.

3. Milestone Schedule Status There are no changes to the status of the milestones in the integrated plan that was submitted on February 28, 2013.

Unit 1 Milestones are as follows:

• Design/Engineering - September of 2014

• Purchase of instruments & equipment - February of 2015

• Receipt of equipment - June of 2015

• Unit 1 Installation & Functional Testing - October of 2015 Unit 2 Milestones are as follows:

• Design/Engineering - December of 2013

• Purchase of instruments & equipment - August of 2014

• Receipt of equipment - November of 2014

• Installation & Functional Testing -April of 2015

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan, however there is a correction to the information provided in the June 25, 2013 response to the NRC Request for Information (RAI). Specifically, in response to RAI 4a we stated "The VEGAPuls 62ER Through Air Radar sensor is similar in form, fit and function to the VEGAPuls 66 that was shock and vibration tested in accordance with MIL-S-901 D."

Further review determined that the VEGAPuls 66 was shock tested to MIL-S-901 D, however, it was vibration tested to MIL-STD-167-1.

Attachment NOC-AE-1 3003020 Page 3 of 4

5. Open Requests for Additional Information (RAIs)

Open RAIs Status NRC RAI-3c In progress as design work continues.

Please provide the following:

A site specific arrangement will be c) A description of the manner by which the mechanical provided in next 6 month update.

connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

NRC RAI-8b In progress as design work continues.

Please provide the following:

Progress will be reported in next 6 b) A description of how such testing and calibration will month update.

enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

NRC RAI-8c In progress as design work continues.

Please provide the following:

It has not been determined how c) A description of how functional checks will be the checks and testing will be performed, and the frequency at which they will be incorporated into current conducted. Describe how calibration tests will be processes or how frequent the performed, and the frequency at which they will be checks and testing will be conducted. Please provide a discussion as to how these performed.

surveillances will be incorporated into the plant surveillance program. Progress will be reported in next 6 month update.

NRC RAI-8d In progress as design work continues.

Please provide the following:

Progress will be reported in next 6 d) A description of what preventative maintenance tasks month update.

are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

Attachment NOC-AE-1 3003020 Page 4 of 4 Open RAIs Status NRC RAI-10 In progress as design work continues.

Please provide a description of the standards, guidelines and/or criteria that will be utilized to develop procedures Progress will be reported in next 6 for inspection, maintenance, repair, operation, abnormal month update.

response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments.

NRC RAI-11 In progress as design work continues.

Please provide the following:

Progress will be reported in next 6 a) Further information describing the maintenance and month update.

testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Please include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of how the guidance in NEI 12-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.

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

7. Potential Draft Safety Evaluation Impacts None