RBG-47444, 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)

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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)
ML14064A263
Person / Time
Site: River Bend Entergy icon.png
Issue date: 02/26/2014
From: Olson E
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RBG-47444
Download: ML14064A263 (13)


Text

Entergy Operations, Inc.

River Bend Station Entergy 5485 U.S. Highway 61N St. Francisville, LA 70775 Tel 225-381 -4374 Eric W. Olson Site Vice President RBG-47444 February 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

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)

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)

RBG-47444 February 26, 2014 Page 2 of 4

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 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 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 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. Joseph Clark, Manager - Licensing, at 225-381-4177.

I declare under penalty of perjury that the foregoing is true and correct; executed on February 26, 2014.

Sincerely, EWO/JAC/dhw

Attachment:

River Bend Station's (RBS) Second 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 (continued)

RBG-47444 February 26, 2014 Page 3 of 4 NRC Resident Inspector R-SB-14 Central Records Clerk Public Utility Commission of Texas 1701 N. Congress Ave.

Austin, TX 78711-3326 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/11F1 11555 Rockville Pike Rockville, MD 20852-2378 (continued)

RBG-47444 February 26, 2014 Page 4 of 4 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/10AI 11555 Rockville Pike Rockville, MD 20852-2378

Attachment to RBG-47444 River Bend Station's (RBS) Second 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 RBG-47444 Page 1 of 8 River Bend Station's (RBS) Second 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 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 July 31, 2013 and are current as of January 31, 2014.

Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE) was received November 25, 2013 (Reference 3). The ISE also includes requests for additional information (RAIs) for NRC staff to complete its review. NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4). Therefore, the RAIs dated July 3, 2013 (Reference 5) are considered superseded by the RAls contained in the ISE. 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 Target Completion Activity Status Completion DateDate Reliable SFPI Installed Spring 2015 Refueling In Progress N/A Outage Respond to NRC RAIs Submitted Dated July 3, 2013 July 26, 2013 Subt N/A (Reference5) July 25, 2013 Respond to NRC RAIs contained in Interim Staff September 30, 2014 See Section 6 N/A Evaluation

Attachment RBG-47444 Page 2 of 8

4. Changes to Compliance Method There are no additional changes to the compliance method.
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 Interim Staff Evaluation As discussed in Section 2, River Bend has received an Interim Staff Evaluation that includes 17 RAIs. Responses to the RAIs are due by September 30, 2014 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 Submitted 2 In Progress 3 In Progress 4 Submitted 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 (Second RAI #9 in In Progress ISE) 12 In Progress 13 In Progress 14 In Progress 15 (#11 in ISE) In Progress 16 (Second RAI #12 in In Progress ISE) 17 (#16 in ISE) In Progress

7. Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6.

Attachment RBG-47444 Page 3 of 8

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 (ML13066A509)
3. "River Bend 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. MF0953)," dated November 25, 2013 (ML13316C065)
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 (ML13347B030)
5. "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)

Attachment RBG-47444 Page 4 of 8

9. Responses to the Interim Staff Evaluation Requests for Additional Information RAI #1 Please provide the updated sketch or marked-up plant drawing of the SFP level instrumentation arrangement. Include the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.

Figure 1 shows the approximate locations of the SFPI probes, the inside dimensions of the SFP, and the proposed cable routing.

Figure 1: SFP Plan View

Attachment RBG-47444 Page 5 of 8 RAI #2 Please provide the analyses verifying that seismic testing of the sensor/probe assemblies and the electronics units, and the analysis of the combined maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly exposed to the potential sloshing effects, show the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure.

This response will be provided in a future update.

RAI #3 For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

This response will be provided in a future update.

RAI #4 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. Also, please provide documentation indicating what is the maximum total integrated dose the sensor electronics can withstand and how it was determined. Please discuss the tirhe period over which the analyzed total integrated dose was applied.

The display/processors will be located on the 98' elevation in the Control Building. As shown in Figure 12.3-2 in the River Bend FSAR, this area is a Zone I radiation area with typical radiation doses less than 0.2 millirem per hour. The figure also shows that the Control Building is significantly far away from the Spent Fuel Building such that dose to the sensor electronics from lower pool levels does not need to be considered.

RAI #5 Please provide information indicating the maximum expected ambient temperature in the room in which the sensor electronics will be located under BDB conditions in which there is no ac power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems, and whether the sensor electronics is capable of continuously performing its required functions under this expected temperature condition.

This response will be provided in a future update.

Attachment RBG-47444 Page 6 of 8 RAI #6 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BDB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing its required functions under this expected humidity condition.

This response will be provided in a future update.

RAI #7 Please provide a description of the specific method or combination of methods you intend to apply to demonstrate the reliability of the permanently installed equipment under BDB shock and vibration conditions.

This response will be provided in a future update.

RAI #8 For RAI #7 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.

RAI #9 Please provide analysis of the vendor analysis and seismic testing results and show that SFP level instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at River Bend, has been adequately demonstrated.

This response will be provided in a future update.

RAI #10 Please provide the NRC staff with the final configuration of the power supply source for each channel so that the staff may conclude the two channels are independent from a power supply assignment perspective.

This response will be provided in a future update.

Attachment RBG-47444 Page 7 of 8 RAI #11 (second RAI #9 in ISE)

Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating 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 #12 Please provide analysis verifying the proposed instrument performance is consistent with these estimated accuracy normal and BDB values. Please demonstrate 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 #13 Please provide a description of the methodology to 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.

RAI #14 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.

Attachment RBG-47444 Page 8 of 8 RAI #15 (RAI #11 in ISE)

For the SFP level instrumentation displays located outside the main control room, please describe the evaluation used to validate the display location can be accessed without unreasonable delay following a BDB event. Include the time available for personnel to access the display as credited 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, please 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 BDB 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 #16 (Second RAI #12 in ISE)

Please provide a list 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 #17 (RAI #16 in ISE)

Please provide further information describing the maintenance and 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; Include a description of 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.

This response will be provided in a future update.