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Entergy'S Third 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)
	ML14239A659
Person / Time
Site:	Grand Gulf
Issue date:	08/27/2014
From:	Kevin Mulligan; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-051, GNRO-2014/00055
	Download: ML14239A659 (13)
	v • d • e

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~Entergy Entergy Operations, Inc.

P. o. Box 756 Port Gibson, MS 39150 Kevin J. Mulligan Site Vice President Grand Gulf Nuclear Station Tel. (601) 437-7500 GNRO-2014/00055 August27,2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Third 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)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

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 (ML12054A682)

2. Entergy Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 26,2013 (GNRO-2013/00016, ML13064A417)

3. Entergy Letter to NRC, Entergy's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28,2013 (GNRO-2013/00061 )

4. Entergy Letter to NRC, Entergy's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2014 (GNRO-2014/00013)

Dear Sir or Madam:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Entergy Operations, Inc. (Entergy). Reference 1 was immediately effective and directs Entergy to install reliable spent fuel pool level instrumentation.

GNRO-2014/00055 Page 2,of 2 Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan (Reference 2). The purpose of this letter is to provide the third 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. James J. Nadeau, Regulatory Assurance Manager, at (601) 437-2103.

I declare under penalty of perjury that the foregoing is true and correct; executed on August 27, 2014.

Sincerely,

~L _

KJM/ras

Attachment:

Grand Gulf Nuclear Station's Third 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 cc: U. S. Nuclear Regulatory Commission AnN: Kriss Kennedy Deputy Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission ATTN: Mr. Alan Wang, NRR/DORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2014/00055 Grand Gulf Nuclear Station's Third 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

Attachment to GNRO-2014/00055 Page 1 of 10 Grand Gulf Nuclear Station's Third 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 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1 in Section 8), 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 January 31, 2014 and are current as of July 31,2014.

None 3 Milestone Schedule Status The following provides an update to the schedule identified in Section 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

Revised Target Activity Target Milestone Completion Status Completion Date Date Spring 2016 Install reliable SFPI Refueling Planned N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013) 2015

Attachment to GNRO-2014/00055 Page 2 of 10 4 Changes to Compliance Method Section 6 of the Overall Integrated Plan (OIP) states that cables in the SFP area are routed in seismically mounted rigid metal conduit. However, the cable between the spent fuel pool and the west wall of the Auxiliary Building is routed through the existing service cable trench that surrounds the SFP and then through a new protective steel channel along the ground before transitioning to rigid metal conduit along the wall. Small sections of flexible conduit protect the cable from the back of the probe and into the cable trench. Although cabling for each channel travels similar routes through the Auxiliary Building, each channel makes use of completely separate conduit supports and penetrations.

Section 7 of the 01 P refers to Attachment 1 for the approximate locations of the level instruments. Attachment 1 of the original OIP shall be superseded by Figure 1 in RAI #2 in Section 9 of this update. Refer to the response in RAI #2 of Section 9 for additional details regarding the SFPI probe arrangement and the separation between the two instrument channels.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation GGNS 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 GGNS has received an Interim Staff Evaluation that includes 19 RAls. Responses to the RAls are due by September 30, 2015 and some responses 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 See Section 9 2 See Section 9 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 See Section 9 10 See Section 9 11 In Progress 12 In Progress 13 See Section 9 14 See Section 9 15 See Section 9 16 See Section 9 17 See Section 9

Attachment to GNRO-2014/00055 Page 3 of 10 18 See Section 9 19 See Section 9 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6.

8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.

1. "Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051)," dated February 26,2013 (GNRO-2013/00016, ML13059A316).

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ML12054A679).

3. "Grand Gulf Nuclear 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. MF0955)," dated November 25, 2013 (ML133168986).

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 (ML133478030).

5. "Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051 )," dated July 30, 2013 (GNRI-2013/00129).

6. Entergy Letter to NRC, Entergy's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28,2013 (GNRO-2013/00061 )

7. Entergy Letter to NRC, Entergy's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2014 (GNRO-2014/00013)

Attachment to GNRO-2014/00055 Page 4 of 10 9 Responses to the Interim Staff Evaluation Requests for Additional Information RAI#1 Please provide information on specific procedures contr911ing irradiated hardware stored in the SFP. Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SFP.

Specific procedures controlling irradiated hardware stored in the SFP are as follows:

Special Nuclear Material S-02-3 Non-Nuclear Material S-02-301 Fuel Movement S-02-75 Control of Highly Irradiated Objects - EN-RP-123 Interim Staff Guidance JLD-ISG-2012-03 'Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation' states liThe NRC staff considers that the methodologies and guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, subject to the clarifications and exceptions in Attachment 1 to this ISG, are an acceptable means of meeting the requirements of Order EA-12-051."

NEI 12-02 R1 section 2.3.2, 'Level 2- level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck' defines Level 2.

Level 2 represents the range of water level where any necessary operations in the vicinity of the spent fuel pool can be completed without significant dose consequences from direct gamma radiation from the stored spent fuel. Level 2 is based on either of the following:

10 feet (+/- 1 foot) above the highest point of any fuel rack seated in the spent fuel pools, or

a designated level that provides adequate radiation shielding to maintain personnel radiological dose levels within acceptable limits while performing local operations in the vicinity of the pool. This level shall be based on either plant-specific or appropriate generic shielding calculations, considering the emergency conditions that may apply at the time and the scope of necessary local operations, including installation of portable SFP instrument channel components. Additional guidance can be found in EPA-400 (Reference 4),

USNRC Regulatory Guide 1.13 (Reference 5) and ANSIIANS-57.2-1983 (Reference 6).

Entergy has selected the 10 foot option which has been determined by the NRC to meet the requirements of the order with no further evaluation or review required.

Attachment to GNRO-2014/00055 Page 5 of 10 RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room.

The read-out/display device will be located in the lower cable spreading room. Figure 1 shows the approximate locations of the SFPI probes (in the northwest and southwest corners), the inside dimensions of the SFP, and the proposed cable routing. Along the walls where the conduits from each channel appear to run together, the conduits are separated vertically, using completely separate supports.

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NO.IAI2 SHIPPING CASK 8TS. POfe-(..ASI( WASHOOWN AREA I I I Figure 1: SFP Plan View RAI #3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.