CNL-14-131, Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant

Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant

ML14248A484
Person / Time
Site:	Watts Bar
Issue date:	08/28/2014
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-14-131, EA-12-051, TAC MF0951, TAC MF1178 L44 140828 002
Download: ML14248A484 (8)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-131 August 28, 2014 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390 Watts Bar Nuclear Plant, Unit 2 Construction Permit No. CPPR-92 NRC Docket No. 50-391

Subject:

Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant (TAC Nos. MF0951 and MF1178)

References:

1. NRC Order Number EA-12-051, Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (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 (ML12221A339)

3. 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 (ML12240A307)

4. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Initial Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 29, 2012 (ML12307A105)

L44 140828 002

U.S. Nuclear Regulatory Commission Page 2 August 28, 2014

5. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant, dated February 28, 2013 (ML13063A440)

6. Letter from NRC to TVA, Watts Bar Nuclear Station, Unit 1 and Unit 2 -

Request for Additional Information Related to Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0951 and MF1178), dated August 2, 2013 (ML13204A231)

7. Letter from TVA to NRC, Tennessee Valley Authority Watts Bar Nuclear Plants First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2013 (ML13261A038)

8. Letter from TVA to NRC, Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0951 and MF1178), dated September 6, 2013 (ML13254A065)

9. Letter from NRC to TVA, Watts Bar Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0951 and MF1178), dated October 24, 2013 (ML13275A373)

10. Letter from TVA to NRC, Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0951 and MF1178), dated November 22, 2013 (ML13333B282)

11. Letter from TVA to NRC, Follow-up Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0951 and MF1178), dated January 10, 2014 (ML14014A137)

U.S. Nuclear Regulatory Commission Page 3 August 28, 2014

12. Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant (TAC Nos. MF0951 and MF1178), dated February 28, 2014 (ML14064A238)

13. Letter from TVA to NRC, Follow-up Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0951 and MF1178), dated June 25, 2014 (ML14177A526)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directs TVA to install reliable spent fuel pool level instrumentation (SFPLI). 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 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the TVA initial status report regarding SFPLI strategies. Reference 5 provided the TVA Watts Bar Nuclear Plant, Units 1 and 2 overall integrated plan. On August 2, 2013, the NRC issued a request for additional information (RAI) (Reference 6) and TVA provided its response on September 6, 2013 (Reference 8).

The NRC issued its Interim Staff Evaluation and RAIs regarding TVAs overall integrated plan on November 13, 2013 (Reference 9). On November 22, 2013, TVA provided an initial response to the Reference 9 RAIs (Reference 10) and provided additional RAI follow-up responses on January 10, 2014 (Reference 11) and on June 25, 2014 (Reference 13).

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. TVA submitted the first six-month update on August 28, 2013 (Reference 7) and the second six-month update on February 28, 2014 (Reference 12).

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 Enclosure provides an update of milestone accomplishments since submittal of the second six-month status report, including any changes to the compliance method or schedule.

The enclosure describes the plans that TVA will use to meet the regulatory requirements outlined in Attachment 2 of Reference 1, but does not identify any additional actions to be taken by TVA. Therefore, this letter contains no regulatory commitments.

U.S. Nuclear Regulatory Commission Page 4 August 28, 2014 If you have any question regarding this submittal, please contact Kevin Casey at (423) 751-8523.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2014.

Respectfully, J. W. Shea Vice President, Nuclear Licensing

Enclosure:

Tennessee Valley Authority Watts Bar Nuclear Plants Third Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) cc (Enclosure):

NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRR JLD Director - NRC Headquarters NRC Regional Administrator - Region II NRC Project Manager - Watts Bar Nuclear Plant, Unit 1 NRC Project Manager - Watts Bar Nuclear Plant, Unit 2 NRC Senior Resident Inspector - Watts Bar Nuclear Plant J. W. Shea Digitally signed by J. W. Shea DN: cn=J. W. Shea, o=Tennessee Valley Authority, ou=Nuclear Licensing, email=jwshea@tva.gov, c=US Date: 2014.08.28 14:40:35 -04'00'

Page 1 of 4 ENCLOSURE TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT THIRD SIX-MONTH STATUS REPORT IN RESPONE TO THE MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051) 1 Introduction Watts Bar Nuclear Plant (WBN) developed an Overall Integrated Plan (Reference 1 in Section 8 of this enclosure), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPLI), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the second six-month status report (Reference 8), including any changes to the compliance method or schedule.

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, 2014.

x WBN completed installation of the Unit 1 and 2 SFPLI on June 27, 2014 3

Milestone Schedule Status The following updates the 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.

The milestone target completion dates do not impact the order implementation date.

Page 2 of 4 Milestone Target Completion Date as Stated in the Second Six-Month Update (Reference 8)

Activity Status Revised Target Completion Date Submit 60 Day Status Report 10/29/2012 Complete Submit Overall Integrated Plan 02/28/2013 Complete Submit 6 Month Updates:

Update 1 08/28/2013 Complete Update 2 02/28/2014 Complete Update 3 08/28/2014 Complete RAI Response 09/06/2013 Complete NRC ISE RAI Response 11/22/2013 Complete NRC ISE RAI1st Follow-up Response 01/10/2014 Complete NRC ISE RAI 2nd Follow-up Response 06/25/2014 Complete Modifications:

Unit 1 Design Engineering 09/27/2013 Complete Unit 1 Implementation 06/27/2014 Complete Unit 2 Design Engineering 09/27/2013 Complete Unit 2 Implementation 06/27/2014 Complete Procedures:

Create Procedures 06/30/2014 Complete Training:

Develop Training Plan 06/30/2014 Complete Training Complete 06/30/2014 Complete Full Site SFPLI Implementation 06/30/2014 Complete Submit Completion Report 10/12/2014 Not Started 4

Changes to Compliance Method There are no other changes to the compliance method as documented in the Overall Integrated Plan (Reference 1) and Section 4 of the first six-month update (Reference 7).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Watts Bar Nuclear Plant (WBN) expects to comply with the order implementation date and no relief/relaxation is required at this time.

Page 3 of 4 6

Open Items from Overall Integrated Plan and NRC Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the NRC Evaluation and the status of each item.

Overall Integrated Plan Open Item Status OI-1) TVA will complete an instrument channel uncertainty calculation and document instrument channel accuracy and calibration requirements.

Closed - See Reference 8, RAI

1. 15, RAI #16 and RAI #17 responses.

OI-2) TVA plans to utilize Guided Wave Radar technology. Confirm final technology selection after contracts are complete.

Closed - Guided Wave Radar technology was utilized.

OI-3) Confirm that the sensor cable and light weight at the bottom of sensor cable will not damage the SFP liner from impact during seismic event.

Closed - See Reference 8, RAI

1. 4, RAI #5 and RAI #6 responses.

OI-4) After detailed engineering design is complete, confirm that SFP level channel components and cable routing will be contained within seismic structures such that the installation will comply with the reasonable protection guidance of NEI 12-06.

Closed - See Reference 8, RAI #4 response.

NRC Evaluation Open Item Status None N/A 7

Potential NRC Evaluation Impacts There are no potential impacts to the NRC Evaluation identified at this time.

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

1. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant, dated February 28, 2013. (ML13063A440)

2. Letter from NRC to TVA, Watts Bar Nuclear Station, Unit 1 and Unit 2 - Request for Additional Information Related to Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0951 and MF1178), dated August 2, 2013. (ML13204A231)

3. Letter from TVA to NRC, Tennessee Valley Authority Watts Bar Nuclear Plants First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2013. (ML13261A038)

Page 4 of 4

4. Letter from TVA to NRC, Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0951 and MF1178), dated September 6, 2013.

(ML13254A065)

5. Letter from NRC to TVA, Watts Bar Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No.

MF0951 and MF1178), dated October 24, 2013. (ML13275A373)

6. Letter from TVA to NRC, Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0951 and MF1178), dated November 22, 2013.

(ML13333B282)

7. Letter from TVA to NRC, Follow-up Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0951 and MF1178), dated January 10, 2014.

(ML14014A137)

8. Letter from TVA to NRC, Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Watts Bar Nuclear Plant (TAC Nos. MF0951 and MF1178), dated February 28, 2014.

(ML14064A238)

9. Letter from TVA to NRC, Follow-up Response to NRC Request for Additional Information Related to Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0951 and MF1178), dated June 25, 2014.

(ML14177A526)

9.

RAI Response On October 24, 2013, the NRC issued RAIs with its Interim Staff Evaluation (Reference 5).

TVA provided responses to the RAIs on November 22, 2013 (Reference 6),

January 10, 2014 (Reference 7) and June 25, 2014 (Reference 9).