CP-201401051, 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)

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)

ML14253A186
Person / Time
Site:	Comanche Peak
Issue date:	08/28/2014
From:	Madden F Luminant Generation Co, Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201401051, EA-12-051, TAC MF0862, TAC MF0863, TXX-14105
Download: ML14253A186 (5)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael.flores@luminant.com Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201401051 REF 10 CFR 2.202 Log # TXX-14105 August 28, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, 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) (TAC NOS. MF0862 AND MF0863)

REFERENCES:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012.

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.

4. Luminant Generation Company LLC's Letter TXX-12156, 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 25, 2012.

5. Luminant Generation Company LLC's Letter TXX-13040, 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.

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Comunission") issued an order (Reference 1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant Power to have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of specified levels in the pool water level conditions by trained personnel. 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, A member of the STARS Alliance Callaway

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U. S. Nuclear Regulatory Commission TXX-14105 Page 2 of 2 08/28/2014 Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided Luminant Power's initial status report regarding Reliable Spent Fuel Pool Instrumentation, as required by Reference 1. Reference 5 provided Luminant Power's integrated plan.

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. 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 attachments to this letter provide an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Carl B. Corbin at (254) 897-0121 or carl.corbin@luminant.com.

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

Executed on August 28, 2014.

Sincerely, Luminant Generation Company LLC Rafael Flores By:/ 2/"- a h .

/Fred W. Madden Director, External Affairs Attachment Comanche Peak Nuclear Power Plant (CPNPP), 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) c- William M Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Resident Inspectors, Comanche Peak

Attachment to TXX-14105 CPNPP Third Six Month Spent Fuel Pool Instrumentation Status Report Page 1 of 3 Comanche Peak Nuclear Power Plant (CPNPP), 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) 1 Introduction Comanche Peak Nuclear Power Plant developed an overall integrated plan (OIP) (Reference 1 [Refer to.

Section 10 of this attachment for a list of references.]), which includes a description of how compliance with the requirements described in Reference 2, Attachment 2 will be achieved. This attachment provides an update of milestone accomplishments since submittal of Reference 1, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

2 Milestone Accomplishments Since the second six month update (Reference 9), three additional milestones have been completed. SFP instrumentation procedures and training is in progress.

3 Milestone Schedule Status The following table provides an update to the milestone schedule. It provides the activity status of each item, and whether the expected completion date has changed. The dates are subject to change as design and implementation details are developed.

There were no changes to the original target completion dates.

Original Target Target Milestone Completion Activity Status Completion Date Date Changes Submit 60-day progress report 10/2012 Complete Submit overall integrated plan 2/2013 Complete Submit six-month updates Update 1 8/2013 Complete Update 2 2/2014 Complete Update 3 8/2014 Complete Update 4 2/2015 Not started Update 5 8/2015 Not started Update 6 2/2016 Not started Update 7 8/2016 Not started Request for Additional Information Submit RAI response to Reference 3 7/2013 Complete Submit RAI response to Reference 6 5/2014* Started Commence Engineering and Design 1Q2013 Complete Complete Design 2Q2014 Complete Receipt of SFP instruments 2Q2014 Complete Complete SFP Instrumentation Procedures 3Q2014 Started and Training SFP Instruments Operational 4Q2014 Not Started The response to Reference 6 is discussed in Sections 7 and 8

Attachment to TXX-14105 CPNPP Third Six Month Spent Fuel Pool Instrumentation S atus Report Page 2 of 3 4 Changes to Compliance Method None 5 Need for Relief and Basis for the Relief Luminant expects to comply with the implementation date in the )rder. No relief is being requested at this time.

6 Open Items from Overall Integrated Plan None 7 Changes to Overall Integrated Plan On July 3, 2013, Luminant Power responded (Reference 4) to an initial NRC Request for Additional Information (Reference 3) dated June 7, 2013. Selected RAI responses were updated in the First Six Month Update (Reference 5). In Reference 6 the NRC transmitted RAIs which subsumed the previously transmitted RAIs (Reference 3). Reference 7 corrected a date in Reference 6.

As a result of communications on February 25, 2014, between Luminant Power (Carl Corbin, et.al.) and the NRC Staff (Balwant Singal, et.al.) of the NRC Staff, the NRC agreed that it is acceptable to provide a written response to all RAIs in Reference 6 by May 30, 2014. In the interim, Luminant Power agreed to provide information for the RAIs from Reference 6 to the NRC using the ePortal virtual audit process.

This process will be similar to the ePortal virtual audit process currently being used for NRC Order EA-12-049 for mitigating strategies (ML13234A503).

On March 26, 2014, the NRC issued a letter (Reference 10) allowing plants to voluntarily participate in an audit based review process for responding to requests for information on order EA-12-051. Reference 10 notified licensees participating in the audit process not to formally submit their RAI responses on the docket but instead to put their responses and any other supporting information on their ePortals. CPNPP is participating in the audit process and has posted the requested information as agreed to with the NRC.

8 Open Items from the Request for Additional Information Luminant Power is participating in the audit based review as allowed by Reference 10. See Section 7 above for additional information.

9 Potential Safety Evaluation Report Impacts There are no potential impacts to the Safety Evaluation Report identified at this time.

Attachment to TXX-14105 CPNPP Third Six Month Spent Fuel Pool Instrumentation S atus Report Page 3 of 3 10 References The following references support the updates to the OIP describe. in this Attachment.

1. Luminant Generation Company LLC's Letter TXX-13040, 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

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

3. NRC Letter to Luminant Generation Company LLC, Comanche Peak Nuclear Power Plant, 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. MF0862 And MF0863), dated June 7, 2013

4. Luminant Generation Company LLC's Letter TXX-13103, R~sponse to Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify License with Regard to Reliable Spent Fuel Pool Implementation (Order Number EA-12-051), dated July 3, 2013

5. Luminant Generation Company LLC's Letter TXX-13130, 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) (TAC NOS. MF0862 AND MF0863),

dated August 28, 2013

6. NRC Letter to Luminant Generation Company LLC, Comanche Peak Nuclear Power 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 NOS. MF0862 and MF0863) dated November 4, 2013

7. NRC Letter to Luminant Generation Company LLC, Comanche Peak Nuclear Power Plant, Units 1 and 2 - Correction to Date related to 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 NOS. MF0862 and MF0863) dated November 19, 2013

8. Luminant Generation Company LLC's Letter TXX-13170, Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, Response to NRC Interim Staff Evaluation and Request for Additional Information Regarding the Overall Implementation Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NOS. MF0862 AND MF0863), dated November 19, 2013

9. Luminant Generation Company LLC's Letter TXX-14026, 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) (TAC NOS. MF0862 AND MF0863),

dated February 27, 2013

10. NRC letter to Operating Reactor Licensees, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014