CNL-14-192, Compliance Letter 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

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Compliance Letter 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
ML14303A561
Person / Time
Site: Watts Bar  Tennessee Valley Authority icon.png
Issue date: 10/29/2014
From: James Shea
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-14-192, EA-12-051, L44 141029 002, TAC MF0951, TAC MF1178
Download: ML14303A561 (9)
v • d • e


Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-14-192 October 29, 2014 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 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:

Compliance Letter 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. 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)
3. 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)

L44 141029 002

U.S. Nuclear Regulatory Commission CNL-14-192 Page 2 October 29, 2014

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 November 22, 2013 (ML13333B282)

5. 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)

6. 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 directed TVA to install reliable spent fuel pool level instrumentation (SFPLI). Specific requirements are outlined in Attachment 2, Requirements for Reliable Spent Fuel Pool Level Instrumentation at Operating Reactor Sites and Construction Permit Holder, of Reference 1.

On February 28, 2013, TVA submitted the Watts Bar Nuclear Plant (WBN), Units 1 and 2 overall integrated plan (OIP) (Reference 2). The NRC issued its Interim Staff Evaluation and Request for Additional Information (RAIs) regarding TVAs OIP on October 24, 2013 (Reference 3). On November 22, 2013, TVA provided an initial response to the Reference 3 RAIs (Reference 4) and provided additional RAI follow-up responses on January 10, 2014 (Reference 5) and on June 25, 2014 (Reference 6).

Reference 1 requires licensees to report to the Commission when full compliance with the requirements described in Attachment 2 of Reference 1 is achieved. The purpose of this letter is to report to the Commission pursuant to Section IV, Condition C.3, of Reference 1, that WBN, Units 1 and 2, has achieved full compliance to the requirements described in of Reference 1.

The Watts Bar Nuclear Plant has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051 (Reference 1). The information provided in Enclosure 1 to this letter documents full compliance with Reference 1 for WBN, Units 1 and 2, with one open issue. In a discussion between TVA (K. Casey) and

U.S. Nuclear Regulatory Commission CNL-14-192 Page 3 October 29, 2014 NRC (J. Paige), on October 28, 2014, TVA communicated its intention to submit a full compliance letter for Order EA-12-051 with one open item.

provides the commitment described in Enclosure 1. If you have any question regarding this submittal, please contact Gordon Arent at (423) 365-2004.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of October 2014.

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

Enclosure:

1.

Tennessee Valley Authority, Watts Bar Nuclear Plant Units 1 and 2, Spent Fuel Pool Instrumentation Compliance Document in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

2.

List of Commitments cc (Enclosures):

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 NRR JLD Project Manager - 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: 2014.10.29 20:33:00

-04'00'

E1-1 of 5 CNL-14-192 ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY, WATTS BAR NUCLEAR PLANT UNITS 1 AND 2 SPENT FUEL POOL INSTRUMENTATION COMPLIANCE DOCUMENT IN RESPONSE TO THE MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

INTRODUCTION At Watts Bar Nuclear Plant (WBN), Units 1 and 2, TVA has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Reference 1). The information provided herein documents full compliance for WBN, Units 1 and 2 pursuant to Section IV, Condition C.3, of Reference 1.

WBN, Units 1 and 2 have provided responses to the following Interim Staff Evaluation (ISE) Open and Confirmatory and Request for Additional Information (RAIs) Questions (Reference 9), Licensee Identified Open Items and Audit Questions/Audit Report Open Items per the following:

x ISE Open Items - There were no ISE Open Items x

ISE Confirmatory Items - There were no ISE Confirmatory Items x

ISE Request for Additional Information (RAI) Items - Complete pending NRC Closure. RAI responses were submitted to the NRC by References 8, 10, 11, and

14.

x Licensee Identified Open Items - Complete pending NRC Closure. Open Items were included in the third six month status report submitted to the NRC by Reference 16.

x Audit Questions/Audit Report Open Items - Complete pending NRC Closure The NRC issued the WBN, Units 1 and 2 Order EA-12-051 Audit Report on May 15, 2014 (Reference 13) and the Westinghouse Audit Report in support of Order EA-12-051 on August 18, 2014 (Reference 15).

TVA has identified a problem with the temperature qualification of the SFP level transmitters for seven days of operation. This problem has been entered in TVAs Corrective Action Program for resolution. TVA will provide to the NRC resolution to the temperature qualification problem by December 17, 2014. Compliance with specific elements of the SFP order is documented in Attachment 1 of this Enclosure.

E1-2 of 5 CNL-14-192 MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report 10/29/2012 (Reference 4)

Submit Overall Integrated Plan 02/28/2013 (Reference 5)

Submit 6 Month Updates:

Update 1 08/28/2013 (Reference 7)

Update 2 02/28/2014 (Reference 12)

Update 3 08/28/2014 (Reference 16)

RAI Response 09/06/2013 (Reference 8)

NRC ISE RAI Response 11/22/2013 (Reference 10)

NRC ISE RAI 1st Follow-up Response 01/10/2014 (Reference 11)

NRC ISE RAI 2nd Follow-up Response 06/25/2014 (Reference 14)

Modifications:

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

Create Procedures 06/30/2014 Training:

Develop Training Plan 06/30/2014 Training Complete 06/30/2014 Full Site SFPLI Implementation 06/30/2014 Submit Completion Report 10/29/2014

E1-3 of 5 CNL-14-192 ENCLOSURE 1 ATTACHMENT 1 ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Watts Bar Nuclear Plant (WBN), Units 1 and 2, as well as the Site Overall Integrated Plan (OIP) response submittal (Reference 5), the 6-Month Status Reports (References 7, 12, and 16), and additional docketed correspondence (References 6, 8, 10, 11, and 14), demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE WBN, Units 1 and 2 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.

INSTRUMENT DESIGN FEATURES - COMPLETE The design of the instruments installed at WBN, Units 1 and 2, comply with the requirements specified in the order and described in NEI 12-02 Industry Guidance for Compliance with NRC Order EA-12-051 (Reference 3). The instruments have been installed in accordance with the station design control process.

The instruments have been arranged to provide reasonable protection against missiles.

The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their designed accuracy following a power interruption and are design to allow for routine testing and calibration.

The instrument displays are located in the 6.9kv Shutdown Board Room A and B of the Control Building. This location is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.

PROGRAM FEATURES - COMPLETE Training for WBN, Units 1 and 2, has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures for WBN, Units 1 and 2, have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

E1-4 of 5 CNL-14-192 REFERENCES The following references support the WBN, Units 1 and 2 SFPI Compliance Document:

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)
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)

E1-5 of 5 CNL-14-192

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)

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 NRC to TVA, Watts Bar Nuclear Plant, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigations Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0950, MF1177, MF0951, and MF1178), dated May 15, 2014 (ML14128A129)
14. 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)

15. Letter from NRC to TVA, Watts Bar Nuclear Plant, Units 1 and 2 - Report for the Westinghouse Audit in Support of Reliable Spent Fuel Instrumentation Related to Order EA-12-0151 (TAC Nos. MF0951 and MF1178), dated August 18, 2014 (ML14211A346)
16. Letter from TVA to NRC, 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), dated August 28, 2014 (ML14248A484)

E2-1 of 1 CNL-14-192 ENCLOSURE 2 LIST OF COMMITMENTS

1. TVA will provide to the NRC resolution to the temperature qualification problem by December 17, 2014.
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