L-2015-214, Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

From kanterella
(Redirected from ML15246A143)
Jump to navigation Jump to search

Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML15246A143
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 08/25/2015
From: Costanzo C
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, L-2015-214
Download: ML15246A143 (7)


Text

0August FP*IL. 25, 2015 L- 2015-214 10 CFR 2.202 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 St. Lucie Units 1 and 2 Dockets 50-33 5 and 50-3 89 Florida Power & Light/St. Lucie Fifth Six Month Status Report in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number BA- 12-051')

References:

(1) U.S. Nuclear Regulatory Commission, Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately),

dated March 12, 2012, Accession No. ML12056A044.

(2) U.S. Nuclear Regulatory Commission, Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order BA- 12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012, Accession No. ML12221A339.

(3) NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order BA- 12-051,

'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"'" dated August, 2012, Accession No. ML12240A307.

(4) FPL Letter L-2012-384, dated October 25, 2012, Florida Power & Light (FPL)'s Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number BA- 12-051), Accession No. ML12300A420.

(5) FPL Letter L-2013-079, dated February 28, 2013, Florida Power & Light/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number BA 05 1), Accession No. ML13063A026.

(6) NRC Letter to Florida Power & Light St. Lucie Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Overall Integrated Plan for Reliable SFP Instrumentation (Order No. EA- 12-051) (TAC Nos. MF00090 and MF0091), dated July 16, 2013, Accession Number ML13196A079.

(7) FPL Letter L-2013-223, dated July 26, 2013, Florida Power & Light/St. Lucie's Response to Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation," Accession No. ML13219A838.

(8) FPL Letter L-2013-253, dated August 27, 2013, Florida Power & Light/St. Lucie's first Six-Month Status Report to the Overall Integrated plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to reliable Spent fuel Pool Instrumentation (Order Number BA- 12-051 ), Accession No .ML13242A006.

Florida Power &Light Company

  • t-L 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2015-214 Page 2 (9) NRC Letter to Florida Power & Light St. Lucie 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 Nos. MF0990 and MF0991) dated November 19, 2013, Accession No. ML13274A473.

(10) FPL Letter L-2013-061, dated February 28, 2014, Florida Power & Light/St. Lucie 's Second Six-Month Status Report to the Overall Integrated plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to reliable Spent fuel Pool Instrumentation (Order Number EA-12-05 1), Accession No. 14064A 193.

(11) FPL Letter L-2014-275 dated August 27, 2014, Florida Power & Light/St. Lucie Third Six Month Status Report in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051), Accession No. ML14253A185.

(12) FPL Letter L-2015-054 dated February 23, 2015, Florida Power & Light/St. Lucie Fourth Six Month Status Report in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number BA 051), Accession No. ML15071A265.

(13) FPL Letter L-2015-1 15 dated May 12, 2015, Florida Power & Light/St. Lucie Unit 1 Final Compliance with EA-12-05 1 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Accession No. ML15140A393.

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to FPL. Reference 1 was immediately effective and directs FPL to install reliable spent fuel pool level instrumentation. 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 NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the FPL initial status report regarding mitigation strategies. Reference 5 provided the FPL Overall 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 first, second, third, and fourth six month status reports were submitted in Reference 8, 10, 11, and 12. The purpose of this letter is to provide the fifth 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 Overall Integrated Plan, including 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 Mr. Eric Katzman, Licensing Manager, at (772) 467-7734.

L-2015-214 Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on ',*A" 25, 2015.

Respectfully submitted, Christopher R. Costanzo 6I~L~

Site Vice President St. Lucie Plant CRC/KWF CC: USNRC Regional Administrator, Region II USNRC Senior Resident Inspector, St. Lucie Units 1 and 2

Enclosure:

Fifth Six Month Status Report in Response to March 12, 2012 Commission Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-051)

L-2015-214 Enclosure Page 1 of 4 L-201 5-214 ENCLOSURE FLORIDA POWER & LIGHT COMPANY'S ST. LUCIE UNITS 1 AND 2 FIFTH SIX MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

L-2015-214 Enclosure Page 2 of 4

1. Introduction Florida Power & Light Company's (FPL) St. Lucie Units 1 and 2 developed an Overall Integrated Plan (Reference 5) documenting the modification with regard to reliable Spent Fuel Pool (SFP) instrumentation in response to Reference 1. This enclosure provides the fifth six-month update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2. Milestone Accomplishments Unit I has been certified to be in full compliance with NRC Order-12-051. All remaining Unit 2 items are proceeding on or ahead of schedule as noted in the Fifth Six Month Update and no issues are anticipated.
3. Milestone Schedule Status There currently are no changes to the Milestone Schedule provided in the Overall Integrated Plan (Reference 5). Any changes to the following target dates will be reflected in the six month updates:

The current milestones are: Unit 1 Unit 2 Commence Engineering and Design Complete Complete Complete Design Complete Complete Complete Procurement of SFP Instruments Complete Complete Complete Installation of SFP Instruments Complete Complete Instruments Operational and Training completed Complete 4Q 2015 Required implementation date: RF26 RF22 Complete 4Q 2015

4. Changes to Compliance Method There currently are no changes to the compliance method documented in the Overall Integrated Plan (Reference 5). Consistent with the requirements of Order EA-12-051 and the Order guidance documents, the six month reports will delineate any proposed changes to compliance methods.

5, Need for Relief/Relaxation and Basis for the Relief/Relaxation St. Lucie is not requesting relief from the requirements of Order EA-12-051 (Reference 1) or guidance document JLD-ISG-2012-03 (Reference 2) at this time.

Consistent with the requirements of Order EA-12-051 (Reference 1) and the guidance in NEI 12-02 (Reference 3), the six month reports will delineate progress made, any proposed changes in compliance methods, updates to the schedule, and if needed, requests for relief and their bases.

L-2015-214 Enclosure Page 3 of 4

6. Requests for Additional Information The NRC staff determined that additional information was required to enable the continued technical review of the NextEra Energy St. Lucie Plant's Overall Integrated Plan (OIP).

Responses to all open RAI were uploaded to the NRC e-portal in early November 2014 prior to the NRC on-site FLEX audit. At that time, all responses were final, except one, for which only preliminary values were available regarding the Total Irradiated Dose (TID) for the system transmitters. Since that time, final values have been calculated (Reference 12). Per a letter to all licensees, (Reference 13) the NRC stated that responses to RAIs were not to be provided via the Six Month Updates but instead, they should be directly uploaded to the CERTREC (e-portal) for NRC staff review. The final RAI responses were uploaded to the NRC ePortal in February of 2015. During the Unit 1 Final Compliance process for Order 12-049 and Order 12-051, a typographical error in the RAI response table was ascertained. A correct set of RAl responses was uploaded to the NRC ePortal in May of 2015. An identical set of RAI responses was provided with the Unit 1 Compliance Letter (Reference 16) for docketing.

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

References:

1. U.S. Nuclear Regulatory Commission, Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately),

dated March 12, 2012, Accession No. ML12056A044.

2. U.S. Nuclear Regulatory Commission, Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012, Accession No. ML12221A339.
3. NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"'" dated August, 2012, Accession No. ML12240A307.
4. FPL Letter L-2012-384, dated October 25, 2012, Florida Power & Light (FPL)'s Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)}, Accession No. ML12300A420.
5. FPL Letter L-2013-079, dated February 28, 2013, "Florida Power & Light/St. Lucie's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051)," Accession No. ML13063A026.
6. NRC Letter to Florida Power and Light St. Lucie Nuclear Plant, Units 1 and 2 Request for Additional Information Regarding Overall Integrated Plan for Reliable SFP Instrumentation (Order No. EA-12-051) (TAO Nos. MFOO09O and MFOO91), dated July 16, 2013, Accession Number ML13196A079.

L-2015-214 Enclosure Page 4 of 4

7. FPL Letter L-2013-223, dated July 26, 2013, Florida Power and Light St. Lucie's Response to Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-1 2-05 1, "Reliable Spent Fuel Pool Instrumentation," Accession No. ML13219A838.
8. FPL Letter L-2013-253, dated August 27, 2013, Florida Power & Light/St. Lucie's first Six-Month Status Report to the Overall Integrated plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to reliable Spent fuel Pool Instrumentation (Order Number EA 051), Accession No.ML13242A006.
9. NRC Letter to Florida Power and Light St. Lucie Nuclear Plant, Units 1 and 2 Interim Staff Evaluation and Request for Additional Information Regarding Spent Fuel Pool Instrumentation (TAC Nos. MF0990 and MF0991) dated November 19, 2013, Accession No. ML13274A473.
10. FPL Letter L-2014-061, dated February 28, 2014, Florida Power & Light/St. Lucie's second Six-Month Status Report to the Overall Integrated plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to reliable Spent fuel Pool Instrumentation (Order Number EA 051 ), Accession No.ML14064A193.
11. FPL Letter L-2014-275, dated August 27, 2014, Florida Power & Light/St. Lucie's Third Six-Month Status Report to the Overall Integrated plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to reliable Spent fuel Pool Instrumentation (Order Number EA 051), Accession No.ML.14253A1 84.
12. ENERCON calculation, FPLSL137-CALC-SFPI-001, St. Lucie Units 1 & 2 Dose to SFP Level Instrumentation Transmitter, Rev. 01.
13. NRC Letter dated March 26, 2014, Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051 [ML14083A620]
14. FPL Letter L-2015-054 dated February 23, 2015, Florida Power & Light/St. Lucie Fourth Six Month Status Report in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA 051), Accession No. ML15071A265
15. NRC Letter dated February 27, 2015, St. Lucie Plant, Units 1 and 2, Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0984, MF0985, MF0990, and MF0991), Accession No. ML15035A670
16. FPL Letter L-2015-115, dated May 12, 2015, Florida Power & Light/St. Lucie Unit 1 Final Compliance with EA-12-051 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation