GNRO-2016/00008, Sixth 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)

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Sixth 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)
ML16056A627
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 02/25/2016
From: Kevin Mulligan
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, GNRO-2016/00008
Download: ML16056A627 (9)
v • d • e


Text

~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-2016/00008 February 25, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Sixth 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)
5. Entergy Letter to NRC, Entergy's Third 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 27,2014 (GNRO-2014/00055)

GNRO-2016/00008 Page 2 of 3

6. Entergy Letter to NRC, Entergy's Fourth 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 18, 2015 (GNRO-2015/00005)
7. Entergy Letter to NRC, Entergy's Fifth 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 28,2015 (GNRO-2015/00050)

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.

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 sixth 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 February 25, 2016.

Sincerely, KJM/sas

~

Attachment:

Grand Gulf Nuclear Station's Sixth 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

GNRO-2016/00008 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATIN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511.

Mr. B. J. Smith Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2016/00008 Grand Gulf Nuclear Station's Sixth 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

GNRO-20 16/00008 Page 1 of 5 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (OIP - Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2 of section 8. 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 July 31, 2015 and are current as of January 31,2016.

  • Install reliable SFPI 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 Completed N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Submitted Respond to ISE RAls (received September 30, February 27, N/A November 25, 2013) 2015 2015 4 Changes to Compliance Method There are no additional changes to the compliance method.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There is no need for Relief/Relaxation at this time.

GNRO-2016/00008 Page 2 of 5 6 Open Items from the Overall Integrated Plan, Interim Staff Evaluation, and Onsite Audit GGNS has received an Interim Staff Evaluation (ISE) that includes 19 RAls. Four additional RAls were received during the onsite audit. The following table provides a status of these RAls.

Responses to any open RAls are provided in Section 9.

RAI# Response Status 1 Closed via Audit Report (Reference 11) 2 Closed via Audit Report (Reference-11) 3 Closed via Audit Report (Reference 11) 4 Closed via Audit Report (Reference 11) 5 Closed via Audit Report (Reference 11) 6 Closed via Audit Report (Reference 11) 7 Closed via Audit Report (Reference 11) 8 Closed via Audit Report (Reference 11) 9 Closed via Audit Report (Reference 11) 10 Closed via Audit Report (Reference 11) 11 Closed via Audit Report (Reference 11) 12 Closed via Audit Report (Reference 11) 13 Closed via Audit Report (Reference 11) 14 Closed via Audit Report (Reference 11) 15 Closed via Audit Report (Reference 11) 16 Closed via Audit Report (Reference 11) 17 Closed via Audit Report (Reference 11) 18 Closed via Audit Report (Reference 11) 19 Closed via Audit Report (Reference 11) 20 (new) Closed via Audit Report (Reference 11) 21 (new) Closed via Audit Report (Reference 11) 22 (new) Closed via Audit Report (Reference 11) 23 (new) In Progress (See Section 9)

GNRO-2016/00008 Page 3 of 5 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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).
8. Entergy Letter to NRC, Entergy's Third 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 27,2014 (GNRO-2014/00055).
9. 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).

GNRO-2016/00008 Page 4 of 5

10. Entergy Letter to NRC, Entergy's Fourth 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 18, 2015 (GNRO-2015/00005).
11. "Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 AND EA-12-051 (TAC NOS, MF0954 AND MF0955),"

dated November 24, 2015 (ML15308A298).

GNRO-20 16/00008 Page 5 of 5 9 Responses to Open Items RAI #23 During the onsite audit, the NRC staff noted that the metal conduits for the two SFP level channels were routed within 3 feet of each other (and sometimes less than that) on the north and west walls of the SFP operating floor in the auxiliary building. This does not appear to meet the requirements of Order EA-12-051 that:

"The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure. II A response to this open item has been provided in ePortal along with a response to two additional requests for information concerning the submitted ePortal response.

~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-2016/00008 February 25, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Sixth 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)
5. Entergy Letter to NRC, Entergy's Third 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 27,2014 (GNRO-2014/00055)

GNRO-2016/00008 Page 2 of 3

6. Entergy Letter to NRC, Entergy's Fourth 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 18, 2015 (GNRO-2015/00005)
7. Entergy Letter to NRC, Entergy's Fifth 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 28,2015 (GNRO-2015/00050)

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.

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 sixth 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 February 25, 2016.

Sincerely, KJM/sas

~

Attachment:

Grand Gulf Nuclear Station's Sixth 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

GNRO-2016/00008 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission ATTN: Mr. Jim Kim, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Rockville, MD 20852-2738 U.S. Nuclear Regulatory Commission ATIN: Mr. Marc Dapas (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511.

Mr. B. J. Smith Director, Division of Radiological Health Mississippi State Department of Health Division of Radiological Health 3150 Lawson Street Jackson, MS 39213 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150

Attachment to GNRO-2016/00008 Grand Gulf Nuclear Station's Sixth 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

GNRO-20 16/00008 Page 1 of 5 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (OIP - Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2 of section 8. 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 July 31, 2015 and are current as of January 31,2016.

  • Install reliable SFPI 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 Completed N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Submitted Respond to ISE RAls (received September 30, February 27, N/A November 25, 2013) 2015 2015 4 Changes to Compliance Method There are no additional changes to the compliance method.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation There is no need for Relief/Relaxation at this time.

GNRO-2016/00008 Page 2 of 5 6 Open Items from the Overall Integrated Plan, Interim Staff Evaluation, and Onsite Audit GGNS has received an Interim Staff Evaluation (ISE) that includes 19 RAls. Four additional RAls were received during the onsite audit. The following table provides a status of these RAls.

Responses to any open RAls are provided in Section 9.

RAI# Response Status 1 Closed via Audit Report (Reference 11) 2 Closed via Audit Report (Reference-11) 3 Closed via Audit Report (Reference 11) 4 Closed via Audit Report (Reference 11) 5 Closed via Audit Report (Reference 11) 6 Closed via Audit Report (Reference 11) 7 Closed via Audit Report (Reference 11) 8 Closed via Audit Report (Reference 11) 9 Closed via Audit Report (Reference 11) 10 Closed via Audit Report (Reference 11) 11 Closed via Audit Report (Reference 11) 12 Closed via Audit Report (Reference 11) 13 Closed via Audit Report (Reference 11) 14 Closed via Audit Report (Reference 11) 15 Closed via Audit Report (Reference 11) 16 Closed via Audit Report (Reference 11) 17 Closed via Audit Report (Reference 11) 18 Closed via Audit Report (Reference 11) 19 Closed via Audit Report (Reference 11) 20 (new) Closed via Audit Report (Reference 11) 21 (new) Closed via Audit Report (Reference 11) 22 (new) Closed via Audit Report (Reference 11) 23 (new) In Progress (See Section 9)

GNRO-2016/00008 Page 3 of 5 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.

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).
8. Entergy Letter to NRC, Entergy's Third 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 27,2014 (GNRO-2014/00055).
9. 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).

GNRO-2016/00008 Page 4 of 5

10. Entergy Letter to NRC, Entergy's Fourth 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 18, 2015 (GNRO-2015/00005).
11. "Grand Gulf Nuclear Station, Unit 1 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 AND EA-12-051 (TAC NOS, MF0954 AND MF0955),"

dated November 24, 2015 (ML15308A298).

GNRO-20 16/00008 Page 5 of 5 9 Responses to Open Items RAI #23 During the onsite audit, the NRC staff noted that the metal conduits for the two SFP level channels were routed within 3 feet of each other (and sometimes less than that) on the north and west walls of the SFP operating floor in the auxiliary building. This does not appear to meet the requirements of Order EA-12-051 that:

"The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure. II A response to this open item has been provided in ePortal along with a response to two additional requests for information concerning the submitted ePortal response.

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