JAFP-16-0140, Seventh 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

Seventh 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

ML16238A522
Person / Time
Site:	FitzPatrick
Issue date:	08/25/2016
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, JAFP-16-0140
Download: ML16238A522 (8)

Text

JAFP-16-0140 August 25, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Seventh 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)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1.

NRC Order Number, EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, ML12056A044, dated March 12, 2012

2.

NRC Interim Staff Guidance, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, JLD-ISG-2012-03, dated August 29, 2012

3.

Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, NEI 12-02, Revision 1, dated August 24, 2012

4.

ENOI letter, 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),

JAFP-12-0125, dated October 29, 2012

5.

ENOI letter, James A. FitzPatrick 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),

JAFP-13-0023, dated February 28, 2013

6.

ENOI letter, JAFP-16-0045, Certification of Permanent Cessation of Power Operations, dated March 16, 2016 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF

Dear Sir or Madam:

JAFP-16-0140 Page 2 of 3 On March 12, 2012, the Nuclear Regulatory Commission ("NRG" or "Commission") issued an order [Reference 1] to James A. FitzPatrick Nuclear Power Plant (JAF). Reference 1 was immediately effective and directed JAF 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.2. Reference 2 endorsed industry guidance document NEI 12-02 Revision 1

[Reference 3] with clarifications and exceptions identified in Reference 2. Reference 4 provided the JAF initial status report regarding spent fuel pool instrumentation. Reference 5 provided the JAF 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 purpose of this letter is to provide the seventh 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.

Reference 6 notified the NRG that Entergy had decided to permanently cease power operations of JAF in January 2017. This status report reflects that decision. Entergy is evaluating its responses to Reference 1 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations. The immediate impact to the six-month update report is to suspend all scheduled actions to allow the evaluation of what specific activities related to spent fuel pool instrumentation will be required. This is reflected in the milestone schedule by revising dates by inserting "to be determined" {TBD).

Recently, the possible option to sell JAF in lieu of permanent cessation of power operation has transpired. Initial review and planning is underway to determine what actions are needed along with completion dates for compliance with NRG Order EA-12-051. However at this point, given no final decision has occurred, no significant changes to this six-month status report are currently warranted.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact William Drews, Regulatory Assurance Manager, at 315-349-6562.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 251h day of August, 2016.

Sincerely, Brian R. Sullivan Site Vice President BRS/WCD/mh

JAFP-16-0140 Page 3 of 3

Attachment:

James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 cc:

Director, Office of Nuclear Reactor Regulation NRC Region I Administrator NRC Resident Inspector NRC Project Manager NYSPSC NYSERDA President

JAFP-16-0140 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 (4 Pages)

JAFP-16-0140 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 Page 1 of 4

1. Introduction James A. FitzPatrick Nuclear Power Plant (JAF) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spend fuel pool level instrumentation (SFPI), in response to Reference 2. 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 January 31, 2016, and are current as of July 31, 2016:

Sixth Six-Month Status Report - February 2016 (JAFP-16-0028).

3. Milestone Schedule Status The following provides an update to 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.

Milestone Target Completion Date*

Activity Status Revised Target Completion Date Submit 60 Day Status Report October 2012 Complete Submit Overall Integrated Plan February 2013 Complete Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Complete Update 7 August 2016 Complete Modifications:

Modifications Evaluation September 2015 Complete Design Engineering September 2015 Complete Implementation Outage TBD**

Not Started

JAFP-16-0140 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 Page 2 of 4 Milestone Target Completion Date*

Activity Status Revised Target Completion Date Procedures:

Create Procedures TBD**

In Progress Training:

Develop Training Plan TBD**

Not Started Training Complete TBD**

Not Started SFP LI Implementation TBD**

Not Started Full Site SFPI Implementation TBD**

Not Started Submit Completion Report TBD**

Not Started Respond to ISE RAIs received December 12, 2013 (Reference 3)

March 31, 2016 Complete Respond to RAIs received August 29, 2013 October 3, 2013 Complete

• Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month update.

• • These milestones are being reassessed and revised target completion dates will be determined and included in a future six-month update (see Section 4).

4. Changes to Compliance Method On March 16, 2016, Entergy notified the NRC that it had decided to permanently cease power operations of JAF in January 2017. Entergy is evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations.

Recently the possible option to sell JAF in lieu of permanent cessation of power operation has transpired. Initial review and planning is underway to determine what actions are needed along with completion dates for compliance with NRC Order EA-12-049. However at this point, given no final decision has occurred, no significant changes to this six-month status report are currently warranted.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF will submit a plan that resolves any issues relative to order implementation. This plan may include a relief/relaxation request.

JAFP-16-0140 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 Page 3 of 4

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation FitzPatrick has received an Interim Staff Evaluation that includes 18 RAIs. Responses to the RAIs are due by March 31, 2016. The following table provides a status of the RAIs.

RAI #

Response Status 1

Submitted in Reference 7 2

Submitted in Reference 9 3

Submitted in Reference 9 4

Submitted in Reference 9 5

Submitted in Reference 7 6

Submitted in Reference 7 7

Submitted in Reference 7 8

Submitted in Reference 7 9

Submitted in Reference 7 10 Submitted in Reference 9 11 Submitted in Reference 7 12 Submitted in Reference 7 13 Submitted in Reference 7 14 Submitted in Reference 7 15 Submitted in Reference 7 16 Submitted in Reference 7 17 Submitted in Reference 7 18 Submitted in Reference 7

7. Potential Interim Staff Evaluation Impacts Entergy is currently evaluating its responses to Reference 2 in order to determine the appropriate actions in alignment with the decision to permanently cease power operations (Reference 10). Therefore, Entergy has not yet identified any additional potential impacts to the Interim Staff Evaluation since the previous six month status report (Reference 11).

JAFP-16-0140 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Seventh 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 Page 4 of 4

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

1. James A. FitzPatrick 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), JAFP-13-0023, dated February 28, 2013 (ML13063A267)

2. Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, EA-12-051, dated March 12, 2012 (ML12056A044)

3. James A. FitzPatrick Nuclear Power Plant - 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. MF1076), dated December 12, 2013 (ML13338A645)

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 (ML13347B030)

5. James A. FitzPatrick Nuclear Power Plant - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) (TAC No. MF1076), dated August 29, 2013 (ML13226A534)

6. Response to Request for Additional Information for the Overall Integrated Plan for the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, JAFP-13-0132, dated October 3, 2013

7. Fourth 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), JAFP-15-0027, dated February 27, 2015 (ML15058A607)

8. Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, NEI 12-02, Revision 1, dated August 24, 2012 (ML12240A307)

9. Fifth 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), JAFP-15-0105, dated August 28, 2015 (ML15240A377)

10. Certification of Permanent Cessation of Power Operations, JAFP-15-0133, dated March 16, 2016 (ML16076A391)

11. 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), JAFP-16-0028, dated February 26, 2016 (ML16057A632)