PLA-7073, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051)

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051)

ML13240A215
Person / Time
Site:	Susquehanna
Issue date:	08/26/2013
From:	Rausch T Susquehanna
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, PLA-7073
Download: ML13240A215 (6)

Text

Timothy S. Rausch PPL Susquehanna, LLC Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 AUG 2 6 2013 tsrausch@ pplweb.com

' TM U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION FIRST SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (NRC ORDER EA-12-051) Docket No. 50-387 PLA-7073 and No. 50-388

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-2-051, 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. PPL Letter (PLA-6925) PPL Susquehanna's 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 29, 2012

5. PPL Letter (PLA-6980) PPL Susquehanna's 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 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to PPL Susquehanna, LLC (PPL). Reference 1 was immediately effective and directs PPL 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 PPL's initial status report regarding Spent Fuel Pool Level

Document Control Desk PLA-7073 Instrumentation. Reference 5 provided PPL's overall integrated plan for 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 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first 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 enclosed 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.

If you have any questions regarding this report, please contact Mr. John L. Tripoli at 570-542-3100.

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

Executed on: '3 1'LcQ{rt>

Sincerely, T. S. Rausch

~._ _- . _ . .,-

Enclosure:

PPL Susquehanna, LLC' s First Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP

Enclosure to PLA-7073 PPL Susquehanna, LLC's First Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation

Enclosure to PLA-7073 Page 1 of 3 PPL Susquehanna, LLC's First Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation

1. Introduction PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan (Reference 1)

[NOTE: References cited in this enclosure are contained in Section 8.], documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFP LI),

in response to Reference 2. This attachment provides an 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 The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013.

• A Modification Evaluation for SFP LI was completed for both Unit 1 and Unit 2 in July, 2013.

• Detailed Design Engineering for SFP LI commenced.

3. Milestone Schedule Status The following table provides a milestone schedule that supports 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.

Revised Target Activity Target Milestone Completion Status Completion Date 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 Not Started Update 3 August 2014 Not Started

Enclosure to PLA-7073 Page 2 of 3 Revised Target Activity Target Milestone Completion Status Completion Date Date Update4 February 2015 Not Started Update 5 August 2015 Not Started Modifications:

Modification Scoping July 2013 Complete Evaluation Issue Unit 1 and Unit 2 March 2014 Started Engineering Change Implementation Outage June 2015 Not Started Procedures:

Create Procedures March 2015 Not Started Training:

Develop Training Plan December 2014 Not Started Training Complete March 2015 Not Started Full Site SFP LI June 2015 Not Started Implementation Submit Completion Report August 2015 Not Started

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with the order implementation date and no relief/relaxation is required at this time.

Enclosure to PLA-7073 Page 3 of 3

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation Open items described in the RAI response (Reference 5) will be addressed in future updates or under separate letter as described in the RAI response and thus are not included in this update letter.

7. Potential Draft Safety Evaluation Impacts None- PPL has not received a draft Safety Evaluation at this time.

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

1. PLA-6980, PPL Susquehanna's 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, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

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

4. NEI 12-02, 'Industry Guidance for Compliance with Order EA-12-051to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation,' Revision 1, August 2012.

5. PLA-7026, PPL Susquehanna's Response to Request for Additional Information on Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation", dated July 3, 2013.