PLA-7222, Third 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)

Third 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)

ML14239A527
Person / Time
Site:	Susquehanna
Issue date:	08/27/2014
From:	Rausch T Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, PLA-7222
Download: ML14239A527 (7)

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 tsrausch@ pplweb.com AUG 2 7 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION THIRD 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-7222 and No. 50-388

References:

I. NRC Order Number EA-I2-05I, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, dated March I2, 20I2

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-05I, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 20 I2

3. NEI I2-02, Industry Guidance for Compliance with NRC Order EA-I2-05I, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision I, dated August 20I2

4. PPL Letter (PLA-6925) PPL Susquehanna's Initial Status Report in Response to March 12, 20I2 Commission Order to Modify Licenses with Regard to Requirements for 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 I2, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order Number EA-12-05I), dated February 28, 20I3

6. PPL Letter (PLA-7073) PPL Susquehanna's 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 Number EA-12-051), dated August 26,2013

7. PPL Letter (PLA-7138) PPL Susquehanna's Second Six-Month Status Report in Response to March I2, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order Number EA-12-051), dated February 27, 2014 The purpose of this letter is to provide the third 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.

Document Control Desk PLA-7222 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 Instrumentation. Reference 5 provided PPL' s overall integrated plan for Spent Fuel Pool Level Instrumentation.

Reference 1 requires submission of status reports at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6 and 7 provided PPL's first and second six-month updates. The enclosure 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. Any changes are identified in the enclosure.

This letter contains no new regulatory commitments.

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

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

Executed on:

Sincerely, T. S. Rausch

Enclosure:

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

Document Control Desk PLA-7222 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-7222 PPL Susquehanna, LLC's Third Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

Enclosure to PLA-7222 Page 1 of 3 PPL Susquehanna, LLC's Third Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for 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 Unit 1 and Unit 2 Engineering Changes have been issued since the second six-month update submitted under Reference 6. The milestones are current as of July 31, 2014.

3. Milestone Schedule Status The following 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 Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete*

Update4 Feb 2015 Not Started Update 5 Aug 2015 Not Started

Enclosure to PLA-7222 Page 2 of3 Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications:

Modification Scoping July 2013 Complete Evaluation Issue Unit 1 and Unit 2 March 2014 Complete*

Engineering Changes Implementation Outage June 2015 Not Started Procedures:

Create Procedures March 2015 Started*

Training:

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

• Revised since the six month update submitted February 27, 2014 (Reference 6)

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.

6. Open Items from Overall Integrated Plan and Draft Safety Evaluation Reference 6 provided PPL's Response to NRC's Request for Additional Information (RAI) identified in Reference 7. Reference 8 identifies that the licensee should not formally submit RAI responses on the docket but instead, put the responses and

Enclosure to PLA-7222 Page 3 of3 supporting information on their ePortal by September 30, 2014, as identified in the Interim Staff Evaluation (ISE).

7. Potential Draft Safety Evaluation Impacts None- PPL Susquehanna has not received a draft Safety Evaluation at this time but has received an ISE (Reference 7).

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 (NRC Order Number EA-12-051)," dated February 28, 2013.

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

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

4. NEI 12-02, 'Industry Guidance for Compliance with Order EA-12-051, To Modify Licenses with Regard to 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.

6. PLA-7138, PPL Susquehanna's Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order Number EA-12-051), dated February 27, 2014.

7. NRC Letter titled, "Susquehanna Steam Electric Station, 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. MF0890 AND MF0891)," dated November 6, 2013.

8. NRC Letter titled, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051,"

dated March 26, 2014.