W3F1-2015-0004, Fourth Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation

Fourth Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation

ML15057A555
Person / Time
Site:	Waterford
Issue date:	02/26/2015
From:	Chisum M Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, W3F1-2015-0004
Download: ML15057A555 (8)

Text

Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 504-739-6660 Fax 504-739-6678 mchisum@entergy.com Michael R. Chisum Vice President - Operations Waterford 3 W3F1-2015-0004 February 26, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Fourth Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License With Regard To Reliable Spent Fuel Pool Instrumentation Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

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 (ADAMS Accession No. ML12054A682)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable SFP Instrumentation, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339)

3. Nuclear Energy Institute (NEI) 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable SFP Instrumentation, Revision 1, dated August 2012 (ADAMS Accession No. ML12240A307)

4. Entergy letter to NRC, Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable SFP Instrumentation (Order Number EA 051), dated October 26, 2012 (ADAMS Accession No. ML12300A446)

5. Waterford Steam Electric Station, Unit 3, letter to NRC, 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 (ADAMS Accession No. ML13063A263).

W3F1-2015-0004 Page 2 of 3

6. Waterford Steam Electric Station, Unit 3 letter to NRC, First Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License With Regard To Reliable Spent Fuel Pool Instrumentation dated August 28, 2013 (ADAMS Accession No. ML13241A280)

7. Waterford Steam Electric Station, Unit 3 letter to NRC, Second Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License With Regard To Reliable Spent Fuel Pool Instrumentation dated February 28, 2014 (ADAMS Accession No. ML14059A087)

8. Waterford Steam Electric Station, Unit 3 letter to NRC, Third Six Month Status Report for Implementation of Order EA-12-051, Commission Order Modifying License With Regard To Reliable Spent Fuel Pool Instrumentation dated August 28, 2014 (ADAMS Accession No. ML14247A294)

Dear Sir or Madam:

On March 12, 2012, the NRC issued NRC Order EA-12-051 (Reference 1) to Entergy Operations, Inc. (Entergy). The Order (Reference 1) was immediately effective and directs Waterford Steam Electric Station, Unit 3 (Waterford 3), to have a reliable indication of the water level in associated spent fuel storage pools.

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 (OIP). Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3). Reference 4 provided the initial status report regarding SFP instrumentation, and Reference 5 provided the OIP.

NRC Order EA-12-051 requires submission of a status report at six-month intervals following submittal of the Overall Integrated Plan with regard to the requirements for reliable spent fuel pool instrumentation for Waterford 3. References 6, 7, and 8 provided the first, second, and third six-month status reports for Waterford 3, respectively. The purpose of this letter is to provide, as an attachment, the fourth six month status report for the implementation of Order EA-12-051.

There are no new commitments identified in this submittal. Should you have any questions concerning the content of this letter, please contact John Jarrell, Regulatory Assurance Manager, at (504) 739-6685.

W3F1-2 2015-0004 Page 3 of 3 I declarre under pennalty of perju ury that the foregoing f is ttrue and corrrect. Execu uted on February 26, 2015.

MRC/A AJH Attachmment: Waterrford Steam Electric Stattion, Unit 3, Fourth Six M Month Statuss Report for the Implemmentation off Order EA-1 12-051, Ordeer Modifying g Licenses w with Regard tto the Reequirements for Reliable e Spent Fuell Pool Instrumentation cc: Attn: Directo or, Office of Nuclear Rea actor Regula ation U. S. NRC RidsNrrMaillCenter@nrc c.gov Mr. Mark L. Dapas, Reg gional Adminnistrator U. S. NRC, Region IV RidsRgn4M MailCenter@n nrc.gov NRC Projec ct Manager forf Waterford d3 Michael.Ore enak@nrc.go ov NRC Seniorr Resident In nspector for Waterford 3 Frances.Ramirez@nrc.g gov Chris.Speerr@nrc.gov

Attachment W3F1-2015-0004 Waterford Steam Electric Station, Unit 3, Fourth Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to the Requirements for Reliable Spent Fuel Pool Instrumentation

Attachment to W3F1-2015-0004 Page 1 of 4 Waterford Steam Electric Station, Unit 3, Fourth Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to the Requirements for Reliable Spent Fuel Pool Instrumentation 1 Introduction Waterford Steam Electric Station, Unit 3 (Waterford 3), developed an Overall Integrated Plan (Reference 1 in Section 8) documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI) in response to NRC Order EA-12-051 (Reference 2). This attachment provides a planned 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, 2014 and are current as of January 31, 2015.

Third Six-Month Status Report August 2014 Fourth Six-Month Status Report Complete with submission of this document in February 2015 Design Engineering - Completed

Attachment to W3F1-2015-0004 Page 2 of 4 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan (Reference 1). 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 N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Complete N/A Update 5 Aug 2015 Not Started No Change Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications:

Engineering and Implementation Design Engineering Oct 2014 Complete N/A Implementation Outage Nov 2015 Not Started No Change Procedures:

Create Procedures Nov 2015 In Progress No Change Training:

Develop Training Plan May 2015 Not Started No Change Implement Training Nov 2015 Not Started No Change Submit Completion Report: Feb 2016 Not Started No Change Respond to NRC ISE RAIs March 2015 In Progress No Change

Attachment to W3F1-2015-0004 Page 3 of 4 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 Waterford 3 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 Interim Staff Evaluation Waterford 3 has received an Interim Staff Evaluation that includes 18 RAIs. Responses to the RAIs are due March 31, 2015. The following table provides a status of any RAIs documented in the Interim Staff Evaluation.

RAI # Response Status 1 To be uploaded to ePortal by 3/31/15 2 To be uploaded to ePortal by 3/31/15 3 To be uploaded to ePortal by 3/31/15 4 To be uploaded to ePortal by 3/31/15 5 To be uploaded to ePortal by 3/31/15 6 To be uploaded to ePortal by 3/31/15 7 To be uploaded to ePortal by 3/31/15 8 To be uploaded to ePortal by 3/31/15 9 To be uploaded to ePortal by 3/31/15 10 To be uploaded to ePortal by 3/31/15 11 To be uploaded to ePortal by 3/31/15 12 To be uploaded to ePortal by 3/31/15 13 To be uploaded to ePortal by 3/31/15 14 To be uploaded to ePortal by 3/31/15 15 To be uploaded to ePortal by 3/31/15 16 To be uploaded to ePortal by 3/31/15 17 To be uploaded to ePortal by 3/31/15 18a To be uploaded to ePortal by 3/31/15 18b To be uploaded to ePortal by 3/31/15 7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6.

Attachment to W3F1-2015-0004 Page 4 of 4 8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.

1. Waterford Steam Electric Station, Unit 3 letter to NRC, 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 (ADAMS Accession No. ML13063A263).

2. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ADAMS Accession No. ML12054A682).

3. Waterford Steam Electric Station, Unit 3 - 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. MF0946), dated November 25, 2013 (ADAMS Accession No. ML13312A787).

4. November 26, 2013, Public Meeting Summary for the Discussion Between the NRC Staff and Industry Concerning Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation, dated December 26, 2013 (ADAMS Accession No. ML13347B030).