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| | issue date = 02/28/2014 | | | issue date = 02/28/2014 |
| | title = Second 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) | | | title = Second 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) |
| | author name = Mulligan K J | | | author name = Mulligan K |
| | author affiliation = Entergy Operations, Inc | | | author affiliation = Entergy Operations, Inc |
| | addressee name = | | | addressee name = |
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| =Text= | | =Text= |
| {{#Wiki_filter:GNRO-2014/00013 February 28, 2014 u.s.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 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 | | {{#Wiki_filter:~ |
| | ~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-2014/00013 February 28, 2014 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Entergy's Second 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) | | Entergy's Second 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 | | Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29 |
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| ==REFERENCES:== | | ==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) |
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| 1.NRC Order Number EA-12-051, Order to Modify Licenses with Regard to Reliable SpentFuelPool (SFP)Instrumentation, dated March 12,2012 (ML 12054A682) 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 26,20132013/00016, ML 13064A417)
| | ==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 second 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. Jeffery A. Seiter, Acting Regulatory Assurance Manager, at (601) 437-2344. |
| | |
| | GNRO-2014/00013 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014. |
| | Sincerely, |
| | ~r---- |
| | KJM/slw |
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| ==Dear Sir or Madam:== | | ==Attachment:== |
| On March 12, 2012, the U.S.Nuclear Regulatory Commission (NRC)issued an order (Reference 1)to Entergy Operations, Inc.(Entergy).
| | Grand Gulf Nuclear Station's Second 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: U. S. Nuclear Regulatory Commission AnN: Steven A. Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 |
| 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 second 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.
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| Should you have any questions regarding this submittal, please contact Mr.Jeffery A.Seiter, Acting Regulatory Assurance Manager, at (601)437-2344.
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| GNRO-2014/00013 February 28, 2014 u.s.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 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
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| ==SUBJECT:==
| | Attachment to GNRO-2014/00013 Grand Gulf Nuclear Station's Second 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 |
| Entergy's Second 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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| Grand Gulf Nuclear Station, Unit 1 Docket No.50-416 License No.NPF-29
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| ==REFERENCES:==
| | Attachment to GNRO-2014/00013 Page 1 of 7 Grand Gulf Nuclear Station's Second 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 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spent 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 August 15, 2013 and are current as of January 31, 2014: |
| | * Respond to NRC RAls (received July 30, 2013) |
| | * Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE) was received November 25, 2013 (Reference 3). The ISE contains 19 requests for additional information (RAls) that are due September 30,2015. NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation (ISE) questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4). Therefore, the RAls dated July 30, 2013 (Reference 5) are considered superseded by the RAls contained in the ISE. |
| | 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 Not started N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013) 2015 |
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| 1.NRC Order Number EA-12-051, Order to Modify Licenses with Regard to Reliable SpentFuelPool (SFP)Instrumentation, dated March 12,2012 (ML 12054A682) 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 26,20132013/00016, ML 13064A417)
| | Attachment to GNRO-2014/00013 Page 2 of7 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 GGNS 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 As discussed in Section 2, GGNS has received an Interim Staff Evaluation that includes 19 RAls. Responses to the RAls are due by September 30,2015 and are provided in Section 9 of this six-month status report. The following table provides a status of any RAls documented in the Interim Staff Evaluation. |
| | RAI# Response Status 1 In Progress 2 In Progress 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 In Progress 14 In Progress 15 In Progress 16 In Progress 17 In Progress 18 In Progress 19 In Progress 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6. |
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| ==Dear Sir or Madam:==
| | Attachment to GNRO-2014/00013 Page 3 of7 8 References The following references support the updates to the Overall Integrated Plan described in this Attachment. |
| On March 12, 2012, the U.S.Nuclear Regulatory Commission (NRC)issued an order (Reference 1)to Entergy Operations, Inc.(Entergy).
| | : 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). |
| Reference 1 was immediately effective and directs Entergy to install reliable spent fuel pool level instrumentation.
| | : 2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012 (ML12054A735). |
| 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 second 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.
| | : 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). |
| Should you have any questions regarding this submittal, please contact Mr.Jeffery A.Seiter, Acting Regulatory Assurance Manager, at (601)437-2344.
| | : 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). |
| GNRO-2014/00013 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct;executed on February 28, 2014.Sincerely, KJM/slw
| | : 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). |
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| ==Attachment:==
| | Attachment to GNRO-2014/00013 Page 4 of? |
| | 9 Responses to the Interim Staff Evaluation Requests for Addition Information RAI#1 Please provide information on specific procedures controlling irradiated hardware stored in the SFP. Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SPF. |
| | This response will be provided in a future update. |
| | RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room. |
| | This response will be provided in a future update. |
| | RAI#3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces. |
| | This response will be provided in a future update. |
| | RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of ~he affected structures/equipment. |
| | This response will be provided in a future update. |
| | RAI#5 Please provide further information describing how other material stored in the SFP will not create adverse interaction with the SFP level instruments. |
| | This response will be provided in a future update. |
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| Grand Gulf Nuclear Station's Second 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: U.S.Nuclear Regulatory Commission AnN: Steven A.Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S.Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U.S.Nuclear Regulatory Commission AnN: Mr.Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 GNRO-2014/00013 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct;executed on February 28, 2014.Sincerely, KJM/slw
| | Attachment to GNRO-2014/00013 Page 5 of7 RAI#6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the sensor electronics (including power boxes, signal processors, and display panels) will be exposed. Provide documentation indicating the maximum total integrated dose the sensor electronics can withstand and how it was determined. Discuss the time period over which the analyzed total integrated dose was applied. |
| | This response will be provided in a future update. |
| | RAI#7 Please provide information indicating (a) the temperature ratings and whether the temperature ratings for the system electronics are continuous duty ratings; and (b) the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions, which include no AC power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems. |
| | This response will be provided in a future update. |
| | RAI#8 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under SOB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing required functions under this expected humidity condition. |
| | This response will be provided in a future update. |
| | RAI#9 Please provide a description of the specific method or combination of methods to be applied to demonstrate the reliability of the permanently installed equipment under BOB shock and vibration conditions. |
| | This response will be provided in a future update. |
| | RAI #10 For RAI #9 above, please provide the results for the selected methods, tests, and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements. |
| | This response will be provided in a future update. |
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| ==Attachment:==
| | Attachment to GNRO-2014/00013 Page 6 of? |
| | RAI #11 Please provide analysis of the vendor analysis and seismic testing results to show that instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at GGNS, has been adequately demonstrated. |
| | This response will be provided in a future update. |
| | RAI #12 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective. |
| | This response will be provided in a future update. |
| | RAI #13 Please provide the results of the calculation depicting battery backup duty cycle requirements, demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured. |
| | This response will be provided in a future update. |
| | RAI #14 Please provide analysis verifying the proposed instrument performance is consistent with these estimated accuracy normal and 808 values. Demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power. |
| | This response will be provided in a future update. |
| | RAI #15 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions. The NRC staff understands this allowed deviation will serve as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy. |
| | This response will be provided in a future update. |
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| Grand Gulf Nuclear Station's Second 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: U.S.Nuclear Regulatory Commission AnN: Steven A.Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S.Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U.S.Nuclear Regulatory Commission AnN: Mr.Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Attachment to GNRO-2014/00013 Grand Gulf Nuclear Station's Second 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 Attachment to GNRO-2014/00013 Grand Gulf Nuclear Station's Second 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 Attachment to GNRO-2014/00013 Page 1 of 7 Grand Gulf Nuclear Station's Second 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 1 Introduction Grand Gulf Nuclear Station (GGNS)developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spent 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 August 15, 2013 and are current as of January 31, 2014:*Respond to NRC RAls (received July 30, 2013)*Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE)was received November 25, 2013 (Reference 3).The ISE contains 19 requests for additional information (RAls)that are due September 30,2015.NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation (ISE)questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4).Therefore, the RAls dated July 30, 2013 (Reference 5)are considered superseded by the RAls contained in the ISE.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.
| | Attachment to GNRO-2014/00013 Page 7 of7 RAI #16 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy. |
| Target Revised Activity Target Milestone Completion Status Completion Date Date Spring 2016 Install reliable SFPI Refueling Not started N/A Outage Respond to NRC RAls (received July August 29, Submitted August 29, N/A 30,2013)2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013)2015 Attachment to GNRO-2014/00013 Page 1 of 7 Grand Gulf Nuclear Station's Second 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 1 Introduction Grand Gulf Nuclear Station (GGNS)developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spent 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 August 15, 2013 and are current as of January 31, 2014:*Respond to NRC RAls (received July 30, 2013)*Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE)was received November 25, 2013 (Reference 3).The ISE contains 19 requests for additional information (RAls)that are due September 30,2015.NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation (ISE)questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4).Therefore, the RAls dated July 30, 2013 (Reference 5)are considered superseded by the RAls contained in the ISE.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.
| | This response will be provided in a future update. |
| Target Revised Activity Target Milestone Completion Status Completion Date Date Spring 2016 Install reliable SFPI Refueling Not started N/A Outage Respond to NRC RAls (received July August 29, Submitted August 29, N/A 30,2013)2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013)2015 Attachment to GNRO-2014/00013 Page 2 of7 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 GGNS 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 As discussed in Section 2, GGNS has received an Interim Staff Evaluation that includes 19 RAls.Responses to the RAls are due by September 30,2015 and are provided in Section 9 of this six-month status report.The following table provides a status of any RAls documented in the Interim Staff Evaluation.
| | RAI #17. |
| RAI#Response Status 1 In Progress 2 In Progress 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 In Progress 14 In Progress 15 In Progress 16 In Progress 17 In Progress 18 In Progress 19 In Progress 7 Potential Interim 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 GNRO-2014/00013 Page 2 of7 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 GGNS 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 As discussed in Section 2, GGNS has received an Interim Staff Evaluation that includes 19 RAls.Responses to the RAls are due by September 30,2015 and are provided in Section 9 of this six-month status report.The following table provides a status of any RAls documented in the Interim Staff Evaluation.
| | Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credit~d in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. |
| RAI#Response Status 1 In Progress 2 In Progress 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 In Progress 14 In Progress 15 In Progress 16 In Progress 17 In Progress 18 In Progress 19 In Progress 7 Potential Interim Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6. | | Additionally, include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event Describe whether personnel are continuously stationed at the display or monitor the display periodically. |
| Attachment to GNRO-2014/00013 Page 3 of7 8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.
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| 1."Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number051)," dated February 26,2013 (GNRO-2013/00016, ML 13059A316).
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| 2.NRC Order Number EA-12-051,"Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012 (ML 12054A735).
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| 3."Grand Gulf Nuclear Station, Unit1-Interim Staff Evaluation and Request for Additional Information RegardingOverallIntegrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)(TAC NO.MF0955)," dated November 25, 2013 (ML 133168986).
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| 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 (ML 133478030).
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| 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).
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| Attachment to GNRO-2014/00013 Page 3 of7 8 References The following references support the updates to the Overall Integrated Plan described in this Attachment.
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| 1."Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number051)," dated February 26,2013 (GNRO-2013/00016, ML 13059A316).
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| 2.NRC Order Number EA-12-051,"Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012 (ML 12054A735).
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| 3."Grand Gulf Nuclear Station, Unit1-Interim Staff Evaluation and Request for Additional Information RegardingOverallIntegrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)(TAC NO.MF0955)," dated November 25, 2013 (ML 133168986).
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| 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 (ML 133478030).
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| 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).
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| Attachment to GNRO-2014/00013 Page 4 of?9 Responses to the Interim Staff Evaluation Requests for Addition Information RAI#1 Please provide information on specific procedures controlling irradiated hardware stored in the SFP.Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SPF.This response will be provided in a future update.RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room.This response will be provided in a future update.RAI#3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.This response will be provided in a future update.RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of affected structures/equipment.
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| This response will be provided in a future update.RAI#5 Please provide further information describing how other material stored in the SFP will not create adverse interaction with the SFP level instruments.
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| This response will be provided in a future update.Attachment to GNRO-2014/00013 Page 4 of?9 Responses to the Interim Staff Evaluation Requests for Addition Information RAI#1 Please provide information on specific procedures controlling irradiated hardware stored in the SFP.Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SPF.This response will be provided in a future update.RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room.This response will be provided in a future update.RAI#3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.This response will be provided in a future update.RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of affected structures/equipment.
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| This response will be provided in a future update.RAI#5 Please provide further information describing how other material stored in the SFP will not create adverse interaction with the SFP level instruments.
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| This response will be provided in a future update. | | This response will be provided in a future update. |
| Attachment to GNRO-2014/00013 Page 5 of7 RAI#6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose)to which the sensor electronics (including power boxes, signal processors, and display panels)will be exposed.Provide documentation indicating the maximum total integrated dose the sensor electronics can withstand and how it was determined.
| | RAI #18 Please provide a Ii~t of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure. |
| Discuss the time period over which the analyzed total integrated dose was applied.This response will be provided in a future update.RAI#7 Please provide information indicating (a)the temperature ratings and whether the temperature ratings for the system electronics are continuous duty ratings;and (b)the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions, which include no AC power available to run Heating, Ventilation, and Air Conditioning (HVAC)systems.This response will be provided in a future update.RAI#8 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under SOB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing required functions under this expected humidity condition.
| |
| This response will be provided in a future update.RAI#9 Please provide a description of the specific method or combination of methods to be applied to demonstrate the reliability of the permanently installed equipment under BOB shock and vibration conditions.
| |
| This response will be provided in a future update.RAI#10 For RAI#9 above, please provide the results for the selected methods, tests, and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
| |
| This response will be provided in a future update.Attachment to GNRO-2014/00013 Page 5 of7 RAI#6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose)to which the sensor electronics (including power boxes, signal processors, and display panels)will be exposed.Provide documentation indicating the maximum total integrated dose the sensor electronics can withstand and how it was determined.
| |
| Discuss the time period over which the analyzed total integrated dose was applied.This response will be provided in a future update.RAI#7 Please provide information indicating (a)the temperature ratings and whether the temperature ratings for the system electronics are continuous duty ratings;and (b)the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions, which include no AC power available to run Heating, Ventilation, and Air Conditioning (HVAC)systems.This response will be provided in a future update.RAI#8 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under SOB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing required functions under this expected humidity condition.
| |
| This response will be provided in a future update.RAI#9 Please provide a description of the specific method or combination of methods to be applied to demonstrate the reliability of the permanently installed equipment under BOB shock and vibration conditions.
| |
| This response will be provided in a future update.RAI#10 For RAI#9 above, please provide the results for the selected methods, tests, and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
| |
| This response will be provided in a future update. | | This response will be provided in a future update. |
| Attachment to GNRO-2014/00013 Page 6 of?RAI#11 Please provide analysis of the vendor analysis and seismic testing results to show that instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at GGNS, has been adequately demonstrated.
| | RAI #19 Please provide further information describing the maintenance and testing program the licen$ee will establish and implement to ensure that regular te~ting and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment. |
| This response will be provided in a future update.RAI#12 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.
| |
| This response will be provided in a future update.RAI#13 Please provide the results of the calculation depicting battery backup duty cycle requirements, demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.This response will be provided in a future update.RAI#14 Please provide analysis verifying the proposed instrument performance is consistent withtheseestimated accuracy normal and 808 values.Demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.This response will be provided in a future update.RAI#15 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions.
| |
| The NRC staff understands this allowed deviation will serve as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.This response will be provided in a future update.Attachment to GNRO-2014/00013 Page 6 of?RAI#11 Please provide analysis of the vendor analysis and seismic testing results to show that instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at GGNS, has been adequately demonstrated.
| |
| This response will be provided in a future update.RAI#12 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.
| |
| This response will be provided in a future update.RAI#13 Please provide the results of the calculation depicting battery backup duty cycle requirements, demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.This response will be provided in a future update.RAI#14 Please provide analysis verifying the proposed instrument performance is consistent withtheseestimated accuracy normal and 808 values.Demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.This response will be provided in a future update.RAI#15 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions.
| |
| The NRC staff understands this allowed deviation will serve as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.This response will be provided in a future update.
| |
| Attachment to GNRO-2014/00013 Page 7 of7 RAI#16 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.This response will be provided in a future update.RAI#17.Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event.Include the time available for personnel to access the display as in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.Additionally, include a description of the radiological and environmental conditions on the paths personnel might take.Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event Describe whether personnel are continuously stationed at the display or monitor the display periodically.
| |
| This response will be provided in a future update.RAI#18 Please provide a of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation.
| |
| The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
| |
| This response will be provided in a future update.RAI#19 Please provide further information describing the maintenance and testing program the licen$ee will establish and implement to ensure that regular and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
| |
| Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
| |
| This response will be provided in a future update.Attachment to GNRO-2014/00013 Page 7 of7 RAI#16 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.This response will be provided in a future update.RAI#17.Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event.Include the time available for personnel to access the display as in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.Additionally, include a description of the radiological and environmental conditions on the paths personnel might take.Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event Describe whether personnel are continuously stationed at the display or monitor the display periodically.
| |
| This response will be provided in a future update.RAI#18 Please provide a of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation.
| |
| The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
| |
| This response will be provided in a future update.RAI#19 Please provide further information describing the maintenance and testing program the licen$ee will establish and implement to ensure that regular and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
| |
| Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment. | |
| This response will be provided in a future update.}} | | This response will be provided in a future update.}} |
|
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Category:Letter type:GNRO
MONTHYEARGNRO-2013/00079, 2013-10-13 (GNRO-2013-00079) Response to RAI Set 49 (Dated Sep-12-2013)2023-10-11011 October 2023 2013-10-13 (GNRO-2013-00079) Response to RAI Set 49 (Dated Sep-12-2013) GNRO-2023/00014, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-06-0606 June 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GNRO-2023/00015, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-06-0606 June 2023 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors GNRO-2021/00037, 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 12021-11-30030 November 2021 2021 Annual Report of Changes and Errors to 10 CFR 50.46 Analysis Grand Gulf Nuclear Station, Unit 1 GNRO-2021/00017, Notification of Readiness for Supplemental Inspection2021-06-22022 June 2021 Notification of Readiness for Supplemental Inspection GNRO-2021/00014, Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency2021-06-0101 June 2021 Inservice Testing Program Relief Request VRR-GGNS-2021-1 Pressure Isolation Valve Testing Frequency GNRO-2021/00015, Annual Radioactive Effluent Release Report2021-04-28028 April 2021 Annual Radioactive Effluent Release Report GNRO-2021/00011, Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 20202021-04-19019 April 2021 Revision of Original Report of 10CFR50.59 and Commitments Change Evaluations - July 1, 2018 Through May 21, 2020 GNRO-2021/00012, Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.22062021-04-13013 April 2021 Annual Report of Individual Monitoring - NRC Form 5 for 2020 Per 10 CFR 20.2206 GNRO-2020/00045, 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis2020-12-16016 December 2020 2020 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2020/00034, Notification of Spent Fuel Cask Use2020-10-0808 October 2020 Notification of Spent Fuel Cask Use GNRO-2020/00033, Response to NRC Integrated Inspection Report 05000416/20200022020-09-10010 September 2020 Response to NRC Integrated Inspection Report 05000416/2020002 GNRO-2020/00029, Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 20202020-08-18018 August 2020 Report of 10 CFR 72.48 Evaluations July 1, 2018 Through June 30, 2020 GNRO-2020/00022, Report of Technical Specification Bases Changes2020-07-21021 July 2020 Report of Technical Specification Bases Changes GNRO-2020/00027, Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-07-16016 July 2020 Core Operating Limits Report (COLR) Cycle 23 Revision 1 for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00023, Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-06-26026 June 2020 Response to Request for Additional Information - License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2020/00020, Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS)2020-05-0505 May 2020 Core Operating Limits Report (COLR) Cycle 23, and Pressure and Temperature Limits Report (PTLR) Update for Grand Gulf Nuclear Station, Unit 1 (GGNS) GNRO-2020/00018, Annual Radiological Effluent Release Report2020-04-30030 April 2020 Annual Radiological Effluent Release Report GNRO-2020/00016, Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.22062020-04-16016 April 2020 Annual Report of Individual Monitoring -NRC Form 5 for 2019 Per 10 CFR 20.2206 GNRO-2020/00015, Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test2020-04-0707 April 2020 Response to Request for Additional Information - License Amendment Request for One-Cycle Extension of Appendix J Type a Integrated Leakage Rate Test and Drywell Bypass Leakage Rate Test GNRO-2020/00007, Spent Fuel Storage Radioactive Effluent Release Report for 20192020-02-20020 February 2020 Spent Fuel Storage Radioactive Effluent Release Report for 2019 GNRO-2020/00006, License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies2020-02-19019 February 2020 License Amendment Request for Permanent Extension of Appendix J Type a Integrated Leakage Rate Test Frequencies GNRO-2019/00052, Report of Changes and Errors to 10 CFR 50.46 Analysis2019-12-13013 December 2019 Report of Changes and Errors to 10 CFR 50.46 Analysis GNRO-2019/00051, Notification of Readiness of 92723 Inspection2019-12-11011 December 2019 Notification of Readiness of 92723 Inspection GNRO-2019/00045, Emergency Plan, Revision 792019-10-29029 October 2019 Emergency Plan, Revision 79 GNRO-2019/00037, Notification of Spent Fuel Cask Use2019-09-20020 September 2019 Notification of Spent Fuel Cask Use GNRO-2019/00036, Correction to Gnro 2019-00017 Emergency Plan Revision 782019-08-0808 August 2019 Correction to Gnro 2019-00017 Emergency Plan Revision 78 GNRO-2019/00027, Notification of Readiness of 95001 Supplemental Inspections2019-07-0303 July 2019 Notification of Readiness of 95001 Supplemental Inspections GNRO-2019/00031, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report2019-06-25025 June 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 - Corrected Report GNRO-2019/00028, Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation.2019-06-13013 June 2019 Supplement to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation. GNRO-2019/00026, Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval2019-05-0606 May 2019 Response to Requests for Additional Information Regarding Relief Request Number GG-ISI-023, Inservice Inspection Impracticality - Limited Coverage Examinations During the Third 10-Year Inservice Inspection Interval GNRO-2019/00024, Annual Radioactive Effluent Release Report2019-04-30030 April 2019 Annual Radioactive Effluent Release Report GNRO-2019/00020, Annual Radiological Operating Report (AREOR)2019-04-30030 April 2019 Annual Radiological Operating Report (AREOR) GNRO-2019/00022, Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.22062019-04-22022 April 2019 Annual Report of Individual Monitoring - NRC Form 5 for 2018 Per 10 CFR 20.2206 GNRO-2019/00017, Emergency Plan, Revision 782019-03-14014 March 2019 Emergency Plan, Revision 78 GNRO-2019/00014, Snubber Testing Program for Fourth Inspection Interval2019-03-13013 March 2019 Snubber Testing Program for Fourth Inspection Interval GNRO-2019/00012, Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program2019-03-0606 March 2019 Internal Events Probabilistic Risk Assessment (PRA) Sensitivity Study Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program GNRO-2019/00016, Spent Fuel Storage Radioactive Effluent Release Report for 20182019-02-21021 February 2019 Spent Fuel Storage Radioactive Effluent Release Report for 2018 GNRO-2019/00003, Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation2019-01-23023 January 2019 Application to Revise Technical Specification (TS) 3.3.1.1, Reactor Protection System (RPS) Instrumentation, and TS 3.3.4.1, End of Cycle Recirculation Pump Trip (EOC-RPT) Instrumentation GNRO-2018/00057, Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan2018-12-0404 December 2018 Submittal of Revision 17 to the Grand Gulf Nuclear Station Physical Security, Safeguards Contingency, and Training and Qualification Plan GNRO-2018/00055, Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ...2018-11-30030 November 2018 Response to Request for Additional Information for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a ... GNRO-2018/00054, Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval2018-11-30030 November 2018 Relief Request No. GG-ISI-023, Inservice Inspection Impracticality: Limited Coverage Examination During the Third 10-Year Inservice Inspection Interval GNRO-2018/00052, License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information2018-10-24024 October 2018 License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into Licensing Basis - Partial Response to Request for Additional Information and Extension of Response to Request for Additional Information GNRO-2018/00051, Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control2018-10-23023 October 2018 Supplement to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control GNRO-2018/00046, Submittal of 2018 Report of Changes and Errors to 10CFR50.462018-10-16016 October 2018 Submittal of 2018 Report of Changes and Errors to 10CFR50.46 GNRO-2018/00047, Submittal of 2018 Inservice Inspection Summary Report2018-10-16016 October 2018 Submittal of 2018 Inservice Inspection Summary Report GNRO-2018/00048, Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 62018-10-10010 October 2018 Response to Request for Additional Information License Amendment Request, Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 GNRO-2018/00042, Core Operating Limits Report Cycle 22, Revision 12018-09-18018 September 2018 Core Operating Limits Report Cycle 22, Revision 1 GNRO-2018/00043, Revised Offsite Dose Calculation Manual2018-09-18018 September 2018 Revised Offsite Dose Calculation Manual GNRO-2018/00039, Report of Technical Specification Bases Changes2018-08-20020 August 2018 Report of Technical Specification Bases Changes 2023-06-06
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~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-2014/00013 February 28, 2014 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Entergy's Second 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)
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 second 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. Jeffery A. Seiter, Acting Regulatory Assurance Manager, at (601) 437-2344.
GNRO-2014/00013 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014.
Sincerely,
~r----
KJM/slw
Attachment:
Grand Gulf Nuclear Station's Second 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: U. S. Nuclear Regulatory Commission AnN: Steven A. Reynolds Acting Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 U. S. Nuclear Regulatory Commission Attn: Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission AnN: Mr. Alan Wang, NRRlDORL Mail Stop OWFN/8 B1 Washington, DC 20555-0001 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150
Attachment to GNRO-2014/00013 Grand Gulf Nuclear Station's Second 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
Attachment to GNRO-2014/00013 Page 1 of 7 Grand Gulf Nuclear Station's Second 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 1 Introduction Grand Gulf Nuclear Station (GGNS) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spent 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 August 15, 2013 and are current as of January 31, 2014:
- Respond to NRC RAls (received July 30, 2013)
- Although not part of the original milestone schedule, an Interim Staff Evaluation (ISE) was received November 25, 2013 (Reference 3). The ISE contains 19 requests for additional information (RAls) that are due September 30,2015. NRC staff clarified during the November 26, 2013 public meeting that the Interim Staff Evaluation (ISE) questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation (Reference 4). Therefore, the RAls dated July 30, 2013 (Reference 5) are considered superseded by the RAls contained in the ISE.
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 Not started N/A Outage Submitted Respond to NRC RAls (received July August 29, August 29, N/A 30,2013) 2013 2013 Respond to ISE RAls (received September 30, See Section 6 N/A November 25, 2013) 2015
Attachment to GNRO-2014/00013 Page 2 of7 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 GGNS 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 As discussed in Section 2, GGNS has received an Interim Staff Evaluation that includes 19 RAls. Responses to the RAls are due by September 30,2015 and are provided in Section 9 of this six-month status report. The following table provides a status of any RAls documented in the Interim Staff Evaluation.
RAI# Response Status 1 In Progress 2 In Progress 3 In Progress 4 In Progress 5 In Progress 6 In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 In Progress 14 In Progress 15 In Progress 16 In Progress 17 In Progress 18 In Progress 19 In Progress 7 Potential Interim 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 GNRO-2014/00013 Page 3 of7 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 (ML12054A735).
- 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).
Attachment to GNRO-2014/00013 Page 4 of?
9 Responses to the Interim Staff Evaluation Requests for Addition Information RAI#1 Please provide information on specific procedures controlling irradiated hardware stored in the SFP. Include details of any analysis performed to determine the projected dose rate impact and the appropriate Level 2 elevation as a result of dose from irradiated material stored in the SPF.
This response will be provided in a future update.
RAI#2 Please provide a clearly labeled sketch or marked-up plant drawing depicting the proposed routing of the cables that will extend from the SFP sensors toward the location of the read-out/display device in the computer and control panel room.
This response will be provided in a future update.
RAI#3 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
This response will be provided in a future update.
RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of ~he affected structures/equipment.
This response will be provided in a future update.
RAI#5 Please provide further information describing how other material stored in the SFP will not create adverse interaction with the SFP level instruments.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 5 of7 RAI#6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the sensor electronics (including power boxes, signal processors, and display panels) will be exposed. Provide documentation indicating the maximum total integrated dose the sensor electronics can withstand and how it was determined. Discuss the time period over which the analyzed total integrated dose was applied.
This response will be provided in a future update.
RAI#7 Please provide information indicating (a) the temperature ratings and whether the temperature ratings for the system electronics are continuous duty ratings; and (b) the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions, which include no AC power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems.
This response will be provided in a future update.
RAI#8 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under SOB conditions, in which there is no ac power available to run HVAC systems, and whether the sensor electronics is capable of continuously performing required functions under this expected humidity condition.
This response will be provided in a future update.
RAI#9 Please provide a description of the specific method or combination of methods to be applied to demonstrate the reliability of the permanently installed equipment under BOB shock and vibration conditions.
This response will be provided in a future update.
RAI #10 For RAI #9 above, please provide the results for the selected methods, tests, and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 6 of?
RAI #11 Please provide analysis of the vendor analysis and seismic testing results to show that instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at GGNS, has been adequately demonstrated.
This response will be provided in a future update.
RAI #12 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.
This response will be provided in a future update.
RAI #13 Please provide the results of the calculation depicting battery backup duty cycle requirements, demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.
This response will be provided in a future update.
RAI #14 Please provide analysis verifying the proposed instrument performance is consistent with these estimated accuracy normal and 808 values. Demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.
This response will be provided in a future update.
RAI #15 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions. The NRC staff understands this allowed deviation will serve as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.
This response will be provided in a future update.
Attachment to GNRO-2014/00013 Page 7 of7 RAI #16 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.
This response will be provided in a future update.
RAI #17.
Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credit~d in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.
Additionally, include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event Describe whether personnel are continuously stationed at the display or monitor the display periodically.
This response will be provided in a future update.
RAI #18 Please provide a Ii~t of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
This response will be provided in a future update.
RAI #19 Please provide further information describing the maintenance and testing program the licen$ee will establish and implement to ensure that regular te~ting and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
This response will be provided in a future update.