ML13242A015

Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

ML13242A015
Person / Time
Site:	North Anna
Issue date:	08/23/2013
From:	Grecheck E S Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-166D, EA-12-051
Download: ML13242A015 (7)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 23, 2013 10 CFR 2.202 EA-12-051 Attention:

Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Serial No.: NL&OS/MAE:

Docket Nos.: License Nos.: 12-166D R2 50-338/339 NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS I AND 2 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)

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 4. Virginia Electric March 12, 2012 Spent Fuel Pool 2012 (Serial No.5. Virginia Electric March 12, 2012 Spent Fuel Pool 2013 (Serial No.6. Virginia Electric and Power Company's Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Reliable Instrumentation (Order Number EA-12-051), dated October 25, 12-166A)and Power Company's Overall Integrated Plan in Response to Commission Order Modifying Licenses with Regard to Reliable Instrumentation (Order Number EA-12-051), dated February 28, 12-166B)and Power Company's March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), Request for Additional Information (RAI) Response, dated July 2, 2013 (Serial No. 12-166C)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference

1) to Virginia Electric and Power Company (Dominion).

Reference 1 was immediately effective and directs Dominion 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 2.4oc(

Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Page 2 of 3 Reference 4 provided Dominion's initial status report regarding mitigation strategies, Reference 5 provided Dominion's overall integrated plan, and Reference 6 provided a response to a request for additional information (RAI).Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The six-month status report (pursuant to Section IV, Condition C.2, of Reference

1) delineates the progress made in implementing the requirements of Reference 1 and is provided as an attachment to this letter. The attached report provides an update of milestone accomplishments since the response to the RAI (Reference

6) including any changes to the compliance method, schedule, or need for relief and the basis, if any.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely, Eugene S. Grecheck Vice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA)COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Eugene S. Grecheck who is Vice President Nuclear Engineering and Development of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this of A! .: ,2013.My Commission 61- ZlD,4.RAG D SLY Notary Public Commonwealth of Virginia Reg. # 7518653 ibblic My Commission Expires December 31, 20LbF....................lic Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. K. R. Cotton Gross NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 D2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr.Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Six Month Status Report for the Implementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Page 1 of 3 Six Month Status Report for the Implementation of Order EA-12-051 1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference

1) documenting the requirements to install reliable spent fuel pool level instrumentation (SFP LI) in response to Order EA-12-051 (the Order) (Reference 2). This attachment provides an update of milestone accomplishments since submittal of the OIP including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.2 Milestone Accomplishments The following milestones have been completed since the development of the OIP and are current as of July 31, 2013." Submit OIP" Commence Engineering and Design 3 Milestone Schedule Status The following table provides an update to the milestone schedule supporting the OIP.This table provides the activity status of each item and the expected completion date noting any change. The target completion dates are subject to change as design and implementation details are developed.

Revised Milestone Target Activity Target Completion Date Status Completion Date Submit OIP February 2013 Complete Commence Engineering and Design March 2013 Complete Complete Engineering and Design September 2013 Started December 2013 Complete Procurement of SEP December 2013 Started May 2014 Instruments Commence Installation of SFP March 2014 Not Started Instruments Level Measurement System September 2014 Not Started Functional The revised milestone target completion dates do not impact the Order implementation date for North Anna Power Station.

Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Page 2 of 3 4 Changes to Compliance Method By letter dated February 28, 2013, Dominion provided an OIP to address reliable SFP LI at North Anna Power Station Units 1 and 2 as required by the Order (Reference 1). On May 28, 2013, Dr. V. Sreenivas, the NRC Project Manager for North Anna Power Station, provided a Request for Additional Information (RAI) in an email to Mr. David Heacock, President and Chief Nuclear Officer of Dominion, regarding the North Anna SFP LI system OIP. By letter dated July 2, 2013, Dominion submitted its response to the RAI (Reference 3).The following are changes to the information provided in the North Anna OIP as supplemented by the North Anna RAI response.

These changes do not alter Dominion's compliance method with NEI 12-02.a) The location of the display units provided in the RAI response was based on conceptual design information and indicated that the display units would be located in the Cable Spreading Room in the Service Building.

The location indicated in the RAI response is being updated to indicate that the display units are now being relocated to within the boundary of the Main Control Room. Final design details are still scheduled to be completed by December 2013 (see Milestone status table, Section 3) and will be forwarded to the NRC in the February 2014 six month status update.b) The SFP LI system continues to utilize Guided Wave Radar technology; however, the level sensor manufacturer has changed. Accordingly, there are design and installation configuration differences from those originally indicated in the OIP and the RAI response.

Further details of the probe design and installation will be available upon completion of the final design, scheduled to be completed by December 2013 (see Milestone status table, Section 3), and will be forwarded to the NRC in the February 2014 six month status update. Completion of procurement of the SFP instruments has been rescheduled to May 2014.c) As discussed in an August 6, 2013, teleconference between Dr. V. Sreenivas of the NRC and Ms. Margaret Earle of Dominion, the formal calculation performed to verify that adequate water level is available to support net positive suction head (NPSH) has been completed and independently reviewed.

Results of the calculation confirm the Level 1 value of 286.6 feet specified in the RAI response is HIGHER than the minimum NPSH value of 284.4 feet (Reference 4).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the order implementation date and no relief/relaxation is required at this time.

Serial No. 12-166D Docket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Page 3 of 3 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation No update is required since there were no open items identified in the OIP submittal and the Draft Safety Evaluation has not been issued.7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.8 References The following references support the updates to the OIP described in this attachment:

1. "Dominion's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," Serial No. 12-166B, dated February 28, 2013.2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.3. "March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), Response to Request for Additional Information (RAI)," Serial No.12-166C, dated July 2, 2013.4. Calculation CALC-MISC-1 1798, Rev. 0, Add 0, "Dominion Fleet Spent Fuel Pool Levels to Provide Adequate NPSH to the Cooling Pumps with a Saturated Pool".