ML13247A290

First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant

ML13247A290
Person / Time
Site:	Browns Ferry
Issue date:	08/28/2013
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051
Download: ML13247A290 (9)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 August 28, 2013 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ML12054A679)

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 (ML12221A339)

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 (ML12240A307)

4. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) - Initial Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated October 29, 2012 (ML12307A105)

5. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant," dated February 28, 2013 (ML13063A437)

Ao Printed on recycled paper R _(,

U.S. Nuclear Regulatory Commission Page 2 August 28, 2013 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directs TVA to install reliable spent fuel pool level instrumentation (SFPLI). The specific requirements are outlined in Attachment 2 of Reference 1.

Reference I 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 V, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the TVA initial status report regarding SFPLI strategies. Reference 5 provided the TVA Browns Ferry Nuclear Plant, Units 1, 2, and 3 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2 of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since submittal of the overall integrated plan, including any changes to the compliance method or schedule.

The enclosure describes the plans that TVA will use to meet the regulatory requirements outlined in Attachment 2 of Reference 1, but does not identify any additional actions to be taken by TVA. Therefore, this letter contains no regulatory commitments.

If you have any question regarding this submittal, please contact Kevin Casey at (423) 751-8523.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2013.

Res ec ully, J. W. Shea Vice President, Nuclear Licensing

Enclosure:

Tennessee Valley Authority Browns Ferry Nuclear Plant's First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 August 28, 2013 cc (Enclosure):

NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRC Regional Administrator - Region II NRC Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

U.S. Nuclear Regulatory Commission Page 4 August 28, 2013 KEC Enclosure bcc (Enclosure):

S. M. Bono S. D. Brown K. E. Casey E. W. Cobey G. M. Cook S. M. Douglas J. E. Emens C. J. Gannon D. L. Hughes S. W. Hunnewell D. E. Jernigan J. R. Morris K. J. Poison D. H. Schavey E. D. Schrull J. W. Shea A. L. Sterdis P. B. Summers P. D. Swafford E. J. Vigluicci B. A. Wetzel R. J. Whalen P. R. Wilson EDMS

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT'S FIRST SIX-MONTH STATUS REPORT IN RESPONSE TO THE MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

ENCLOSURE I Introduction Browns Ferry Nuclear Plant (BFN) developed an Overall Integrated Plan (Reference 1 in Section 8 of this Enclosure), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPLI), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method or schedule.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 30, 2013.

• A design kickoff meeting has been completed.

• Response to BFN Request for Additional Information (RAI) is complete (Reference 3).

3 Milestone Schedule Status The following updates the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

The milestone target completion dates do not impact the order implementation date.

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Target Revised Milestone Completion Activity Target Date Status Completion Date_ Date Submit 60 Day Status Report 10/29/2012 Complete Submit Overall Integrated Plan 02/28/2013 Complete Submit 6 Month Updates:

Update 1 08/28/2013 Complete Update 2 02/28/2014 Not Started Update 3 08/28/2014 Not Started Update 4 02/28/2015 Not Started Update 5 08/28/2015 Not Started Update 6 02/282016 Not Started Update 7 08/28/2016 Not Started RAI response 07/18/2013 Complete Modifications:

Unit 1 Design Engineering 06/30/2014 Design started 09/02/2014 Unit 1 Installation 11/15/20161 Not Started 09/26/2016 Unit 2 Design Engineering 03/31/2014 Design started 09/02/2014 Unit 2 Installation 04/28/20151 Not Started 10/28/2014 Unit 3 Design Engineering 06/30/2014 Design started 09/02/2014 Unit 3 Installation 04/12/2016' Not Started 08/24/2015 Procedures:

Create Procedures 2 10/31/2014 Not Started Training:

Develop Training Plan 2 09/30/2014 Not Started Training Complete 2 03/31/2015 Not Started Full Site SFP LI Implementation 11/15/201.6 Not Started Submit Completion Report 12/15/2016 Not Started Notes: 1. The original target completion dates for implementation for Units 1, 2, and 3 corresponded to the completion of the second refueling outage of the respective unit following submittal of the February 28, 2013 integrated plan. Implementation of the SFPLI is currently scheduled to be performed on-line as indicated by the revised target completion dates.

2. These milestones were not included in the February 28, 2013, Overall Integrated Plan.

4 Changes to Compliance Method The primary and backup instrument channel battery life was anticipated to exceed 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> in the February 2013 Integrated Plan. A preliminary battery life calculation has been completed.

TVA is updating the anticipated battery life to 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> to provide margin for issues that may arise during the design process.

There are no other changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

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5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Browns Ferry Nuclear Plant (BFN) 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 NRC Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the NRC Evaluation and the status of each item.

Overall Integrated Plan Open Item Status 01-1) TVA will complete an instrument channel Engineering and vendor uncertainty calculation and document instrument documentation are in progress.

channel accuracy and calibration requirements. This will complete on the Design Engineering milestone shown above.

01-2) TVA plans to utilize Guided Wave Radar Engineering and vendor technology. Confirm final technology selection after documentation are in progress.

contracts are complete. This will complete on the Design Engineering milestone shown above.

01-3) Confirm that the sensor cable and light weight at Engineering and vendor the bottom of sensor cable will not damage the SFP liner documentation are in progress.

from impact during seismic event. This will complete on the Design Engineering milestone shown above.

01-4) After detailed engineering design is complete, Engineering and vendor confirm that SFP level channel components and cable documentation are in progress.

routing will be contained within seismic structures such This will complete on the Design that the installation will comply with the reasonable Engineering milestone shown protection guidance of NEI 12-06. above.

Draft Safety Evaluation Open Item Status None N/A 7 Potential NRC Evaluation Impacts There are no potential impacts to the NRC Evaluation identified at this time.

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

1. Letter from TVA to NRC, "Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) for Browns Ferry Nuclear Plant," dated February 28, 2013.

2. NRC Order Number EA-1 2-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

3. Letter from TVA to NRC, "Response to NRC Request for Additional Information Regarding Overall integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0881, MF0882, and MF0883)," dated July 18, 2013.

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