ML13242A016

Virginia Electric & Power Company Surry Power Station Units 1 & 2 Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel

ML13242A016
Person / Time
Site:	Surry
Issue date:	08/23/2013
From:	Grecheck E S Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk
References
EA-12-051
Download: ML13242A016 (7)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 2326110 CFR 2.202August 23, 2013 EA-12-051 Attention:

Document Control Desk Serial No.: 12-167CU.S. Nuclear Regulatory Commission NL&OS/MAE:

R4Washington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOLINSTRUMENTATION (ORDER NUMBER EA-12-051)

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation, dated March 12, 20122. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with OrderEA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation, Revision 0, dated August 29, 20123. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "ToModify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation",

Revision 1, dated August 20124. Virginia Electric and Power Company's Initial Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051),

dated October 25,2012 (Serial No. 12-167A)5. Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 28,2013 (Serial No. 12-167B)6. Virginia Electric and Power Company's March 12, 2012 Commission OrderModifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

Request for Additional Information (RAI) Response, dated August 8, 2013 (Serial No.13-416)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference

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

Reference 1 wasimmediately effective and directs Dominion to install reliable spent fuel pool levelinstrumentation.

Specific requirements are outlined in Attachment 2 of Reference 1.Reference 1 required submission of an initial status report 60 days following issuance ofthe final interim staff guidance (Reference

2) and an overall integrated plan pursuant toSection IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02,Revision 1 (Reference

3) with clarifications and exceptions identified in Reference

2.

Serial No. 12-167CDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-051 Page 2 of 3Reference 4 provided Dominion's initial status report regarding mitigation strategies, Reference 5 provided Dominion's Overall Integrated Plan, and Reference 6 provided aresponse 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 thecontent 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 therequirements of Reference 1 and is provided as an attachment to this letter. Theattached report provides an update of milestone accomplishments since the response tothe RAI (Reference

6) including any changes to the compliance method, schedule, orneed for relief and the basis, if any.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Eugene S. GrecheckVice President Nuclear Engineering and Development Attachment Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIACOUNTY 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 ofVirginia Electric and Power Company.

He has affirmed before me that he is duly authorized to executeand file the foregoing document in behalf of the Company, and that the statements in the document aretrue to the best of his knowledge and belief.Acknowledged before me this 2.day of Pu 2013.My Commission Expires:'

_ ol.J ....CRAIG D- LY...Notary PublicCommonwealth of VirginiaReg. # 7518653 tPbMy Commission Expires December 31, Serial No. 12-167CDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-051 Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257 Ms. K. R. Cotton GrossNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North AnnaU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. J. A. Kratchman U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 09 D211555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No. 12-167CDocket Nos. 50-280/281 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 forReliable Spent Fuel Pool Instrumentation Surry Power Station Units I and 2Virginia Electric and Power Company (Dominion)

Serial No. 12-167CDocket Nos. 50-280/281 Six Month Status Report -Order EA-1 2-051Attachment Page 1 of 3Six Month Status Report for the Implementation of Order EA-1 2-0511 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference

1) documenting therequirements to install reliable spent fuel pool level instrumentation (SFP LI) in responseto Order EA-12-051 (the Order) (Reference 2). This attachment provides an update ofmilestone accomplishments since submittal of the OIP including any changes to thecompliance 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 andare current as of July 31, 2013.00Submit OIPCommence Engineering and Design3 Milestone Schedule StatusThe 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 datenoting any change. The target completion dates are subject to change as design andimplementation details are developed.

Target Activity Revised TargetMilestone Completion Status Completion Date DateSubmit OIP Feb 2013 CompleteCommence Engineering and March 2013 CompleteDesignComplete Engineering and Design September 2013 Started December 2013Complete Procurement of SFP December 2013 Started May 2014Instruments Commence Installation of SFP June 2014 Not StartedInstruments Level Measurement System September 2014 Not StartedFunctional The revised milestone target completion dates do not impact the Order implementation date for Surry Power Station.

Serial No. 12-167CDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-051 Attachment Page 2 of 34 Changes to Compliance MethodBy letter dated February 28, 2013, Dominion provided an OIP to address reliable SFP LIat Surry Power Station Units 1 and 2 as required by the Order (Reference 1). OnJuly 11, 2013, Ms. Karen Cotton Gross, the NRC Project Manager for Surry PowerStation, provided a Request for Additional Information (RAI) in an email to Mr. DavidHeacock, President and Chief Nuclear Officer of Dominion, regarding the Surry SFP LIsystem OIP. By letter dated August 8, 2013, Dominion submitted its response to theRAI (Reference 3).The following are changes to the information provided in the Surry OIP andsupplemented by the Surry RAI response.

These changes do not alter Dominion's compliance method with NEI 12-02.a) As an update to the response to RAI la, the formal calculation performed toverify that adequate water level is available to support net positive suction head(NPSH) has been completed and independently reviewed.

Results of thecalculation confirm the Level 1 value of 42.2 feet specified in the RAI response isHIGHER than the minimum NPSH value of 40.4 feet (Reference 4). Thisinformation is being provided herein versus the February 2014 six month statusupdate.b) Completion of procurement of the SFP instruments has been rescheduled toMay 2014.5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date, and no requiredrelief/relaxation has been identified at this time.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 andthe Draft Safety Evaluation has not been issued.7 Potential Draft Safety Evaluation ImpactsThere 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. 12-167B, dated February 28, 2013.

Serial No. 12-167CDocket Nos. 50-280/281 Six Month Status Report -Order EA-12-051 Attachment Page 3 of 32. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation,"

dated March 12, 2012.3. "March 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Instrumentation (Order NumberEA-12-051),

Response to Request for Additional Information (RAI)," Serial No.13-416, dated August 8, 2013.4. Calculation CALC-MISC-11798, Rev. 0, Add 0, "Dominion Fleet Spent Fuel PoolLevels to Provide Adequate NPSH to the Cooling Pumps with a Saturated Pool."