ML14059A077
| ML14059A077 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/28/2014 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, PNP 201 4-010 | |
| Download: ML14059A077 (12) | |
Text
~ Entergy w, #aicra, I
1tt7 Entergy Entergy Nuclear Palisades 27780 Blue Covert, Nuclear Operations, Palisades Nuclear 27780 Blue Star Covert, MI Tel Tel 269 Operations, Inc.
Nuclear Plant Plant Star Memorial Inc.
Memorial Highway Ml 49043-9530 269 764 49043-9530 764 2000 2000 Highway Anthony J.
Anthony J. Vitale Vitale Site Site Vice Vice President President 201 4-010 PNP 2014-010 PNP February 28, February 2014 28, 2014 u.s. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission ATTN: Document Document Control Desk Desk 11555 Rockville 11555 Rockville Pike Pike Rockville, MD 20852 Rockville,
SUBJECT:
Palisades Nuclear Plant Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Fuel Pool Instrumentation Instrumentation (Order Number EA-12-051)
Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20
REFERENCES:
REFERENCES:
- 1. NRC Order Number EA-12-051, Order To Modify Licenses With Instrumentation, dated March 12, Regard To Reliable Spent Fuel Pool Instrumentation, 2012 (ADAMS Accession No. ML ML12054A612054A682) 82)
JLD-ISG-2012-03, Compliance with Order
- 2. NRC Interim Staff Guidance JLD-ISG-2012-03, EA- 12-051, Reliable Spent Fuel Pool Instrumentat EA-12-051, Instrumentation, ion, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML 12221 A339)
ML12221A3 39)
- 3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentat ion, Revision 1, Instrumentation," 1, dated August 2012 (ADAMS Accession Accession No. No. ML1 2240A307)
ML12240A307) 4.
- 4. Entergy Nuclear Nuclear Operations, Operations, Inc.
Inc. (ENO) letter letter to to NRC, NRC, PNP PNP 2012-092, 2012-092, Initial Status Report in Response to March 12, 2012 Commission Order 12,2012 Modifying Licenses Licenses with Regard to Reliable Reliable Spent Spent Fuel PoolPool Instrumentat Instrumentation ion (Order Number EA- dated October 12-05 1), dated EA-12-051), October 25, 25,2012 2012 (ADAMS (ADAMS Accession Accession No.No. ML1 2300A067)
- 5. Entergy
- 5. Entergy Nuclear Nuclear Operations, Operations, Inc.
Inc. (ENO)
(ENO) letter letter to to NRC, NRC, PNP PNP 2013-009, 2013-009, Overall Integrated Overall Integrated Plan Plan in in Response Response to to March March 12, 12,2012 Commission 2012 Commission Order Order Modifying Modifying License License With Regard Regard to to Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentat Instrumentation ion (Order (Order Number Number EA- 12-05 1), dated EA-12-051), dated February February 28, 28,2013 2013 (ADAMS (ADAMS Accession Accession No.No. ML13060A3 ML13060A360) 60)
NRC Interim
- 6. NRC
- 6. Interim Staff Staff Evaluation, Evaluation, Palisades Palisades -Interim Staff Evaluation Interim Staff Evaluation and and Request Request for for Additional Additional Information Information Regarding Regarding the the Overall Overall Integrated Integrated Plan for Implementat Plan for Implementation ion of of Order Order EA- 12-05 1, Reliable EA-12-051, Reliable Spent Spent Fuel Fuel Pool Pool Instrumentat Instrumentation ion (TAC (TAC No.No. MFO769 MF0769), ), dated dated November November 26, 26,2013 2013 (ADAMS (ADAMS Accession Accession No.No. ML13312A4 ML13312A423) 23)
PNP 2014-010 PNP 201 4-010 Page 22 of Page of 22 Dear Sir Dear Sir or or Madam:
Madam:
On March On March 12, 12, 2012, 2012, the Nuclear Regulatory the Nuclear Regulatory Commission Commission (NRC)
(NRC) issued issued anan order order (Reference 1)
(Reference 1) to to Entergy Entergy Nuclear Nuclear Operations, Operations, Inc. (ENO). This Inc. (END). This order order was immediately immediately effective and directed ENO effective ENO to install install reliable reliable spent spent fuel pool level instrumentation pool level instrumentation at the Palisades Nuclear Palisades Nuclear Plant Plant (PNP).
(PNP).
Reference 11 required submission Reference submission of an initial status report 60 days following issuance of the staff guidance final interim staff guidance (Reference 2) and and an overall integrated plan pursuant to Section IV, Condition C. Reference 11 requires submission of a status report report at six-month intervals following submittal of the overalloverall integrated plan.
plan. Reference 3 provides provides direction regarding the content of the status reports. Reference 2 endorses industry guidance NEI 12-02, Revision 11 (Reference 3) with clarifications and exceptions identified in document NEI12-02, Reference 2. Reference 4 provided the PNP initial status report regarding mitigation strategies. Reference 5 provided the PNP overall integrated plan. Reference 6 contains a request for additional information regarding the overall integrated plan for implementation of EA-12-051..
Order EA-12-051 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 also provides information in response to the request for additional information in Reference 6.
This letter contains no new commitments and no revised commitments.
II declare under penalty of perjury that the foregoing is true and correct; executed on February 28, 2014.
Sincerely, 4/) /{
ajv/jse
Attachment:
Palisades Palisades Nuclear Nuclear Plant Second Second Six-Month Status Status Report in in Response Response to March March 12,12, 2012 2012 Commission Commission Order Order Modifying Licenses withwith Regard to to Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation (Order (Order Number Number EA-12-051)
EA-12-051) cc:
cc: Office Office Director, Director, NRR, NRR, USNRC USNRC Administrator, Administrator, Region Region Ill, III, USNRC USNRC Project Project Manager, Manager, Palisades, Palisades, USNRC USNRC Resident Resident Inspector, Inspector, Palisades, Palisades, USNRC USNRC
Attachment Attachment Palisades Nuclear Palisades Nuclear PlantPlant Second Second Six-Month Six-Month StatusStatus ReportReport in in Response to Response to March March 12, 12, 2012 2012 Commission Commission Order Order Modifying Modifying Licenses Licenses with Regard to Reliable with Regard to Reliable Spent Fuel Pool Spent Fuel Pool Instrumentation Instrumentation (Order (Order NumberNumber EA-12-0S1)
EA-12-051) 11 Introduction Introduction Entergy Nuclear Entergy Nuclear Operations, Operations, Inc.
Inc. (ENO)
(ENO) developed developed forfor Palisades Palisades Nuclear Nuclear Plant Plant (PNP)
(PNP) anan overall integrated plan (Reference overall integrated plan (Reference 1), 1), documenting the requirements requirements to install reliable to install reliable spent fuel pool fuel pool level level instrumentation instrumentation (SFPI),
(SFPI), inin response response to Reference Reference 2. This This attachment attachment provides provides an an update of milestone accomplishm of milestone accomplishments ents since the the last report, including status report, including any changes compliance method, schedule, or to the compliance or need need for relief/relaxation relief/relaxation and thethe basis, ifif any.
2 Accomplishments Milestone Accomplishments The following milestone(s) have been completed since July 31,2013, 31, 2013, and are current as of January 31 31,, 2014:
- Response to NRC request for additional information dated July 18, 2013 (Reference 3).
- Although not part of the original milestone schedule, ENO received an Interim Staff Evaluation (ISE) for PNP from the NRC on November 26, 26,2013 2013 (Reference 4). The ISE also includes requests for additional information (RAls) (RAIs) for NRC staff to complete its review. NRC staff clarified during the November 26, 2013, public meeting that the Interim Staff Evaluation questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentat ion (Reference 5).
instrumentation Therefore, the RAIs RAls dated July 18, 18, 2013 (Reference 3), are considered superseded by the RAIs RAls contained in the ISE. The addition of this milestone and target completion date does not not impact the Order implementat implementation date.
ion date.
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33 Milestone Schedule Milestone Schedule Status Status The following provides The following provides aa line item update line item update to milestone schedule to milestone schedule to support the to support the Overall Overall Integrated Plan. It provides Integrated Plan. It provides the activity status of activity status of each each item, item, and and whether whether thethe expected expected completion date completion date has changed. The has changed. The dates are planning dates are planning dates dates subject subject to change as to change as design design and implementati on details and implementation details are developed.
are developed.
Target Completion Revised Target Revised Target Activity Milestone Milestone Datett Completion Completion Date Status Status Date Date Reliable SFPI Installed Reliable Installed Fall 2015 Refueling Fall Refueling In Progress In Progress N/A N/A Outage Response to NRC Request for Additional Information 19, 2013 August 19,2013 Submitted N/A (received July 18, 2013)
August 19, (Reference 3) 2013 Response to NRC ISE Request for Additional 31, 2015 March 31,2015 See Section 6 N/A Information (received November 26, 2013) tTarget Completion Date is the last submitted date from either the overall integrated plan or tTarget previous six-month update.
4 Changes to Compliance Method Attachment 11 of the Overall Integrated Plan (Reference 1) shows Channel A mounted against the north wall near the northwest corner of the Spent Fuel Pool (SFP). (SFP). The location of Channel A has been moved to the west wall near the northwest corner of the SFP. See Section 7 for additional discussion. Section 7 also contains a figure with the new cable routing for the SFP area.
Section 6 of the Overall Integrated Plan Plan states that SFPI cables in the SFP area area shall be routed in seismically mounted mounted rigid metal conduit. This is true for the coaxial cable, but does not apply to the Si0 2
Si02 stainless steel armored cable. See Section 7 for additional discussion.
Attachment 2 of the Overall Integrated Integrated Plan shows SFPI Channel A being powered by MCC-7 MCC-7 via via Lighting Panel EL-25.
EL-25. SFPI Channel Channel A will now be powered by MCC-1 via Lighting Panel EL-25B.
EL-25B.
55 Need Need for Relief/Relax Relief/Relaxation ation and Basis for the Relief/Relax Relief/Relaxation ation ENO expects ENO to comply expects to comply with with the the order order implementati implementation date and on date and nono relief/relaxat relief/relaxation is required ion is required at this time.
at 22 of of 10 10
66 Open Open Items Items fromfrom Overall Overall Integrated Integrated Plan Plan and and Interim Interim StaffStaff Evaluation Evaluation As discussed As discussed in in Section Section 2, 2, ENO ENO hashas received received an Interim Staff an Interim Evaluation for Staff Evaluation for PNP PNP that that includes 18 RAIs. Responses to the includes 18 RAls. Responses to the RAls are RAIs are duedue by by March March 31,2015, 31, 2015, and and are discussed in are discussed in Section 99 of Section of this this six-month six-month status status report.
report. The The following following table provides aa status table provides status of of the the RAls RAIs documented in documented in the the Interim Staff Evaluation.
Interim Staff Evaluation.
RAI #
RAI# Response Status Response Status 11 Progress In Progress In 22 InIn Progress Progress 33 In Progress In Progress 4 Progress In Progress 5 In Progress 6 In Progress In Progress 7 In Progress 8 In Progress 9 In Progress 10 In Progress 11 In Progress 12 In Progress 13 13 In Progress 14 In Progress 15 In Progress 16 16 In Progress 17 17 In Progress 18 18 In Progress 33 of of 1010
77 Potential Interim Potential Interim Staff Staff Evaluation Evaluation Impacts Impacts Section 3.4 Section 3.4 of of the the Interim Interim Staff Staff Evaluation Evaluation discusses discusses the the arrangement arrangement of of the the SFPI SFPI channels channels and references and references thethe sketch sketch in in Attachment Attachment 11 of of the Overall Integrated the Overall Integrated Plan.
Plan. As discussed in As discussed in Section 4, the Section the location location of of the the Channel Channel A levellevel instrument instrument has has been been moved moved to to the the west west SFP SEP waIl, within 12" wall, 12 of of the the northwestnorthwest SFP SEP corner.
corner. The The updated updated sketch sketch of of the the SFPI SFPI arrangement arrangement showing the new cable the new cable routing routing is provided below is provided below in in Figure Figure 1.
1.
__ _ _ j .... ,_* , ' 1 I I '~
_ -.=- -- ' -'
= :-- "?_=.
' -' - =1J
-- ,: ' ~ - o;. ~' ** :;~ '. '.~ :,. * ",: ".
-~ "'-
SEP Area Plan View Figure 1: SFP Section 3.4 of the Interim Staff Evaluation also refers to a statement that declares cables in the SEP SFP area will be routed in seismically mounted rigid metal conduit. It should be noted that this statement does not apply to the first 20 ft. of cable run, which is comprised of SiC Si02 2
stainless steel armored cable. The SiC 2 Si0 2 stainless steel armored cable then transitions to coaxial cable, at which point the coaxial cable will be installed in seismically mounted rigid metal conduit for the remainder of the run in the SEP SFP area. This cable installation is applicable to both Channel A and Channel B. B.
There are no no additional potential potential impacts to to the Interim Interim Staff Staff Evaluation identified at this time except for those those identified in Section 6.
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88 References References The following The following references references support support the the updates updates to to the the overall overall integrated integrated plan plan described described inin this this attachment.
attachment.
- 1. ENO
- 1. ENO letter letter to to NRC, NRC, PNP PNP 2013-009, 2013-009, Overall Overall Integrated Integrated Plan Plan in in Response Response to to March March 12,12, 2012 Commission 2012 Commission Order Modifying License Order Modifying License WithWith Regard Regard toto Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation (Order Instrumentation (Order Number Number EA-12-051),
EA- 12-051), dated dated February February 28,2013 28, 2013 (ADAMS (ADAMS Accession No.
Accession No. MLML113060A360) 3060A360)
- 2. NRC
- 2. NRC Order Order Number Number EA-12-051, EA-12-051, Order Order ToTo Modify Modify Licenses Licenses With Regard To With Regard To Reliable Reliable Spent Fuel Pool Instrumentat ion, dated March Spent Fuel Pool Instrumentation, dated March 12,2012 12, 2012 (ADAMS (ADAMS Accession Accession No.No.
ML 2054A682)
- 3. NRC
- 3. NRC email ENO, Palisades email to ENO, Palisades Nuclear Nuclear Plant Plant - Requests Requests forfor Additional Information Information Regarding Overall Overall Integrated Plan Plan for Reliable Rellable Spent Spent Fuel Pool Pool Instrumentation Instrumentation (TAC (TAC MFO769), dated July MF0769), July 18, 18, 2013 (ADAMS (ADAMS Accession No. No. ML ML13200A313200A328) 28)
Pailsades -Interim
- 4. NRC letter to ENO, Palisades Interim Staff Staff Evaluation andand Request for Additional Information Regarding the the Overall Integrated Plan for Implementation Implementation of of Order EA EA Instrumentation (TAC NO. MF0769), dated November 051, Reliable Spent Fuel Pool Instrumentation November 26, 2013 (ADAMS Accession No. ML ML113312A423) 331 2A423)
- 5. Summaiy of the November Summary November26 26,, 2013, Public Publlc Meeting to Discuss Industry Responses to Instrumentation, dated December 26, Staff Interim Evaluations for Spent Fuel Pool Instrumentation, 2013 (ML (ML1133478030).
3347B030).
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Responses to 99 Responses to thethe Interim Interim Staff Staff Evaluation Evaluation RequestsRequests for for Additional Information Additional Information RAI #1 RAI#1 Given the Given the potential potential for for varied varied dose dose rates from other rates from other materials materials stored stored in in the the SFP, SFP, please please describe how describe how level will be level 22 will be adjusted adjusted to other than to other than the the elevation elevation provided provided in section 22 above.
in section above.
ENO Response:
ENO Response:
This response This response will will be provided in be provided in aa future future update.
update.
RAI #2 RAI#2 Please provide the analyses verifying the analyses verifying the seismic capability of the the level probes, the mounting brackets, and the electronics units, and provide the results of of the analysis analysis of thethe combined hydrodynamic forces on the cantilevered maximum seismic and hydrodynamic cantilevered portion of of the assembly exposed to the potential sloshing effects. Show that the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure.
ENO Response:
This response will be provided in a future update.
RAI#3 For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/eq uipment.
structures/equipment.
ENO Response:
This response will be provided in a future update.
RAI RAI#4#4 Please address address how how other other hardware hardware stored stored in in the the SFP SFP will will not not create create adverse adverse interaction interaction with the fixed instrument location(s).
ENO ENO Response:
Response
This This response response will be provided will be provided in in aa future future update.
update.
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RAI #5 RAI#5 Please provide Please provide analysis analysis of of the maximum expected the maximum expected radiological radiological conditions conditions (dose (dose rate rate and and total total integrated dose) integrated dose) to which the to which the sensor sensor electronics electronics will will be be exposed.
exposed. Also, Also, please please provide provide documentation indicating documentation indicating the radiological dosage the radiological dosage thethe electronics electronics for for this this equipment equipment areare capable capable of of withstanding.
withstanding. Please Please discuss discuss thethe time time period period over which the over which the analyzed analyzed total total integrated dose integrated dose is is evaluated evaluated to to be be applied.
applied.
ENO Response:
ENO Response:
This response This response will will be provided in be provided in aa future future update.
update.
RAI #6 RAI#6 Please provide information Please information indicating indicating the maximum expected the maximum expected ambient ambient temperature temperature in in the the which the room in which the sensor electronics will will be be located under under BOB BDB conditions with with no ac power Ventilation and Air Conditioning available to run Heating Ventilation Conditioning (HVAC) systems, and whether the sensor electronics are capable of continuously sensor continuously performing required functions under this temperature condition.
expected temperature ENO Response:
This response will be provided in a future update.
This RAI #7 RAI#7 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BOB BDB conditions, with no ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition.
ENO Response:
The response will be provided in a future update.
RAI RAI#8 #8 Please provide a description of the specific method method or combination of methods that will be used toto demonstrate the reliability of the permanently installed installed equipment equipment under under BDB BDB shock and and vibration conditions.
conditions. Identify Identify the specific specific commercial and/or andlor military military standards that will be be used used to establish the testing requirements requirements,, and and the specific specific acceleration levels andand frequencies that will will be be simulated.
simulated.
ENO ENO Response:
Response
This This response response will be provided will be provided in in aa future future update.
update.
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- 9
- 9 For RAI For RAI #8#8 above, above, please please provide provide the the results results for for the the selected selected methods, methods, tests tests and and analyses analyses used to used to demonstrate demonstrate the the qualification qualification and and reliability reliability of of the the installed installed equipment equipment in in accordance accordance with the with the Order Order requirements.
requirements.
ENO Response:
ENO Response:
This response This response will will be provided in be provided in aa future future update.
update.
RAI#1O RAI#10 Please provide Please provide an an evaluation evaluation ofof the the vendor vendor analysis analysis andand seismic seismic testing testing results results and and show show that that the instrument performance reliability, the instrument reliability, following following exposure exposure to to simulated simulated seismic seismic conditions conditions representative of the environment anticipated for the representative SFP structures at Palisades, the SFP Palisades, has been adequately demonstrated.
adequately demonstrated.
Response
ENO Response:
This response will be provided in a future update.
RAI #11 RAI#11 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.
ENO Response:
This response will be provided in a future update.
RAI #12 RAI#12 Please provide the results of the calculation depicting the battery backup backup duty cycle requirements demonstratin demonstrating g battery capacity is sufficient to maintain the level indication function until offsite resource availability availability is reasonably assured.assured.
ENO Response:
ENO This response response will will be be provided provided inin aa future update.
update.
RAI#13 RAJ #13
- Please, Please, provide provide anan analysis analysis verifying verifying the the proposed proposed instrument instrument performance performance is is consistent consistent with with these these estimated estimated accuracy accuracy normal normal and and BDB BOB values.
values. Please Please demonstrate demonstrate the the channels channels will will retain retain these these accuracy accuracy performance performance values following aa loss values following loss ofofpower power and and subsequent subsequent restoration restoration of ofpower.
power.
ENO ENO Response:
Response
This response This response will be provided will be provided in in aa future future update.
update.
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RAI #14 RAI #14 Please provide Please provide aa description description of of the the methodology methodology that that will will be used for be used for determining determhhg the the maximum allowed deviation maximum allowed deviation from from thethe instrument instrument channel channel design design accuracy accuracy to to be be employed employed under normal under normal operating operating conditions conditions as as an acceptance criterion an acceptance criterion for for aa calibration calibration procedure procedure to to alert operators alert operators and technicians of and technicians of the the need need for for adjustment adjustment to within normal to within normal design design accuracy.
accuracy.
ENO Response:
ENO Response:
This response This response will will be provided in be provided in aa future future update.
update.
RAI #15 RAI Please provide Please provide a description description of the in-situ of the calibration process h-situ calibration process at at the the SFP SFP location location that that will will result in result in the the channel channel calibration calibration being maintained maintained at at its its design design accuracy.
accuracy.
ENO Response:
ENO Response:
This response This response will be provided in a future update. update.
RAI#16 instrumentation backup display located in the radwaste control panel room, For the SFP level instrumentation please describe the evaluation used to validate the display location can be accessed without unreasonable delay following a BOB BDB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the backup display. Additionally walk-throughs) Additionally,,
please include a description of the radiological and environmental environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental environmental conditions following a BDB BOB event.
Describe whether personnel are continuously stationed at the backup display or monitor the display periodically.
ENO Response:
This response will be provided provided in in a future update.
update.
RAI#17 Please Please provide provide a list list of of the the procedures addressing addressing operation operation (both normalnormal and and abnormal abnormal response), calibration, calibration, test, maintenance maintenance,, and and inspection that will be be developed developed for use of of the SFP SFP instrumentati instrumentation.on. TheThe licensee licensee is is requested requested to include aa brief to hclude brief description description of of the the specific specific technical technical objectives objectives toto be be achieved achieved within within each each procedure.
procedure.
ENO ENO Response:
Response
This This response response will be provided will be provided in in aa future future update.
update.
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RAI#18 RAI#18 Please provide Please provide further further information information describing describing thethe maintenance maintenance and and testing testing program program the the licensee will establish and implement licensee will establish and implement to ensure to ensure that regular testing that regular testing and and calibration calibration isis performed and performed and verified verified by inspection and by inspection and audit audit to to demonstrate demonstrate conformance conformance withwith design design andand system readiness requirements system readiness requirements. Include a description
. Include a description of of your plans for your plans for ensuring ensuring that that necessary channel necessary channel checks, checks, functional functional tests, tests, periodic periodic calibration, calibration, and and maintenance maintenance willwill be be conducted for the level measuremen conducted for the level measurementt system and system and its its supporting supporting equipment.
equipment.
ENO Response:
ENO Response:
This response This response will will be provided in be provided in aa future future update.
update.
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