L-13-244, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

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First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)
ML13238A259
Person / Time
Site: Beaver Valley, Davis Besse, Perry
Issue date: 08/26/2013
From: Sena P
FirstEnergy Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
L-13-244, EA-12-051, TAC MF0799, TAC MF0800, TAC MF0802, TAC MF0960
Download: ML13238A259 (12)
v • d • e


Text

FENOG Fisl Energl Nucr*, O*rrn,Ua 76 South Main Street Akron. Ohio 44308 Peter P. Sena lll President and Chief Nuclear Officer August 26,2013 L-13-244 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 FirstEnerqy Nuclear Operatinq Companv's (FENOC's)

First Six-Month Status Report in

Response

to March 12. 2012 Commission Order Modifvins Licenses with Resard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC Nos. MF0799,

MF0800, MF0960, and MF0802)

On March 12,2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference

1) to FENOC. Reference 1 was immediately effective and directs FENOC to have a reliable indication of the water level in associated spent fuel storage pools. 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 lV, Condition C. Reference2 endorses industry guidance document Nuclear Energy Institute (NEl) 12-02, Revision 1 (Reference
3) with clarifications and exceptions identified in Reference
2. Reference 4 provided the FENOC initial status report regarding requirements for reliable spent fuel pool instrumentation.

Reference 5

provided the FENOC overall integrated plan for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS),

and Perry Nuclear Power Plant (PNPP).

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

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-13-244 Page 2 status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The attached reports for BVPS, DBNPS, and PNPP (Attachments 1, 2, and 3, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compfiance method, schedule, or need for relieflrelaxation and the basis, if any.

This letter contains no new regulatory commitments.

lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August a6,2013.

Respectfu lly su bm itted, p* g -/g-Peter P. Sena, lll Attachments:

1.

Beaver Valley Power Station First Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Davis-Besse Nuclear Power Station First Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Perry Nuclear Power Plant First Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

References:

1. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2A12 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, 2412 NEI 12-02,Industry Guidance for Compliance with NRC Order EA-12-051

, "To Modify Licenses with Regard t Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 2012 FirstEnergy Nuclear Operating Company's (FENOC's)

Initial Status Report in

Response

to March 12,2012, Commission Order Modifying Licenses with Regard 2.

3.

2.

3.

4.

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-13-244 Page 3 to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated October 26,2012

5.

FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in

Response

to March 12,2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated February 27, 2013 cc: Director, Office of Nuclear Reactor Regulation (NRR)

NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS)

NRC Resident Inspector (DBNPS)

NRC Resident Inspector (PNPP)

NRC Project Manager (BVPS)

NRC Project Manager (DBNPS)

NRC Project Manager (PNPP)

Ms. Lisa M. Regner, NRR/JLD/PMB, NRC Mr. Blake A. Purnell, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments)

Site BRP/DEP Representative (without Attachments)

Utility Radiological Safety Board (without Attachments)

L-13-244 Beaver Valley Power Station First Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 3 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference2. This attachment provides an update of milestone accomplishments since submittal of the OlP, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.

2 Milestone Accomplishments The following nrilestone(s) have been completed since the submittal of the OIP (Reference 1). This update is current as of July 29,2013.

. Commenced SFP instrumentation procurement.

FENOC issued the purchase order for two trains of reliable SFP Ll for each BVPS unit.

3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. 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 following milestones are being added as part of this update to reflect the submittal of each response to a request for additional information (RAl).

Submit Six-Month Status Updates o Update 1: August 2013 o Update 2, including response to RAI-1 (parts a and b), RAI-2, RAI-3, RAI-4, RAI-S, RAI-6, and RAI-7: February 2014 Update 3, including response to RAI-8, RAI-10, and RAI-1 1 : August-2014 Update 4: February 2015 o Update 5: August 2015 The revised milestone target completion dates do not impact the order implementation date.

L-13-244 Page 2 of 3 4 Ghanges to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

Milestone Target Completion Date Activity Status (as of 7129l,131 Revised Target Completion Date Submit Six-Month Status Updates (Unit Nos. I and 2)

Update 1 N/A Started Ausust 2013 Update 2, including response fo RAI-1 (parts a and b), RAI-2, RAI-3, RAI-4, RAI-I, RAI-6, and RAI-7 N/A Not Started Februarv 2014 Update 3, including response fo RAI-9, RAI-I0. and RAI-11 N/A Not Started Auqust 2014 Update 4 N/A Not Started February 2015 Update 5 N/A Not Started Ausust 2015 BVPS Unit No. I Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 4Q13 Started SFP Instrumentation Deliverv 2Q14 Not Started Besin SFP Instrumentation Installation 3Q14 Not Started Commissioninq of SFP Instrumentation 2Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)

Sprinq 2415 Not Started BVPS Unit No. 2 Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 4Q13 Started SFP Instrumentation Delivery 3Q14 Not Started Besin SFP Instrumentation Installation 4Q14 Not Started Commissioninq of SFP Instrumentation 4Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)

Fall 2015 Not Started L-13-244 Page 3 of 3 6 Open ltems from Overall Integrated Plan and Draft Safety Evaluation None.

7 Potential Draft Safety Evaluation lmpacts 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. FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in

Response

to March 12,2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 27, 2013.

2. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool lnstrumentation, dated March 12,2012.

L-13-244 Davis-Besse Nuclear Power Station First Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 3 lntroduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),

documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Referen ce 2. This attachment provides an update of milestone accomplishments since submittal of the OlP, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Mifestone Accomplishments The following milestone(s) have been completed since the submittal of the OIP (Reference 1). This update is current as of July 29,2013.

o Commenced SFP instrumentation procurement.

FENOC issued the purchase order for two trains of reliable SFP Ll.

3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. 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.

As of July 29,2013, the FENOC response to Reference 3 was in progress;

however, this response was subsequently submitted on August 12,2013. To assist in the review process, the following milestones are being added as part of this update to reflect the submittal of each response to a request for additional information (RAl).

Submit Six-Month Status Updates o Update 1: August 2013 o Update 2, including response to RAI-1, RAI-2, RAI-3, RAI-4, RAI-S, RAI-6, and RAI-7: February 2014 Update 3, including response to RAI-8, RAI-10, and RAI-1 1 : August 2014 o Update 4: February 2015 o Update 5: August 2015 o Update 6: February 2016 The revised milestone target completion dates do not impact the order implementation date.

L-13-244 Page 2 of 3 4 Changes to Gompliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for RelieflRelaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

6 Open ltems from Overall Integrated Plan and Draft Safety Evaluation None.

7 Potential Draft Safety Evaluation lmpacts There are no potential impacts to the draft safety evaluation identified at this time.

Milestone Target Completion Date Activity Status (as of 71291131 Revised Target Completion Date Submit Six-Month Status Updates Undate 1 N/A Started Ausust 2013 Update 2, including response fo RAI-I, RAI.z, RAI.s, RAI-4, RAI-', RAI-6, and RAI-7 N/A Not Started Februarv 2014 Update 3, including response fo RAI-8, RAI-10 and RAI-I1 N/A Not Started Auqust 2014 Update 4 N/A Not Started February 2015 Update 5 N/A Not Started Auqust 2015 Update 6 N/A Not Started February 2016 Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 1Q14 Started 4Q13 SFP Instrumentation Deliverv 4Q14 Not Started Begin SFP Instrumentation Installation 1Q15 Not Started Commissioninq of SFP Instrumentation 2Q16 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outaqe after imolementation plan submittal)

Sprinq 2016 Not Started L-13-244 Page 3 of 3 I

References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in

Response

to March 12,2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 27,2013.

2. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.
3. NRC Letter, Davis-Besse Nuclear Power Station, Unit 1 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool f nstrumentation (TAC No. MF0960),

dated July 17,2013.

Attachment 3

L-13-244 Perry Nuclear Power Plant First Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 3 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference2. This attachment provides an update of milestone accomplishments since submittal of the OlP, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the submittal of the OIP (Reference 1). This update is current as of July 29,2013.

o Commenced SFP instrumentation procurement.

FENOC issued the purchase order for two trains of reliable SFP Ll.

3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. 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 following milestones are being added as part of this update to reflect the submittal of each response to a request for additional information (RA11.

Submit Six-Month Status Updates o Update 1. August 2013 o Update 2, including response to RAI-1 (part c), RAI-2, RAI-3, RAI-4, RAI-S, RAI-6, and RAI-7: February 2014

. Update 3, including response to RAI-8, RAI-10, and RAI-1 1 : August 2014 Update 4: February 2015 The revised milestone target completion dates do not impact the order implementation date.

Attachment 3

L-13-244 Page 2 of 3 4 Changes to Gompliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

6 Open ltems from Overall lntegrated Plan and Draft Safety Evaluation None.

7 Potential Draft Safety Evaluation lmpacts There are no potential impacts to the draft safety evaluation identified at this time.

Milestone Target Completion Date Activity Status (as of 71291131 Revised Target Gompletion Date Submit Six-Month Status Updates Update 1 N/A Started Ausust 2013 Update 2, including response fo RAI-1 (part c), RAI-2, RAI-3, RAI-4, RAI-I, RAI-6, and RAI-7 N/A Not Started February 2414 Update 3, including response fo RAI-8, RAI-I0, and RAI-I1 N/A Not Started Auqust 2Q14 Update 4 N/A Not Started February 2015 Commence SFP Instrumentation Desion 4Q12 Complete Commence SFP I nstrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desisn 3Q13 Started 4Q13 SFP Instrumentation Deliverv 2Q14 Not Started Begin SFP Instrumentation lnstallation 3Q14 Not Started Commissionins of SFP Instrumentation 1Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)

Sprinq 2015 Not Started L-13-244 Page 3 of 3 8

References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in

Response

to March 12,2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February 27,2013.

2. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.
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