ML13242A015

North Anna, Units 1 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 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 COMPANYRICHMOND, VIRGINIA 23261August 23, 201310 CFR 2.202EA-12-051 Attention:

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

Docket Nos.:License Nos.:12-166DR250-338/339 NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS I 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 ElectricMarch 12, 2012Spent Fuel Pool2012 (Serial No.5. Virginia ElectricMarch 12, 2012Spent Fuel Pool2013 (Serial No.6. Virginia Electricand Power Company's Initial Status Report in Response toCommission Order Modifying Licenses with Regard to ReliableInstrumentation (Order Number EA-12-051),

dated October 25,12-166A)and Power Company's Overall Integrated Plan in Response toCommission Order Modifying Licenses with Regard to ReliableInstrumentation (Order Number EA-12-051),

dated February 28,12-166B)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 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 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 2.4oc(

Serial No. 12-166DDocket Nos. 50-338/339 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 VIRGINIA)COUNTY OF HENRICOThe 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 of A! .: ,2013.My Commission 61- ZlD,4.RAG D SLYNotary PublicCommonwealth of VirginiaReg. # 7518653 ibblicMy Commission Expires December 31, 20LbF....................lic Serial No. 12-166DDocket Nos. 50-338/339 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 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. K. R. Cotton GrossNRC Project Manager SurryU. 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 North Anna Power StationMr. J. E. Reasor, Jr.Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 3004201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 12-166DDocket 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 forReliable Spent Fuel Pool Instrumentation North Anna Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)

Serial No. 12-166DDocket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Page 1 of 3Six Month Status Report for the Implementation of Order EA-12-051 1 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." Submit OIP" Commence 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.

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

Serial No. 12-166DDocket Nos. 50-338/339 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 North Anna Power Station Units 1 and 2 as required by the Order (Reference 1). OnMay 28, 2013, Dr. V. Sreenivas, the NRC Project Manager for North Anna PowerStation, provided a Request for Additional Information (RAI) in an email to Mr. DavidHeacock, President and Chief Nuclear Officer of Dominion, regarding the North AnnaSFP LI system OIP. By letter dated July 2, 2013, Dominion submitted its response tothe RAI (Reference 3).The following are changes to the information provided in the North Anna OIP assupplemented by the North Anna RAI response.

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

The locationindicated in the RAI response is being updated to indicate that the display unitsare now being relocated to within the boundary of the Main Control Room. Finaldesign details are still scheduled to be completed by December 2013 (seeMilestone status table, Section 3) and will be forwarded to the NRC in theFebruary 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 aredesign and installation configuration differences from those originally indicated inthe OIP and the RAI response.

Further details of the probe design andinstallation will be available upon completion of the final design, scheduled to becompleted by December 2013 (see Milestone status table, Section 3), and will beforwarded 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 ofthe NRC and Ms. Margaret Earle of Dominion, the formal calculation performed to verify that adequate water level is available to support net positive suctionhead (NPSH) has been completed and independently reviewed.

Results of thecalculation confirm the Level 1 value of 286.6 feet specified in the RAI responseis 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. 12-166DDocket Nos. 50-338/339 Six Month Status Report -Order EA-12-051 Attachment Page 3 of 36 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. 12-166B, dated February 28, 2013.2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to ReliableSpent 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.12-166C, dated July 2, 2013.4. Calculation CALC-MISC-1 1798, Rev. 0, Add 0, "Dominion Fleet Spent Fuel PoolLevels to Provide Adequate NPSH to the Cooling Pumps with a Saturated Pool".