L-15-001, Firstenergy Nuclear Operating Company'S (Fenoc'S) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool.: Difference between revisions

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{{#Wiki_filter:FENOC i"76 South Main StreetAkron. Ohio 44308 Samuel L. Belcher Senior Vice President and Chief Operating OfficerFebruary 26,2015 L-15-001ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001
{{#Wiki_filter:i" FENOC                                                                                            76 South Main Street Akron. Ohio 44308 Samuel L. Belcher Senior Vice Presidentand Chief Operating Officer February    26,2015 L-15-001                                                                        10cFR2.202 ATTN: Document         ControlDesk U.S.NuclearRegulatory          Commission Washington,     DC 20555-001


==SUBJECT:==
==SUBJECT:==
Beaver Valley Power Station, Unit Nos. 1 and 2Docket No.
 
50-334, License No. DPR-66Docket No.
BeaverValleyPowerStation,UnitNos.1 and2 DocketNo.50-334,LicenseNo.DPR-66 DocketNo.50-412,LicenseNo.NPF-73 Davis-Besse     NuclearPowerStation DocketNo.50-346,LicenseNo. NPF-3 PerryNuclearPowerPlant DocketNo.50-440,LicenseNo. NPF-58 FirstEnerqv    NuclearOperating        Company's   (FENOC's)     FourthSix-Month     StatusRgpo(
50-412, License No. NPF-73Davis-Besse Nuclear Power StationDocket No. 50-346, License No. NPF-3Perry Nuclear Power PlantDocket No. 50-440, License No. NPF-5810 cFR 2.202FirstEnerqv Nuclear Operating Company's (FENOC's)
in Response     to March12,2012Commission              OrderModifying    Liqenseg with Reqardto Reliable   SpentFuelPoolInstrumentation            (OrderNumberEA-12-051)
Fourth Six-Month Status Rgpo(in Response to March 12, 2012 Commission Order Modifying Liqenseg with Reqard 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) issuedan order (Reference
(TACNos.MF0799,MF0800.MF0960.andMF0802)
: 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 toSection lV, Condition C. Reference2 endorses industry guidance document Nuclear Energy lnstitute (NEI) 12-02, Revision 1 (Reference
On March12,2012,the NuclearRegulatory                  Commission     (NRCor Commission)     issued an order(Reference1) to FENOC.Reference1 was immediately                       effectiveand directs FENOCto havea reliableindication            of the waterlevelin associated     spentfuelstorage pools. Specificrequirements          areoutlinedin Attachment     2 of Reference   1.
: 3) with clarifications and exceptionsidentified in Reference 2. Reference 4 provided the FENOC initial status reportregarding requirements for reliable spent fuel pool instrumentation.
Reference1 requiredsubmission            of an initialstatusreport60 daysfollowingissuanceof the finalinterimstaffguidance(Reference             2) andan overallintegrated    planpursuantto SectionlV, Condition       C. Reference2       endorses   industry guidance   documentNuclear Energylnstitute    (NEI)   12-02,Revision1        (Reference   3) with clarificationsandexceptions identifiedin Reference2. Reference4 providedthe FENOCinitialstatusreport regardingrequirements        for reliablespentfuelpoolinstrumentation.           Reference 5 providedthe FENOCoverallintegrated              planfor BeaverValleyPowerStation(BVPS),
Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station (DBNPS), and Perry NuclearPower Plant (PNPP).Reference 1 requires submission of a status report at six-month intervals followingsubmittal of the overall integrated plan. Reference 3 provides direction regarding thecontent of the status reports. The purpose of this letter is to provide the fourth Beaver Valley Power Station, Unit Nos. 1 and 2Davis-Besse Nuclear Power StationPerry Nuclear Power Plant L-15-001 Page 2six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference
UnitNos.1 and2, Davis-Besse             NuclearPowerStation(DBNPS),and PerryNuclear PowerPlant(PNPP).
: 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 complian@
Reference1 requiressubmission            of a statusreportat six-monthintervals      following submittalof the overallintegrated          plan. Reference     3 providesdirectionregarding    the contentof the statusreports.The           purpose   of this letteris to provide the fourth
method, schedule, or need for relieflrelaxation and the basis, if any.The NRC staff also issued interim staff evaluations (References 6,7, and 8) that included requests for additional information (RAls). The NRC staff subsequently indicated the intention to complete the ongoing review of the responses to Reference 1by conducting audits and utilizing the ePortal system for review of RAI responses (Reference g). The attached reports have been updated to reflect this process change.This letter contains no new regulatory commitments.
 
lf you have any questionsregarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing,at 330-315-6810.
BeaverValleyPowerStation,UnitNos.1 and2 Davis-Besse NuclearPowerStation PerryNuclearPowerPlant L-15-001 Page2 six-monthstatusreportpursuantto SectionlV, ConditionC.2,of Reference         1, that delineates progressmadein implementing   the requirements   of Reference   1. The attachedreportsfor BVPS,DBNPS,and PNPP       (Attachments   1 , 2, and 3, respectively) providean updateof milestone accomplishments   sincethe laststatusreport,including anychangesto the complian@     method,schedule, or needfor relieflrelaxation   andthe basis,if any.
I declare under penalty of perjury that the foregoing is true and correct. Executed onFebruary Lb
The NRCstaffalsoissuedinterimstaffevaluations    (References   6,7, and8) that includedrequestsfor additional information(RAls).The NRCstaffsubsequently indicatedthe intentionto completethe ongoingreviewof the responsesto Reference1 by conductingauditsand utilizingthe ePortalsystemfor reviewof RAI responses (Referenceg). The attachedreportshavebeenupdatedto reflectthis processchange.
,2015.Respectfully, Samuel L. Belcher Attachments:1. Beaver Valley Power Station Fourth Six-Month Status Report for thelmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Z. Davis-Besse Nuclear Power Station Fourth Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation
Thislettercontainsno newregulatory  commitments. lf you haveanyquestions regarding this report,pleasecontactMr.ThomasA. Lentz,Manager- FleetLicensing, at 330-315-6810.
: 3. Perry Nuclear Power Plant Fourth Six-Month Status Report for the lmplementation of Oider EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent FuelPool Instrumentation
I declareunderpenaltyof perjurythatthe foregoingis true and correct.Executedon FebruaryLb ,2015.
Respectfully, SamuelL. Belcher Attachments:
: 1. BeaverValleyPowerStationFourthSix-MonthStatusReportfor the lmplementation  of OrderEA-12-051, OrderModifying    LicenseswithRegardto ReliableSpentFuelPoolInstrumentation Z. Davis-Besse   NuclearPowerStationFourthSix-MonthStatusReportfor the lmplementation of OrderEA-12-051, OrderModifying    Licenseswith Regardto ReliableSpentFuelPoolInstrumentation
: 3. PerryNuclearPowerPlantFourthSix-Month       StatusReportfor the lmplementation of Oider EA-12-051,OrderModifyingLicenseswith Regardto ReliableSpentFuel PoolInstrumentation


==References:==
==References:==
: 1. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to ReliableSpent Fuel Pool lnstrumentation, dated March 12,2012 Z. NRC Interim Staff Guidance JLD-lSG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 Beaver Valley Power Station, Unit Nos. 1 and 2Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-15-001Page 3 3. NEI 1 2-O2,lndustry Guidance for Compliance with NRC Order EA-1 2-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 4. FirstEnergy Nuclear Operating Company's (FENOC's)
: 1. NRCOrderNumberEA-12-051,OrderModifying            LicenseswithRegardto Reliable SpentFuelPoollnstrumentation,   datedMarch12,2012 Z. NRCInterimStaffGuidance      JLD-lSG-2012-03, Compliance   withOrderEA-12-051, OrderModifying    LicenseswithRegardto ReliableSpentFuelPool Instrumentation, Revision0, datedAugust29, 2012
Initial Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 26, 2012 S. FirstEnergy Nuclear Operating Company's (FENOC's) Overall Integrated Plan in Response io 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 O. Beaver Vaitey Power Station, Units 1 and 2 - Interim Staff Evaluation and Request for Additionai Information Regarding the Overall Integrated Plan for lmplementationof Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, datedNovember 19, 2013Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Informtion Regarding the Overall Integrated Plan forf mpiementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation,dated December 11 ,2013Perry Nuclear Power Plant, Unit 1, - Interim Staff Evaluation and Request forAdditional Information Regarding the Overall Integrated Plan for lmplementation ofOrder EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, datedDecember 11,2413NRC Audits of Licensee Responses to Reliable Spent Fuel Pool InstrumentationOrder EA-12-051, dated March 26,2014 Director, Office of Nuclear Reactor Regulation (NRR)NRC Region I AdministratorNRC Region lll AdministratorNRC 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, NRCMr. Blake A.
 
Purnell, NRR/JLD/PMB, NRCDirector BRP/DEP (without Attachments)
BeaverValleyPowerStation,UnitNos.1 and2 Davis-Besse NuclearPowerStation PerryNuclearPowerPlant L-15-001 Page3
Site BRP/DEP Representative (without Attachments)
: 3. NEI 12-O2,lndustry   Guidancefor Compliance  withNRCOrderEA-12-051,"To ModifyLicenseswithRegardto ReliableSpentFuelPoolInstrumentation,"
Utility Radiological Safety Board (without Attachments) 7.8.9.}}
Revision1, datedAugust2012
: 4. FirstEnergy  NuclearOperating  Company's  (FENOC's)InitialStatusReportin Response  to March12,2012,Commission    OrderModifyingLicenseswithRegard to Requirements  for ReliableSpentFuelPoolInstrumentation (OrderNumber EA-12-051),  datedOctober26,2012 S. FirstEnergy  NuclearOperating  Company's  (FENOC's) OverallIntegratedPlanin Response  io March12,2012Commission      Orderlssuanceof Orderto Modify LicenseswithRegardto ReliableSpentFuelPoolInstrumentation      (OrderNumber EA-12-051),  datedFebruary27,2013 O. BeaverVaiteyPowerStation,Units1 and 2 - InterimStaffEvaluation    and Request for AdditionaiInformation  Regardingthe OverallIntegratedPlanfor lmplementation of OrderEA-12-051,ReliableSpentFuel    Pool                dated Instrumentation, November    19,2013
: 7. Davis-Besse    NuclearPowerPlantUnitNo. 1 - InterimStaffEvaluation  and Requestfor AdditionalInformtion  Regarding the OverallIntegrated for Plan fmpiementation  of OrderEA-12-051,ReliableSpentFuelPoolInstrumentation, datedDecember      11,2013 8 . PerryNuclearPowerPlant,Unit1, - InterimStaffEvaluation    and Requestfor AdditionalInformation  Regarding                    Planfor lmplementation the OverallIntegrated                      of OrderEA-12-051,ReliableSpentFuelPoolInstrumentation,      dated December  11,2413
: 9. NRC  Auditsof LicenseeResponses  to ReliableSpentFuelPoolInstrumentation OrderEA-12-051,    datedMarch26,2014 Director,Officeof NuclearReactorRegulation  (NRR)
NRCRegionI Administrator NRCRegionlll Administrator NRCResidentInspector    (BVPS)
NRCResidentInspector    (DBNPS)
NRCResidentInspector    (PNPP)
NRCProjectManager(BVPS)
NRCProjectManager(DBNPS)
NRCProjectManager(PNPP)
Ms.LisaM. Regner,NRR/JLD/PMB,      NRC Mr.BlakeA. Purnell,NRR/JLD/PMB,    NRC DirectorBRP/DEP(withoutAttachments)
Site BRP/DEPRepresentative    (withoutAttachments)
UtilityRadiological SafetyBoard(withoutAttachments)
 
Attachment 1 L-15-001 Beaver Valley Power Station Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1   Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) 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 (LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2    Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.
Update 3 was submitted Completed SFP instrumentation design for Unit No. 1 Delivery of SFP instrumentation was completed for Unit No. 1 Began SFP instrumentation installation for Unit No. 1 Completed SFP instrumentation design for Unit No. 2 Delivery of SFP instrumentation was completed for Unit No. 2 3    Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)
(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.
The revised milestone target completion dates do not impact the order implementation date.
 
Attachment 1 L-15-001 Page 2 of 6 Target        Activity    Revised Target Milestone                  Completion      Status      Completion Date      (as of 1/31/15)      Date Submit Six-Month Status Updates (Unit Nos. 1 and 2)
Update 1                                  August 2013    Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a    February 2014    Complete Update 3                                  August 2014    Complete Post Response to ISE RAI-4b schematic, RAI-5, RAI-7, RAI-8, RAI-10b, RAI-11, RAI-12, RAI-13, RAI-14, and RAI-15 on ePortal                                September 2014    Started      March 2015 Update 4                                February 2015    Started Update 5                                  August 2015    Not Started BVPS Unit No. 1 Commence SFP Instrumentation Design        4Q12        Complete Commence SFP Instrumentation Procurement                                2Q13        Complete Complete SFP Instrumentation Design        3Q14        Complete SFP Instrumentation Delivery                3Q14        Complete Begin SFP Instrumentation Installation      4Q14        Complete Commissioning of SFP Instrumentation        2Q15        Not Started NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)                          Spring 2015    Not Started BVPS Unit No. 2 Commence SFP Instrumentation Design        4Q12        Complete Commence SFP Instrumentation Procurement                                2Q13        Complete Complete SFP Instrumentation Design        1Q15        Complete SFP Instrumentation Delivery                3Q14        Complete Begin SFP Instrumentation Installation      2Q15        Not Started Commissioning of SFP Instrumentation        4Q15        Not Started      3Q15 NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)                          Fall 2015    Not Started 4    Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).
 
L-15-001 Page 3 of 6 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 Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.
Overall Integrated Plan Open Item                                Status None                                                                      Not Applicable Interim Staff Evaluation Open Item                                Status RAI-1: Please specify for Level 1 how the identified location              Complete. (Provided in represents the higher of the two points described in the NEI 12-02        February 2014 status guidance for this level.                                                  report.)
RAI-2: Please provide a clearly labeled sketch depicting the              Complete. (Provided in elevation view of the proposed typical mounting arrangement for the        February 2014 status portions of the instrument channel consisting of permanent                report.)
measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.
RAI-3: Please provide a clearly labeled sketch or marked-up plant          Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside        February 2014 status dimensions, the planned locations/placement of the primary and            report.)
backup SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.
RAI-4: Please provide the following:                                      Started. (Provided in (a) The design criteria that will be used to estimate the total loading    February 2014 status on the mounting device(s), including static weight loads and dynamic      report with exception of loads. Describe the methodology that will be used to estimate the          4b schematic. 4b total loading, inclusive of design basis maximum seismic loads and        schematic to be posted the hydrodynamic loads that could result from pool sloshing or other      on ePortal).
effects that could accompany such seismic forces.
(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.
(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to
 
L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item                                Status support the level sensor assembly.
RAI-5: For RAI 4(a) above, please provide the results of the              Started. (Response to analyses used to verify the design criteria and methodology for           be posted on ePortal.)
seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
RAI-6: For each of the mounting attachments required to attach SFP        Complete. (Provided in level equipment to plant structures, please describe the design          February 2014 status inputs, and the methodology that was used to qualify the structural      report.)
integrity of the affected structures/equipment.
RAI-7: Please provide the following:                                      Started. (Response to (a) A description of the specific method or combination of methods        be posted on ePortal.)
that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.
(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (i) the level sensor mounted in the SFP area, and (ii) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RAI-8: For RAI 7 above, please provide the results from the selected      Started. (Response to methods, tests and analyses used to demonstrate the qualification        be posted on ePortal.)
and reliability of the installed equipment in accordance with the Order requirements.
RAI-9: Please provide the following:                                      Complete. (Provided in (a) A description of how the two channels of the proposed level          February 2014 status measurement system meet this requirement so that the potential for        report.)
a common cause event to adversely affect both channels is minimized to the extent pacticable.
(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and backup channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the read-out devices, and the independence of the displays.
RAI-10: Please provide the following:                                    Started. (Provided (a) A description of the electrical ac power sources and capabilities    RAI-10a response in for the primary and backup channels.                                      February 2014 status (b) Please provide the results of the calculation depicting the battery  report. Response to backup duty cycle requirements demonstrating that its capacity is        RAI-10b to be posted on
 
L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item                                Status sufficient to maintain the level indication function until offsite      ePortal.)
resource availability is reasonably assured.
RAI-11: Please provide the following:                                    Started. (Response to (a) An estimate of the expected instrument channel accuracy              be posted on ePortal.)
performance (e.g., in percent of span) under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.
(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RAI-12: Please provide the following:                                    Started. (Response to (a) A description of the capability and provisions the proposed level    be posted on ePortal.)
sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.
(b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
(c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.
Discuss how these surveillances will be incorporated into the plant surveillance program.
(d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RAI-13: Please provide a list of the procedures addressing operation    Started. (Response to (both normal and abnormal response), calibration, test, maintenance,    be posted on ePortal.)
and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
RAI-14: Please provide the following:                                    Started. (Response to (a) Further information describing the maintenance and testing          be posted on ePortal.)
program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
(b) Describe how the guidance in NEI 12-02, Section 4.3, regarding compensatory actions for one or both non-functioning channels will
 
L-15-001 Page 6 of 6 Interim Staff Evaluation Open Item                                Status be addressed.
(c) Describe what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.
RAI-15: Please provide a description of the in-situ calibration        Started. (Response to process at the SFP location that will result in the channel calibration be posted on ePortal.)
being maintained at its design accuracy.
7    Potential Interim Staff Evaluation Impacts There are potential impacts to the ISE identified for this reporting period. The SFP LI design for Unit No. 1 and Unit No. 2 has progressed from the conceptual design phase to final design. As a result, some of the locations of the instrumentation and conduit routing have been changed.
8    References The following references support the updates to the OIP described in this attachment.
: 1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27, 2013.
: 2. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
: 3. Beaver Valley Power Station, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 19, 2013.
: 4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.
 
Attachment 2 L-15-001 Davis-Besse Nuclear Power Station Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1    Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),
documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2    Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.
Update 3 was submitted Delivery of SFP instrumentation was completed 3    Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)
(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.
The revised milestone target completion dates do not impact the order implementation date.
 
Attachment 2 L-15-001 Page 2 of 6 Target          Activity      Revised Target Milestone                      Completion          Status        Completion Date        (as of 1/31/15)        Date Submit Six-Month Status Updates Update 1                                        August 2013        Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a          February 2014        Complete Update 3                                        August 2014        Complete Update 4                                      February 2015        Started Update 5                                        August 2015        Not Started Post response to ISE RAI-4b schematic, RAI-5, RAI-7, RAI-8, RAI-10b, RAI-11, RAI-12, RAI-13, RAI-14, and RAI-15 on ePortal                                      September 2015        Started Update 6                                      February 2016      Not Started Commence SFP Instrumentation Design                    4Q12            Complete Commence SFP Instrumentation Procurement                                            2Q13            Complete Complete SFP Instrumentation Design                    2Q15            Started            1Q15 SFP Instrumentation Delivery                          4Q14            Complete Begin SFP Instrumentation Installation                3Q15          Not Started          2Q15 Commissioning of SFP Instrumentation                  2Q16          Not Started          3Q15 NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)        Spring 2016        Not Started 4  Changes 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.
6  Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.
Overall Integrated Plan Open Item                                Status None                                                                    Not Applicable Interim Staff Evaluation Open Item                                Status RAI-1: Please specify for Level 1 how the identified location          Complete. (Provided in represents the higher of the two points described in the NEI 12-02      February 2014 status
 
L-15-001 Page 3 of 6 Interim Staff Evaluation Open Item                                Status guidance for this level.                                                  report.)
RAI-2: Please provide a clearly labeled sketch depicting the              Complete. (Provided in elevation view of the proposed typical mounting arrangement for the        February 2014 status portions of the instrument channel consisting of permanent                report.)
measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.
RAI-3: Please provide a clearly labeled sketch or marked-up plant          Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside        February 2014 status dimensions, the planned locations/placement of the primary and            report.)
back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.
RAI-4: Please provide the following:                                      Started. (Provided in (a) The design criteria that will be used to estimate the total loading    February 2014 status on the mounting device(s), including static weight loads and dynamic      report with exception of loads. Describe the methodology that will be used to estimate the          4b schematic. 4b total loading, inclusive of design basis maximum seismic loads and        schematic to be posted the hydrodynamic loads that could result from pool sloshing or other      on ePortal.)
effects that could accompany such seismic forces.
(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.
(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.
RAI-5: For RAI 4(a) above, please provide the results of the              Started. (Response to analyses used to verify the design criteria and methodology for            be posted on ePortal.)
seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
RAI-6: For each of the mounting attachments required to attach SFP        Complete. (Provided in Level equipment to plant structures, please describe the design            February 2014 status inputs, and the methodology that was used to qualify the structural        report.)
integrity of the affected structures/equipment.
RAI-7: Please provide the following:                                      Started. (Response to (a) A description of the specific method or combination of methods        be posted on ePortal.)
that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.
(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform
 
L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item                                Status reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RAI-8: For RAI 7 above, please provide the results from the selected      Started. (Response to methods, tests and analyses used to demonstrate the qualification        be posted on ePortal.)
and reliability of the installed equipment in accordance with the Order requirements.
RAI-9: Please provide the following:                                      Complete. (Provided in (a) A description of the manner the two channels of the proposed          February 2014 status level measurement system meet the independence requirement to            report.)
minimize, to the extent pacticable, the potential for a common cause event to adversely affect both channels.
(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RAI-10: Please provide the following:                                    Started. (Provided (a) A description of the electrical ac power sources and capabilities    RAI-10a response in for the primary and backup channels.                                      February 2014 status (b) Please provide the results of the calculation depicting the battery  report. Response to backup duty cycle requirements demonstrating that its capacity is        RAI-10b to be posted on sufficient to maintain the level indication function until offsite        ePortal.)
resource availability is reasonably assured.
RAI-11: Please provide the following:                                    Started. (Response to (a) An estimate of the expected instrument channel accuracy              be posted on ePortal.)
performance (e.g., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.
(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RAI-12: Please provide the following:                                    Started. (Response to (a) A description of the capability and provisions the proposed level    be posted on ePortal.)
sensing equipment will have to enable periodic testing and
 
L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item                              Status calibration, including how this capability enables the equipment to be tested in-situ.
(b) A description of the testing and calibration necessary to enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
(c) A description of the calibration tests and functional checks processes to be performed, and their frequency. Discuss the steps to be taken to ensure these surveillances will be incorporated into the plant surveillance program.
(d) A description of the preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RAI-13: Please provide a list of the procedures addressing operation    Started. (Response to (both normal and abnormal response), calibration, test, maintenance,    be posted on ePortal.)
and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
RAI-14: Please provide the following:                                  Started. (Response to (a) Further information describing the maintenance and testing          be posted on ePortal.)
program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
(b) A description of the approach and process to be used by the licensee to follow guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels.
(c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.
RAI-15: Please provide a description of the in-situ calibration        Started. (Response to process at the SFP location that will result in the channel calibration be posted on ePortal.)
being maintained at its design accuracy.
7    Potential Interim Staff Evaluation Impacts There are no potential impacts to the ISE identified for this reporting period.
 
L-15-001 Page 6 of 6 8  References The following references support the updates to the OIP described in this attachment.
: 1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27, 2013.
: 2. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
: 3. Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated December 11, 2013.
: 4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.
 
Attachment 3 L-15-001 Perry Nuclear Power Plant Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1    Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2    Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.
Update 3 was submitted Responses to interim staff evaluation requests for additional information were posted on the ePortal Completed SFP instrumentation design Delivery of SFP instrumentation was completed Began SFP instrumentation installation for Unit No. 1 3    Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)
(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.
The revised milestone target completion dates do not impact the order implementation date.
 
Attachment 3 L-15-001 Page 2 of 6 Target          Activity      Revised Target Milestone                  Completion        Status        Completion Date        (as of 1/31/15)       Date Submit Six-Month Status Updates Update 1                                  August 2013      Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3 (except 3b schematic), RAI-5, RAI-8, and RAI-9a      February 2014      Complete Update 3                                  August 2014      Complete Post Response to ISE RAI-3b schematic, RAI-4, RAI-6, RAI-7, RAI-9b, RAI-10, RAI-11, RAI-12, RAI-13, and RAI-14 on ePortal                                  September 2014      Complete Update 4                                  February 2015      Started Commence SFP Instrumentation Design              4Q12          Complete Commence SFP Instrumentation Procurement                                      2Q13          Complete Complete SFP Instrumentation Design              3Q14          Complete SFP Instrumentation Delivery                    3Q14          Complete Begin SFP Instrumentation Installation          4Q14          Complete Commissioning of SFP Instrumentation            1Q15            Started NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)   Spring 2015      Not Started 4  Changes to Compliance Method There are no additional changes to the compliance method as documented in the OIP (Reference 1) for this reporting period.
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 Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.
Overall Integrated Plan Open Item                          Status None                                                            Not Applicable
 
L-15-001 Page 3 of 6 Interim Staff Evaluation Open Item                                Status RAI-1: Please provide a clearly labeled sketch depicting the              Complete. (Provided in elevation view of the proposed typical mounting arrangement for the        February 2014 status portions of the instrument channel consisting of permanent                report.)
measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.
RAI-2: Please provide a clearly labeled sketch or marked-up plant          Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside        February 2014 status dimensions, the planned locations/placement of the primary and            report.)
back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.
RAI-3: Please provide the following:                                      Complete. (Provided in (a) The design criteria that will be used to estimate the total loading    February 2014 status on the mounting device(s), including static weight loads and dynamic      report with exception of loads. Describe the methodology that will be used to estimate the          3b. 3b schematic total loading, inclusive of design basis maximum seismic loads and        posted on ePortal.)
the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.
(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.
RAI-4: For RAI 3(a) above, please provide the results of the              Complete. (Response analyses used to verify the design criteria and methodology for            posted on ePortal.)
seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
RAI-5: For each of the mounting attachments required to attach SFP        Complete. (Provided in Level equipment to plant structures, please describe the design            February 2014 status inputs, and the methodology that will be used to qualify the structural    report.)
integrity of the affected structures/equipment.
RAI-6: Please provide the following:                                      Complete. (Response (a) A description of the specific method or combination of methods        posted on ePortal.)
that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.
(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform
 
L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item                                Status reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RAI-7: For RAI 6 above, please provide the results from the selected      Complete. (Response methods, tests and analyses used to demonstrate the qualification        posted on ePortal.)
and reliability of the installed equipment in accordance with the Order requirements.
RAI-8: Please provide the following:                                      Complete. (Provided in (a) A description of how the two channels of the proposed level          February 2014 status measurement system meet this requirement so that the potential for        report.)
a common cause event to adversely affect both channels is minimized to the extent pacticable.
(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RAI-9: Please provide the following:                                      Complete (Provided (a) A description of the electrical ac power sources and capabilities    RAI-9a response in for the primary and backup channels.                                      February 2014 status (b) Please provide the results of the calculation depicting the battery  report. Response to backup duty cycle requirements demonstrating that its capacity is        RAI-9b posted on sufficient to maintain the level indication function until offsite        ePortal.)
resource availability is reasonably assured.
RAI-10: Please provide the following:                                    Complete. (Response (a) An estimate of the expected instrument channel accuracy              posted on ePortal.)
performance (e.g., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.
(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RAI-11: Please provide the following:                                    Complete. (Response (a) A description of the capability and provisions the proposed level    posted on ePortal.)
sensing equipment will have to enable periodic testing and
 
L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item                              Status calibration, including how this capability enables the equipment to be tested in-situ.
(b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
(c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.
Discuss how these surveillances will be incorporated into the plant surveillance program.
(d) A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RAI-12: Please provide a list of the procedures addressing operation    Complete. (Response (both normal and abnormal response), calibration, test, maintenance,    posted on ePortal.)
and inspection that will be developed for use of the spent SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
RAI-13: Please provide the following:                                    Complete. (Response (a) Further information describing the maintenance and testing          posted on ePortal.)
program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
(b) A description of FENOCs procedure/process to implement the guidance in NEI 12-02 Section 4.3 on compensatory actions for one or both non-functioning channels.
(c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.
RAI-14: Please provide a description of the in-situ calibration          Complete. (Response process at the SFP location that will result in the channel calibration  posted on ePortal.)
being maintained at its design accuracy.
7    Potential Interim Staff Evaluation Impacts There are no potential impacts to the ISE identified for this reporting period.
 
L-15-001 Page 6 of 6 8  References The following references support the updates to the OIP described in this attachment.
: 1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance 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.
: 3. Perry Nuclear Power Plant, Unit 1, - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated December 11, 2013.
: 4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.}}

Revision as of 14:58, 31 October 2019

Firstenergy Nuclear Operating Company'S (Fenoc'S) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool.
ML15057A396
Person / Time
Site: Beaver Valley, Davis Besse, Perry
Issue date: 02/26/2015
From: Belcher S
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, L-15-001, TAC MF0799, TAC MF0800, TAC MF0802, TAC MF0960
Download: ML15057A396 (26)
v • d • e


Text

i" FENOC 76 South Main Street Akron. Ohio 44308 Samuel L. Belcher Senior Vice Presidentand Chief Operating Officer February 26,2015 L-15-001 10cFR2.202 ATTN: Document ControlDesk U.S.NuclearRegulatory Commission Washington, DC 20555-001

SUBJECT:

BeaverValleyPowerStation,UnitNos.1 and2 DocketNo.50-334,LicenseNo.DPR-66 DocketNo.50-412,LicenseNo.NPF-73 Davis-Besse NuclearPowerStation DocketNo.50-346,LicenseNo. NPF-3 PerryNuclearPowerPlant DocketNo.50-440,LicenseNo. NPF-58 FirstEnerqv NuclearOperating Company's (FENOC's) FourthSix-Month StatusRgpo(

in Response to March12,2012Commission OrderModifying Liqenseg with Reqardto Reliable SpentFuelPoolInstrumentation (OrderNumberEA-12-051)

(TACNos.MF0799,MF0800.MF0960.andMF0802)

On March12,2012,the NuclearRegulatory Commission (NRCor Commission) issued an order(Reference1) to FENOC.Reference1 was immediately effectiveand directs FENOCto havea reliableindication of the waterlevelin associated spentfuelstorage pools. Specificrequirements areoutlinedin Attachment 2 of Reference 1.

Reference1 requiredsubmission of an initialstatusreport60 daysfollowingissuanceof the finalinterimstaffguidance(Reference 2) andan overallintegrated planpursuantto SectionlV, Condition C. Reference2 endorses industry guidance documentNuclear Energylnstitute (NEI) 12-02,Revision1 (Reference 3) with clarificationsandexceptions identifiedin Reference2. Reference4 providedthe FENOCinitialstatusreport regardingrequirements for reliablespentfuelpoolinstrumentation. Reference 5 providedthe FENOCoverallintegrated planfor BeaverValleyPowerStation(BVPS),

UnitNos.1 and2, Davis-Besse NuclearPowerStation(DBNPS),and PerryNuclear PowerPlant(PNPP).

Reference1 requiressubmission of a statusreportat six-monthintervals following submittalof the overallintegrated plan. Reference 3 providesdirectionregarding the contentof the statusreports.The purpose of this letteris to provide the fourth

BeaverValleyPowerStation,UnitNos.1 and2 Davis-Besse NuclearPowerStation PerryNuclearPowerPlant L-15-001 Page2 six-monthstatusreportpursuantto SectionlV, ConditionC.2,of Reference 1, that delineates progressmadein implementing the requirements of Reference 1. The attachedreportsfor BVPS,DBNPS,and PNPP (Attachments 1 , 2, and 3, respectively) providean updateof milestone accomplishments sincethe laststatusreport,including anychangesto the complian@ method,schedule, or needfor relieflrelaxation andthe basis,if any.

The NRCstaffalsoissuedinterimstaffevaluations (References 6,7, and8) that includedrequestsfor additional information(RAls).The NRCstaffsubsequently indicatedthe intentionto completethe ongoingreviewof the responsesto Reference1 by conductingauditsand utilizingthe ePortalsystemfor reviewof RAI responses (Referenceg). The attachedreportshavebeenupdatedto reflectthis processchange.

Thislettercontainsno newregulatory commitments. lf you haveanyquestions regarding this report,pleasecontactMr.ThomasA. Lentz,Manager- FleetLicensing, at 330-315-6810.

I declareunderpenaltyof perjurythatthe foregoingis true and correct.Executedon FebruaryLb ,2015.

Respectfully, SamuelL. Belcher Attachments:

1. BeaverValleyPowerStationFourthSix-MonthStatusReportfor the lmplementation of OrderEA-12-051, OrderModifying LicenseswithRegardto ReliableSpentFuelPoolInstrumentation Z. Davis-Besse NuclearPowerStationFourthSix-MonthStatusReportfor the lmplementation of OrderEA-12-051, OrderModifying Licenseswith Regardto ReliableSpentFuelPoolInstrumentation
3. PerryNuclearPowerPlantFourthSix-Month StatusReportfor the lmplementation of Oider EA-12-051,OrderModifyingLicenseswith Regardto ReliableSpentFuel PoolInstrumentation

References:

1. NRCOrderNumberEA-12-051,OrderModifying LicenseswithRegardto Reliable SpentFuelPoollnstrumentation, datedMarch12,2012 Z. NRCInterimStaffGuidance JLD-lSG-2012-03, Compliance withOrderEA-12-051, OrderModifying LicenseswithRegardto ReliableSpentFuelPool Instrumentation, Revision0, datedAugust29, 2012

BeaverValleyPowerStation,UnitNos.1 and2 Davis-Besse NuclearPowerStation PerryNuclearPowerPlant L-15-001 Page3

3. NEI 12-O2,lndustry Guidancefor Compliance withNRCOrderEA-12-051,"To ModifyLicenseswithRegardto ReliableSpentFuelPoolInstrumentation,"

Revision1, datedAugust2012

4. FirstEnergy NuclearOperating Company's (FENOC's)InitialStatusReportin Response to March12,2012,Commission OrderModifyingLicenseswithRegard to Requirements for ReliableSpentFuelPoolInstrumentation (OrderNumber EA-12-051), datedOctober26,2012 S. FirstEnergy NuclearOperating Company's (FENOC's) OverallIntegratedPlanin Response io March12,2012Commission Orderlssuanceof Orderto Modify LicenseswithRegardto ReliableSpentFuelPoolInstrumentation (OrderNumber EA-12-051), datedFebruary27,2013 O. BeaverVaiteyPowerStation,Units1 and 2 - InterimStaffEvaluation and Request for AdditionaiInformation Regardingthe OverallIntegratedPlanfor lmplementation of OrderEA-12-051,ReliableSpentFuel Pool dated Instrumentation, November 19,2013
7. Davis-Besse NuclearPowerPlantUnitNo. 1 - InterimStaffEvaluation and Requestfor AdditionalInformtion Regarding the OverallIntegrated for Plan fmpiementation of OrderEA-12-051,ReliableSpentFuelPoolInstrumentation, datedDecember 11,2013 8 . PerryNuclearPowerPlant,Unit1, - InterimStaffEvaluation and Requestfor AdditionalInformation Regarding Planfor lmplementation the OverallIntegrated of OrderEA-12-051,ReliableSpentFuelPoolInstrumentation, dated December 11,2413
9. NRC Auditsof LicenseeResponses to ReliableSpentFuelPoolInstrumentation OrderEA-12-051, datedMarch26,2014 Director,Officeof NuclearReactorRegulation (NRR)

NRCRegionI Administrator NRCRegionlll Administrator NRCResidentInspector (BVPS)

NRCResidentInspector (DBNPS)

NRCResidentInspector (PNPP)

NRCProjectManager(BVPS)

NRCProjectManager(DBNPS)

NRCProjectManager(PNPP)

Ms.LisaM. Regner,NRR/JLD/PMB, NRC Mr.BlakeA. Purnell,NRR/JLD/PMB, NRC DirectorBRP/DEP(withoutAttachments)

Site BRP/DEPRepresentative (withoutAttachments)

UtilityRadiological SafetyBoard(withoutAttachments)

Attachment 1 L-15-001 Beaver Valley Power Station Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) 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 (LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.

Update 3 was submitted Completed SFP instrumentation design for Unit No. 1 Delivery of SFP instrumentation was completed for Unit No. 1 Began SFP instrumentation installation for Unit No. 1 Completed SFP instrumentation design for Unit No. 2 Delivery of SFP instrumentation was completed for Unit No. 2 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)

(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.

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

Attachment 1 L-15-001 Page 2 of 6 Target Activity Revised Target Milestone Completion Status Completion Date (as of 1/31/15) Date Submit Six-Month Status Updates (Unit Nos. 1 and 2)

Update 1 August 2013 Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a February 2014 Complete Update 3 August 2014 Complete Post Response to ISE RAI-4b schematic, RAI-5, RAI-7, RAI-8, RAI-10b, RAI-11, RAI-12, RAI-13, RAI-14, and RAI-15 on ePortal September 2014 Started March 2015 Update 4 February 2015 Started Update 5 August 2015 Not Started BVPS Unit No. 1 Commence SFP Instrumentation Design 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Design 3Q14 Complete SFP Instrumentation Delivery 3Q14 Complete Begin SFP Instrumentation Installation 4Q14 Complete Commissioning of SFP Instrumentation 2Q15 Not Started NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Spring 2015 Not Started BVPS Unit No. 2 Commence SFP Instrumentation Design 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Design 1Q15 Complete SFP Instrumentation Delivery 3Q14 Complete Begin SFP Instrumentation Installation 2Q15 Not Started Commissioning of SFP Instrumentation 4Q15 Not Started 3Q15 NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Fall 2015 Not Started 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

L-15-001 Page 3 of 6 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 Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.

Overall Integrated Plan Open Item Status None Not Applicable Interim Staff Evaluation Open Item Status RAI-1: Please specify for Level 1 how the identified location Complete. (Provided in represents the higher of the two points described in the NEI 12-02 February 2014 status guidance for this level. report.)

RAI-2: Please provide a clearly labeled sketch depicting the Complete. (Provided in elevation view of the proposed typical mounting arrangement for the February 2014 status portions of the instrument channel consisting of permanent report.)

measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.

RAI-3: Please provide a clearly labeled sketch or marked-up plant Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside February 2014 status dimensions, the planned locations/placement of the primary and report.)

backup SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.

RAI-4: Please provide the following: Started. (Provided in (a) The design criteria that will be used to estimate the total loading February 2014 status on the mounting device(s), including static weight loads and dynamic report with exception of loads. Describe the methodology that will be used to estimate the 4b schematic. 4b total loading, inclusive of design basis maximum seismic loads and schematic to be posted the hydrodynamic loads that could result from pool sloshing or other on ePortal).

effects that could accompany such seismic forces.

(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to

L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item Status support the level sensor assembly.

RAI-5: For RAI 4(a) above, please provide the results of the Started. (Response to analyses used to verify the design criteria and methodology for be posted on ePortal.)

seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

RAI-6: For each of the mounting attachments required to attach SFP Complete. (Provided in level equipment to plant structures, please describe the design February 2014 status inputs, and the methodology that was used to qualify the structural report.)

integrity of the affected structures/equipment.

RAI-7: Please provide the following: Started. (Response to (a) A description of the specific method or combination of methods be posted on ePortal.)

that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.

(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (i) the level sensor mounted in the SFP area, and (ii) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

RAI-8: For RAI 7 above, please provide the results from the selected Started. (Response to methods, tests and analyses used to demonstrate the qualification be posted on ePortal.)

and reliability of the installed equipment in accordance with the Order requirements.

RAI-9: Please provide the following: Complete. (Provided in (a) A description of how the two channels of the proposed level February 2014 status measurement system meet this requirement so that the potential for report.)

a common cause event to adversely affect both channels is minimized to the extent pacticable.

(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and backup channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the read-out devices, and the independence of the displays.

RAI-10: Please provide the following: Started. (Provided (a) A description of the electrical ac power sources and capabilities RAI-10a response in for the primary and backup channels. February 2014 status (b) Please provide the results of the calculation depicting the battery report. Response to backup duty cycle requirements demonstrating that its capacity is RAI-10b to be posted on

L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item Status sufficient to maintain the level indication function until offsite ePortal.)

resource availability is reasonably assured.

RAI-11: Please provide the following: Started. (Response to (a) An estimate of the expected instrument channel accuracy be posted on ePortal.)

performance (e.g., in percent of span) under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

RAI-12: Please provide the following: Started. (Response to (a) A description of the capability and provisions the proposed level be posted on ePortal.)

sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

(b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

(c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.

Discuss how these surveillances will be incorporated into the plant surveillance program.

(d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

RAI-13: Please provide a list of the procedures addressing operation Started. (Response to (both normal and abnormal response), calibration, test, maintenance, be posted on ePortal.)

and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

RAI-14: Please provide the following: Started. (Response to (a) Further information describing the maintenance and testing be posted on ePortal.)

program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

(b) Describe how the guidance in NEI 12-02, Section 4.3, regarding compensatory actions for one or both non-functioning channels will

L-15-001 Page 6 of 6 Interim Staff Evaluation Open Item Status be addressed.

(c) Describe what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.

RAI-15: Please provide a description of the in-situ calibration Started. (Response to process at the SFP location that will result in the channel calibration be posted on ePortal.)

being maintained at its design accuracy.

7 Potential Interim Staff Evaluation Impacts There are potential impacts to the ISE identified for this reporting period. The SFP LI design for Unit No. 1 and Unit No. 2 has progressed from the conceptual design phase to final design. As a result, some of the locations of the instrumentation and conduit routing have been changed.

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

1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27, 2013.
2. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
3. Beaver Valley Power Station, Units 1 and 2 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 19, 2013.
4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.

Attachment 2 L-15-001 Davis-Besse Nuclear Power Station Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),

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

2 Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.

Update 3 was submitted Delivery of SFP instrumentation was completed 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)

(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.

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

Attachment 2 L-15-001 Page 2 of 6 Target Activity Revised Target Milestone Completion Status Completion Date (as of 1/31/15) Date Submit Six-Month Status Updates Update 1 August 2013 Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Started Update 5 August 2015 Not Started Post response to ISE RAI-4b schematic, RAI-5, RAI-7, RAI-8, RAI-10b, RAI-11, RAI-12, RAI-13, RAI-14, and RAI-15 on ePortal September 2015 Started Update 6 February 2016 Not Started Commence SFP Instrumentation Design 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Design 2Q15 Started 1Q15 SFP Instrumentation Delivery 4Q14 Complete Begin SFP Instrumentation Installation 3Q15 Not Started 2Q15 Commissioning of SFP Instrumentation 2Q16 Not Started 3Q15 NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Spring 2016 Not Started 4 Changes 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.

6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.

Overall Integrated Plan Open Item Status None Not Applicable Interim Staff Evaluation Open Item Status RAI-1: Please specify for Level 1 how the identified location Complete. (Provided in represents the higher of the two points described in the NEI 12-02 February 2014 status

L-15-001 Page 3 of 6 Interim Staff Evaluation Open Item Status guidance for this level. report.)

RAI-2: Please provide a clearly labeled sketch depicting the Complete. (Provided in elevation view of the proposed typical mounting arrangement for the February 2014 status portions of the instrument channel consisting of permanent report.)

measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.

RAI-3: Please provide a clearly labeled sketch or marked-up plant Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside February 2014 status dimensions, the planned locations/placement of the primary and report.)

back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.

RAI-4: Please provide the following: Started. (Provided in (a) The design criteria that will be used to estimate the total loading February 2014 status on the mounting device(s), including static weight loads and dynamic report with exception of loads. Describe the methodology that will be used to estimate the 4b schematic. 4b total loading, inclusive of design basis maximum seismic loads and schematic to be posted the hydrodynamic loads that could result from pool sloshing or other on ePortal.)

effects that could accompany such seismic forces.

(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

RAI-5: For RAI 4(a) above, please provide the results of the Started. (Response to analyses used to verify the design criteria and methodology for be posted on ePortal.)

seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

RAI-6: For each of the mounting attachments required to attach SFP Complete. (Provided in Level equipment to plant structures, please describe the design February 2014 status inputs, and the methodology that was used to qualify the structural report.)

integrity of the affected structures/equipment.

RAI-7: Please provide the following: Started. (Response to (a) A description of the specific method or combination of methods be posted on ePortal.)

that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.

(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform

L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item Status reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

RAI-8: For RAI 7 above, please provide the results from the selected Started. (Response to methods, tests and analyses used to demonstrate the qualification be posted on ePortal.)

and reliability of the installed equipment in accordance with the Order requirements.

RAI-9: Please provide the following: Complete. (Provided in (a) A description of the manner the two channels of the proposed February 2014 status level measurement system meet the independence requirement to report.)

minimize, to the extent pacticable, the potential for a common cause event to adversely affect both channels.

(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RAI-10: Please provide the following: Started. (Provided (a) A description of the electrical ac power sources and capabilities RAI-10a response in for the primary and backup channels. February 2014 status (b) Please provide the results of the calculation depicting the battery report. Response to backup duty cycle requirements demonstrating that its capacity is RAI-10b to be posted on sufficient to maintain the level indication function until offsite ePortal.)

resource availability is reasonably assured.

RAI-11: Please provide the following: Started. (Response to (a) An estimate of the expected instrument channel accuracy be posted on ePortal.)

performance (e.g., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

RAI-12: Please provide the following: Started. (Response to (a) A description of the capability and provisions the proposed level be posted on ePortal.)

sensing equipment will have to enable periodic testing and

L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item Status calibration, including how this capability enables the equipment to be tested in-situ.

(b) A description of the testing and calibration necessary to enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

(c) A description of the calibration tests and functional checks processes to be performed, and their frequency. Discuss the steps to be taken to ensure these surveillances will be incorporated into the plant surveillance program.

(d) A description of the preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

RAI-13: Please provide a list of the procedures addressing operation Started. (Response to (both normal and abnormal response), calibration, test, maintenance, be posted on ePortal.)

and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

RAI-14: Please provide the following: Started. (Response to (a) Further information describing the maintenance and testing be posted on ePortal.)

program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

(b) A description of the approach and process to be used by the licensee to follow guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels.

(c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.

RAI-15: Please provide a description of the in-situ calibration Started. (Response to process at the SFP location that will result in the channel calibration be posted on ePortal.)

being maintained at its design accuracy.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the ISE identified for this reporting period.

L-15-001 Page 6 of 6 8 References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27, 2013.
2. Nuclear Regulatory Commission (NRC) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
3. Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated December 11, 2013.
4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.

Attachment 3 L-15-001 Perry Nuclear Power Plant Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 1 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OIP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since July 21, 2014 and are current as of January 31, 2015.

Update 3 was submitted Responses to interim staff evaluation requests for additional information were posted on the ePortal Completed SFP instrumentation design Delivery of SFP instrumentation was completed Began SFP instrumentation installation for Unit No. 1 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OIP. 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 milestones indicate the number assigned in the interim staff evaluation (ISE)

(Reference 3) to each request for additional information (RAI). Updates to RAI responses are to be posted on the ePortal as indicated in Reference 4.

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

Attachment 3 L-15-001 Page 2 of 6 Target Activity Revised Target Milestone Completion Status Completion Date (as of 1/31/15) Date Submit Six-Month Status Updates Update 1 August 2013 Complete Update 2, including response to ISE RAI-1, RAI-2, RAI-3 (except 3b schematic), RAI-5, RAI-8, and RAI-9a February 2014 Complete Update 3 August 2014 Complete Post Response to ISE RAI-3b schematic, RAI-4, RAI-6, RAI-7, RAI-9b, RAI-10, RAI-11, RAI-12, RAI-13, and RAI-14 on ePortal September 2014 Complete Update 4 February 2015 Started Commence SFP Instrumentation Design 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Design 3Q14 Complete SFP Instrumentation Delivery 3Q14 Complete Begin SFP Instrumentation Installation 4Q14 Complete Commissioning of SFP Instrumentation 1Q15 Started NRC Order Implementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Spring 2015 Not Started 4 Changes to Compliance Method There are no additional changes to the compliance method as documented in the OIP (Reference 1) for this reporting period.

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 Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.

Overall Integrated Plan Open Item Status None Not Applicable

L-15-001 Page 3 of 6 Interim Staff Evaluation Open Item Status RAI-1: Please provide a clearly labeled sketch depicting the Complete. (Provided in elevation view of the proposed typical mounting arrangement for the February 2014 status portions of the instrument channel consisting of permanent report.)

measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.

RAI-2: Please provide a clearly labeled sketch or marked-up plant Complete. (Provided in drawing of the plan view of the SFP area, depicting the SFP inside February 2014 status dimensions, the planned locations/placement of the primary and report.)

back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device.

RAI-3: Please provide the following: Complete. (Provided in (a) The design criteria that will be used to estimate the total loading February 2014 status on the mounting device(s), including static weight loads and dynamic report with exception of loads. Describe the methodology that will be used to estimate the 3b. 3b schematic total loading, inclusive of design basis maximum seismic loads and posted on ePortal.)

the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

RAI-4: For RAI 3(a) above, please provide the results of the Complete. (Response analyses used to verify the design criteria and methodology for posted on ePortal.)

seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

RAI-5: For each of the mounting attachments required to attach SFP Complete. (Provided in Level equipment to plant structures, please describe the design February 2014 status inputs, and the methodology that will be used to qualify the structural report.)

integrity of the affected structures/equipment.

RAI-6: Please provide the following: Complete. (Response (a) A description of the specific method or combination of methods posted on ePortal.)

that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions.

(b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform

L-15-001 Page 4 of 6 Interim Staff Evaluation Open Item Status reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

(c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

RAI-7: For RAI 6 above, please provide the results from the selected Complete. (Response methods, tests and analyses used to demonstrate the qualification posted on ePortal.)

and reliability of the installed equipment in accordance with the Order requirements.

RAI-8: Please provide the following: Complete. (Provided in (a) A description of how the two channels of the proposed level February 2014 status measurement system meet this requirement so that the potential for report.)

a common cause event to adversely affect both channels is minimized to the extent pacticable.

(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RAI-9: Please provide the following: Complete (Provided (a) A description of the electrical ac power sources and capabilities RAI-9a response in for the primary and backup channels. February 2014 status (b) Please provide the results of the calculation depicting the battery report. Response to backup duty cycle requirements demonstrating that its capacity is RAI-9b posted on sufficient to maintain the level indication function until offsite ePortal.)

resource availability is reasonably assured.

RAI-10: Please provide the following: Complete. (Response (a) An estimate of the expected instrument channel accuracy posted on ePortal.)

performance (e.g., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

(b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

RAI-11: Please provide the following: Complete. (Response (a) A description of the capability and provisions the proposed level posted on ePortal.)

sensing equipment will have to enable periodic testing and

L-15-001 Page 5 of 6 Interim Staff Evaluation Open Item Status calibration, including how this capability enables the equipment to be tested in-situ.

(b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

(c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.

Discuss how these surveillances will be incorporated into the plant surveillance program.

(d) A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

RAI-12: Please provide a list of the procedures addressing operation Complete. (Response (both normal and abnormal response), calibration, test, maintenance, posted on ePortal.)

and inspection that will be developed for use of the spent SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

RAI-13: Please provide the following: Complete. (Response (a) Further information describing the maintenance and testing posted on ePortal.)

program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

(b) A description of FENOCs procedure/process to implement the guidance in NEI 12-02 Section 4.3 on compensatory actions for one or both non-functioning channels.

(c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.

RAI-14: Please provide a description of the in-situ calibration Complete. (Response process at the SFP location that will result in the channel calibration posted on ePortal.)

being maintained at its design accuracy.

7 Potential Interim Staff Evaluation Impacts There are no potential impacts to the ISE identified for this reporting period.

L-15-001 Page 6 of 6 8 References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Companys (FENOCs) Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance 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.
3. Perry Nuclear Power Plant, Unit 1, - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated December 11, 2013.
4. NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26, 2014.
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