L-15-208, Provides Notification of Completion of Required Action by NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
| ML15203A101 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/22/2015 |
| From: | Emily Larson FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, L-15-208, TAC MF0799 | |
| Download: ML15203A101 (45) | |
Text
Beaver Valley Power Station FENOC' ~
P.O. Box 4 Shippingporl, PA 15077 RrstEnergy Nuclear Operating Company Eric A. Larson 724-682-5234 Site Vice President Fax: 724-643-8069 July 22, 2015 L-15-208 10 CFR 2.202 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001
SUBJECT:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Completion of Required Action by NRC Order EA-12-051. Reliable Spent Fuel Pool Instrumentation (TAC No. MF0799)
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, to FirstEnergy Nuclear Operating Company (FENOC). This Order was effective immediately and directed FENOC to have a reliable indication of the water level in associated spent fuel storage pools for the Beaver Valley Power Station, Unit No. 1 (BVPS-1) as outlined in Attachment 2 of the Order. This letter, along with its attachments, provides the notification required by Section IV.C.3 of the Order that full compliance with the requirements described in Attachment 2 of the Order has been achieved for BVPS-1.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 2 ':( 2015.I Respectfully submitted, Z:-c\J~
Eric A. Larson
Beaver Valley Power Station, Unit No. 1 L-15-208 Page2 Attachments:
- 1. Compliance with Order EA-12-051
- 2. NRC Requests for Information cc: Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region I Administrator NRC Resident Inspector NRC Project Manager Ms. Lisa M. Regner, NRR/JLD/PMB, NRC Mr. Blake A. Purnell, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments)
Site BRP/DEP Representative (without Attachments)
Attachment 1 L-15-208 Compliance with Order EA-12-051 Page 1 of 4 BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Reference 1), to FirstEnergy Nuclear Operating Company (FENOC).
This Order was effective immediately and directed FENOC to have a reliable indication of the water level in associated spent fuel storage pools for the Beaver Valley Power Station, Unit No. 1 (BVPS-1) as outlined in Attachment 2 of the Order. The Order required compliance prior to plant startup from the second refueling outage following submittal of the overall integrated plan (OIP), or by December 31, 2016, whichever comes first. The compliance date for BVPS-1 was May 23, 2015. The NRC staff requested that the compliance report be submitted within 60 days of the compliance date. The information provided herein documents full compliance for BVPS-1 in response to the Order.
COMPLIANCE FENOC has installed two independent full scale level monitors on the spent fuel pool (SFP) at BVPS-1 in response to Reference 1. This SFP instrumentation was supplied and qualified by Westinghouse, LLC (Westinghouse). BVPS-1 discharges irradiated fuel to a single spent fuel storage pool. With the exception of limited time periods for maintenance or non-refueling operations, administrative controls maintain gates in the open position between the following pools: spent fuel pool, fuel transfer canal, and cask loading pit. Thus, these pools are normally inter-connected and at the same water level when the water level in the spent fuel pool is greater than 1 foot above the top of stored fuel seated in the storage racks. These pools are treated as one SFP with regard to Reference 1.
FENOC submitted the Beaver Valley Power Station OIP by letter dated February 27, 2013 (Reference 2). By letter dated November 19, 2013 (Reference 3),
the NRC provided its interim staff evaluation and requested additional information necessary for completion of the review. The information requested by the NRC is included in Attachment 2 of this submittal.
Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance and status reports at six-month intervals following submittal of the OIP. FENOC provided the initial status report for BVPS-1 by letter dated October 26, 2012 (Reference 4). The first, second, third, and fourth six-month status reports for BVPS-1 were provided by letters dated August 26, 2013, February 27, 2014, August 28, 2014, and February 26, 2015, respectively (References 5, 6, 7, and 8.)
Attachment 1 L-15-208 Page 2 of 4 Compliance with Order EA-12-051 was achieved using the guidance in Nuclear Energy Institute (NEI) document NEI 12-02, Revision 1 (Reference 9), which has been endorsed by the NRC (Reference 10) with exceptions and clarifications. A summary of the compliance elements is provided below Identification of Levels of Required Monitoring FENOC has identified the three required levels for monitoring SFP level in compliance with Reference 1. These levels have been integrated into the site processes for monitoring SFP level during beyond-design-basis external events (BDBEEs) and responding to loss of SFP inventory.
Instrumentation Design Features FENOC has installed SFP instrumentation consisting of permanently mounted, fixed primary and backup instrument channels at BVPS-1. This SFP instrumentation was supplied and qualified by Westinghouse. The design of the SFP instrumentation system complies with the requirements specified in Reference 1 and Reference 9. The SFP instrumentation has been installed in accordance with the site design control process.
The instruments have been arranged to provide reasonable protection against missiles (airborne objects). Each channel consists of a level sensor, an electronics unit, and an indicator. The sensors are mounted on the opposite ends of the SFP as far apart as practical within the constraints of the existing pool geometry and equipment and as close to the adjacent corners as possible to minimize the possibility of a single event or missile damaging both channels. The sensor arrangement also limits interference with existing equipment in or around the SFP. This design is in compliance with Reference 1; however it does represent a minor deviation from Reference 9. This design does not pose a potential hazard to personnel working around the pool or on the SFP level instrumentation itself.
The instruments have been mounted to retain design configuration during and following the maximum expected ground motion considered in the design of the SFP structure.
The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their designed accuracy following a power interruption and are designed to allow for routine testing and calibration.
The instrument display is readily accessible during postulated BDBEEs and allows for SFP level information to be promptly available to decision makers.
Attachment 1 L-15-208 Page 3 of 4 Program Features The Systematic Approach to Training was utilized to develop and implement training.
Training has been provided for applicable personnel in the use of, and provision of alternate power to, primary and backup instrument channels.
Procedures for the testing, calibration, and use of the primary and backup SFP instrument channels have been established and integrated with existing procedures.
Preventive maintenance tasks have also been established and scheduled to ensure the instruments are maintained at their design accuracy.
REFERENCES
- 1. Nuclear Regulatory Commission (NRG) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
- 2. FirstEnergy Nuclear Operating Company's (FENOC's) 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.
- 3. NRG Letter, 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. FirstEnergy Nuclear Operating Company's (FENOC's) 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.
- 5. FirstEnergy Nuclear Operating Company's (FENOC's) First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos.
MF0799, MFOBOO, MF0960, and MF0802), dated August 26, 2013.
- 6. FirstEnergy Nuclear Operating Company's (FENOC's) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
(TAC Nos. MF0799, MFOBOO, MF0960, and MF0802), dated February 27, 2014.
- 7. FirstEnergy Nuclear Operating Company's (FENOC's) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with L-15-208 Page 4 of 4 Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
(TAC Nos. MF0799, MF0800, MF0960, and MF0802), dated August 28, 2014.
- 8. FirstEnergy Nuclear Operating Company's (FENOC's) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
(TAC Nos. MF0799, MF0800, MF0960, and MF0802), dated February 26, 2015.
- 9. NEI Document, NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012.
- 10. NRC Japan Lessons-Learned Project Directorate Interim Staff Guidance, JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated August 29, 2012.
Attachment 2 L-15-208 NRC Requests for Information Page 1 of 39 By letter dated November 19, 2013, the Nuclear Regulatory Commission (NRC) issued an interim staff evaluation (ISE) and request for additional information (RAI) regarding the Beaver Valley Power Station, Units 1 and 2 (BVPS-1, BVPS-2) overall integrated plan for implementation of NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation. Subsequently, by letter dated March 26, 2014, the NRC staff transitioned to an audit-based review process that allowed the use of the licensee's ePortal to provide responses to the RAls to support the staff's review process.
FirstEnergy Nuclear Operating Company (FENOC) utilized the ePortal to provide the majority of RAI responses for BVPS-1. The compliance date for BVPS-1 was May 23, 2015. The ISE RAls are provided below as they pertain to BVPS-1. The responses to the following RAls were previously provided to the NRC via the FENOC ePortal: RAl-4(b) schematic, RAl-5, RAl-7, RAl-8, RAl-1 O(b), RAl-11, RAl-12, RAl-13, RAl-14, and RAl-15. RAI responses to RAl-2, RAl-3, RAl-4(c), RAl-5, RAl-9(a),
RAl-12(b), and RAl-13 have been amended. The responses are provided in the tense that was applicable when presented on the ePortal, and therefore may not reflect the final completed status. The NRC staff question is presented in bold type, followed by the FENOC response. Following the RAI responses is a copy of the bridging document that was previously provided to the NRC via the FENOC ePortal.
RAl-1:
Please specify for Level 1 how the identified location represents the higher of the two points described in the NEI [Nuclear Energy Institute] 12-02 guidance for this level.
Response
The response to this RAI was provided by FENOC letter dated February 27, 2014.
RAl-2:
Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent 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.
(This information was previously requested as RAl-1 b in the NRC letter dated June 25, 2013.)
L-15-208 Page 2 of 39
Response
By letter dated February 27, 2014, FENOC provided a sketch depicting the requested datum values. Subsequently, more refined measurements were obtained for the top of fuel rack and bottom of measurement range. An updated sketch is provided below.
BVPS Uni! 1 C~ Level Bevatons and Measurement Range (WEC Email ;;r - EL. 767' 10"
~2113) ~75"i _ _ {Drawing RIJ-3A) launch pliihi barn:!
EL. 766' 7.125"
{L*14.024)
.__.....-- EL 766' to 766' 4"
--........_- Normal Level (CR 7.014-12986)
Measurabte Range EL. 758' 291, 125w l Level1 (24' 3.125"}
Probe Length 307. i25~
(25' 7.125")-
(l 14"024)
EL. 752' -
Level2 - -1 (NEI 12-C2, SecUon 2.3.2}
EL 742'4" EL. 742'6.5"-
Level3 (l14*024}
EL 741' 11" -
T
-6" L
l
- 10 feet Top of the Rack (Measur&d 3i6/2Q14)
_._.....1.~~~~~~ ...............~~~~_._-ELnr4" (Drawing RM46)
Attachment 2 L-15-208 Page 3 of 39 RAl-3:
Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP [spent fuel pool] area, depicting the SFP inside dimensions, the planned locations/placement of the primary and 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.
(This information was previously requested as RAl-2 in the NRC letter dated June 25, 2013.)
Response
The response to this RAI was provided by FENOC letter dated February 27, 2014.
Subsequently, by FENOC letter dated February 26, 2015, the design for 8VPS-1 progressed from conceptual design to final design. As a result, some of the locations of the instrumentation and conduit routing were changed. Updated sketches are provided below, depicting general configuration. Previous versions of these sketches were made available to the NRG staff for review.
The electronics enclosure units (transmitters) are located in an area removed from the SFP environment, which would be accessible in the event of a beyond-design-basis external event (8D8EE) that would restrict access to the SFP. The enclosures for the two instrument channels are separated to minimize the possibility of a single event damaging both channels. The primary level indicating transmitter LIT-1FC-200A is located on the west wall of the auxiliary building, general area elevation (El.) 735' 6",
just east of the stairwell. The backup level indicating transmitter LIT-1 FC-2008 is located on the west wall of the auxiliary building, general area El. 735' 6, just east of the stairwell. The level transmitters located in the auxiliary building have a local display, although the credited display units will be located in the main control room (MGR).
Cabling for each channel is run in separate conduits and cable trays to the control room indicators.
The primary electronics enclosure PNL-1 FC-200A (control room analog indication) is located on the south wall of the old Shift Manager's Office in the control room, El. 735' 6". The backup electronics enclosure PNL-1 FC-2008 is also located on the south wall of the old Shift Manager's Office in the control room, El. 735' 6".
/""\llCH... l 111 lt::l l l L L-15-208 Sketches for BVPS-1 Primary SFP Instrumentation Page 4 of 39
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SEE NOTE2 NOTES: SECTION A-A
- 1. FOR PANEL MOUNTING SEE PAGE 3.
- 2. GROUND NE\-J EQUIPMENT TO NEAREST STATION GROUND PER 1/2-PIPS-El5.3.
- 3. ATTACH BONDING JUMPER FROM END OF cmmun TO NEARBY CABL..E TRAY.
AT ELECTRONICS ENCLOSURE, INSTALL A BONDING LOCKNUT AT CONDUIT AND ATTACH A GROUND JUMPER FROM LOCKNUT TO GROUND TERMINAL INSIDE ENCLOSUlE.
- 5. CORE HOLES TD BF DRILLED IN HOLLOW SECTION OF CONCRETE BLOCK WITH A ECP 13-0561-003 MAXIMUM OF ONE HOLE PER BLOCK. CORE HOLE LOCATION TO BE ADJUSTED IN THE =!ELD TO ENSUlE NEW CORE HOLE IS NOT LOCATED ON A GROUT LINE. ITR ATTACHMENT PAGE ? OF 3 L-15-208 Page 12 of 39 Sketches for BVPS-1 Backup SFP Instrumentation
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- 2. DELETED 1 FABRICATE AND INSTALL A RAMP OVER CONDUIT TO AVOID A TRIPPING HAZARD. SEE ATTACHMENT C.
PLAN VIEW
- CORE HOLE TO BE A MAXIMUM OF 2" DIAMETER UNIT l FUEL BUILDING
- 5. CORE HOLE LOCATIC"li IN CRANE RAIL PHESTAL MAY 8£ Al TEREO TD AYD[O FIELD ossnruc::TJOHS.
- 7. A PORT(OH !F fLEX CONDUIT SHALL BE lNSTALLEO IN CCHlUlT Rl.J\I WI-ERE CONOUlT ATTACHEC/Sl.PPORTEO TO AUXILIARY BulLD£NCi STRUCTURE T~ANSITIONS TO CC>>IOUIT ATTACH£0/Sl.PPORTEO TO FUR BUILDING STRUCTlflE TO PROVIDE lSOLATIO"I eETWEEN THE: nro BtllLOJNGS.
ECP 13-0561-004
- 8. THIS SECTION OF CONDUIT IS UNUSED. REMOVE EMPTY CONDUIT AND REPAIR CONCRETE PER
REFERENCE:
1/2-PIP-505 CONDUIT PLANS & DETAILS, FUEL BUILDING RE-SOA ITR ATTACHMENT A PLANS AT EL. 768-5X" & EL. 752'*5" FUEL BUILDING RC-27B PAGE 1 OF 2 REV6 L-15-208 Page 13 of 39
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GROUNDING Pl.OHS, AUX. BUILDING RE*33C PLAN ECP 13-0561-005 CABLE TRl\Y DESIGNATIONS. AUXILIARY SUILOING-SH. t CIJNOUlT Pt.AN, AUX BUILDING*SH. 3 CONDUIT PLAN. AUX BUILDING--SH. 5 RE*3'AH RE**BC RE-<BE AUXILIARY BUILDING EL. 752'-6' & 735'-6'
!TR ATTACHMENT PAGE 1 OF 5 A
Auacnmem L L-15-208 Page 14 of 39
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- l. Sl.f'PORT TYPES AND LOCATIONS FOR CONDUIT ANO JUNCTION BOXES SHOWN ARE SUNESTEO ANO MAY BE AL TEAED IN THE FIELO IN ACCORDANCE WITH THE CRITERIA SECTION A-A SHOWN IN STATION ECIOS ANO PIP PROCEDURES. ANY CHANGES SHALL SE REOLINEO ANO SENT TO DESIGN ENGINEERING FOR ECP CLOSEOUT. AUXILIARY BULDING ECP 13-0561-005
- 2. TYPE A SUPPORTS ARE SHOWN IN BOTH SUPPLEMENT 2 ANO SUPPLEMENT 5 CONDUIT EL. 752'-6' & 735'-6' ITR ATTACHMENT A LAYOUTS. Sl.f'PORTS TO BE INSTALLED IN ONLY ONE SUPPLEMENT.
PAGE 2 OF 5 L-15-208 Page 15 of 39 r1 ~~T~
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- 1. FOR JUr<C TIJN BOX MOUNTING SEE PAGE 4. SECTION B-B
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AUXILIARY BULOil'JC
- 3. GROUMJ NE\-; EQUIPMENT TO NEAREST srnTJOr, EL. 735'-6" GROUND l'EP l/2-P!PS-E15.3.
4, SUPPOPT TYPES ANO LOCATIONS FOR CONDUIT AND JUNCTION BOXES SHOWN ARE SUGGESTED AND M~Y BE A_TERED JN THE FJELD IN ACCORDANCE WITH THE CRITERIA SHUWN II\ STAT JUN EC IDS AND P!F' PROCEuUliES. :'.<NY UWNCES SHALL :lE RE.DLINEO AND SE~T TO DESIGN ENGINEERING FOR ECP CLLISELIU!.
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- 5. SUf"POPT IS SHCWI~ IN ROTH Sl.WPL.E.MENT 2 A\O SUPPLJ.:~*1f:::Nl 5 crn~DUI l i r.\YDUT 'i.
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- ~~,6 PAGE 1 OF 3 Rev.3 1> 2' DIA.
L-15-208 t CORE HOLES
- <SEE NOTE 51 Page 18 of 39 i s~*
EXISTING CONDUIT ROUTED UP THRU DROP CEILING CTYP.l EXISTING EXISTING EXISTING SPEAKER SPEAKER DROP CEILING BLOCK WALL
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EXISTING TYPE AO SUPPORT PLATE ITYP.HSEE NOTE 41 FLOOR EL. 735'-6' SECTION A-A NOTES:
- 1. FOR PANEL MOUNTING SEE PAGE 3.
- 2. GROUND NEW EQUIPMENT TO NEAREST STATION GROUND PER 1/2-PIPS-El5.3.
- 3. ATTACH BONDING JUMPER FROM END OF CONDUIT TO NEARBY CABLE TRAY.
AT ELECTRONICS ENCLOSURE, INSTALL A BONDING LOCKNUT AT CONDUIT AND ATTACH A GROUND JUMPER FROM LOCKNUT TO GROUND TERMINAL INSIDE ENCLOSURE.
Attachment 2 L-15-208 Page 19 of 39 RAl-4:
Please provide the following:
(a) The design criteria that will be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and 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.
(This information was previously requested as RAl-3 in the NRC letter dated June 25, 2013.)
Response
The response to part (a) of this RAI was provided by FENOC letter dated February 27, 2014.
With the exception of providing a schematic, a response to part (b) of this RAI was provided by FENOC letter dated February 27, 2014. The requested schematic contains vendor proprietary information. Westinghouse, LLC (Westinghouse) drawing 1006693, Revision 1, provides details of the mechanical and electrical connections for the mounting of the level sensor in the Fuel Handling Building. The drawing was made available to the NRC staff for review.
The response to part (c) of this RAI was provided by FENOC letter dated February 27, 2014. Part (c) has subsequently been amended as follows:
(c) The attachment of the seismically qualified bracket to the pool deck will be through permanently installed anchors. With permanently installed anchors, the bracket pedestal will be secured to the poolside deck with adequate washers and bolts.
The following results of the response spectra analysis are contained in Westinghouse calculation CN-PEUS-13-25, Revision 1, Seismic Analysis of the SFP Mounting Bracket at Davis-Besse and Beaver Valley Nuclear Stations. The GTSTRUDL model and output considers self-weight, dead load of the instrumentation, hydrodynamic loads due to
Attachment 2 L-15-208 Page 20 of 39 seismic effects, and seismic load on the bracket. All members passed code check with interaction ratios below the allowable limit using the applicable requirements per American Institute of Steel Construction (AISC) 7th Edition. Considering all of the loads and load combinations, all members of the bracket are acceptable. All welds and bolts are acceptable when compared to their applicable allowable values. This calculation, which contains vendor proprietary information, was made available for NRC review.
RAl-5:
For RAI 4(a) above, please provide the results of the analyses used to verify the design criteria and methodology for 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.
Response
The results of the analysis and the parameters used are contained in Westinghouse calculation CN-PEUS-13-25, Revision 1, Seismic Analysis of the SFP Mounting Bracket at Davis-Besse and Beaver Valley Nuclear Stations. The results are obtained from the GTSTRUDL model and are in accordance with site design requirements and AISC 7th Edition. Considering all of the applicable loads and load combinations, all members of the bracket are acceptable. All welds and bolts are acceptable when compared to their applicable allowable values. The results of the analysis represent all the applied loads and load combinations that were applied. The GTSTRUDL model and output considers self-weight, dead load of the instrumentation, hydrodynamic effects of the SFP water, and seismic load on the bracket. All members passed code check with interaction ratios below the allowable limit using the applicable requirements per AISC 7th Edition.
Considering all of the loads and load combinations, all members of the bracket are acceptable. All welds and bolts are acceptable when compared to their applicable values. This calculation, which contains vendor proprietary information, was made available for NRC review.
The seismic-related documents for the evaluation for the mounting of the electronic components and conduits were made available for NRC review. These documents included: Engineering Change Package (ECP) 13-0561-000, Reference Documents -
Installation of Spent Fuel Pool Level Instrumentation (SFPLI) for Beyond Design Basis External Events; ECP 13-0561-001, SFPLI inside the Unit 1 Fuel Handling Building -
Installation of Primary Level Sensor LE-1 FC-200A, including the primary channel wiring, cables, conduits, supports, and equipment in the SFP area; ECP 13-0561-002, SFPLI inside the Unit 1 Auxiliary Building - Installation of Primary Level Indicating Transmitter LIT-1 FC-200A, including the primary channel wiring, cables, conduits, supports, and equipment from the SFP area and to the MCR; ECP 13-0561-003, SFPLI inside the Unit 1 MCR - Installation of Primary Electronic Enclosure (indication) PNL-1 FC-200B, including the primary channel wiring, cables, conduits, supports, and equipment in the MCR; ECP 13-0561-004, SFPLI inside the Unit 1 Fuel Handling Building- Installation of Backup Level Sensor LE-1 FC-200B, including the backup channel wiring, cables,
Attachment 2 L-15-208 Page 21 of 39 conduits, supports, and equipment in the SFP area; ECP 13-0561-005, SFPLI inside the Unit 1 Auxiliary Building - Installation of Backup Level Indicating Transmitter LIT-1 FC-200B, including the backup channel wiring, cables, conduits, supports, and equipment from the SFP area up to the MCR; and ECP 13-0561-006, SFPLI inside the Unit 1 MCR - Installation of Backup Electronic Enclosure (indication) PNL-1 FC-200B, including the backup channel wiring, cables, conduits, supports, and equipment in the MCR.
Calculations are DSC-0351, Spent Fuel Pool Level Instrumentation Mounting Anchor Qualification, and DSC-0352, Spent Fuel Pool Level Instrumentation equipment mounting. The vendor manual is 2507.210-000-008; Qualification Reports; and Drawings. These documents demonstrate that the design for the mounting of electronic components and conduits was completed in accordance with the endorsed guidance in Institute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 344-2004, "IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations."
Because BVPS and Davis-Besse Nuclear Power Station (DBNPS) share a bracket design and because DBNPS has a larger pool, the sloshing analysis performed in CN-PEUS-13-25 is bounded by DBNPS. The wave height due to sloshing is 2.574 feet maximum. This value is documented in CN-PEUS-13-25, Section 4.5.2.3, and is based on TID-7024. This 2.574 feet value is bounded by the 5-foot value considered in the generic qualitative analysis performed for the level sensing probe documented in LTR-SEE-11-13-47. The BVPS-1 specific distance from the nominal water level to the bracket is 15 inches, which is greater than the 12 inches used in the generic analysis performed by Westinghouse (LTR-SEE-11-13-47). Westinghouse and BVPS engineering have assessed the BVPS-1 specific parameters by estimating the change in the postulated hydrodynamic load on the level sensor combined with the design loads. Review of the postulated load has confirmed that it remains within the allowable limit of 2000 lbs for the 3/8 inch anchors, affirming the general conclusions of LTR-SEE-11-13-047 that the resulting loads on the level sensor probe will not result in probe ejection or potential impact of the instrument on the side walls.
RAl-6:
For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.
Response
The response to this RAI was provided by FENOC letter dated February 27, 2014.
Attachment 2 L-15-208 Page 22 of 39 RAl-7:
Please provide the following:
(a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BOB [beyond-design-basis] 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.
(This information was previously requested as RAl-4 in the NRC letter dated June 25, 2013.)
Response
The NRC staff audited the Westinghouse SFP instrumentation design verification analyses and performance test results in support of its review of Tennessee Valley Authority's (TVA's) overall integrated plan for the Watts Bar Nuclear Plant (WBN) facility (ADAMS Accession No. ML14211A346) for compliance to EA-12-051. The NRC staff found the SFP instrumentation design and qualification process reasonable.
Westinghouse methodologies for demonstrating the reliability of the installed SFP level instrumentation system are described in Westinghouse report EQ-QR-269, Revision 1, Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation System and Westinghouse report EQ-QR-264, Revision 0, Equipment Qualification Abbreviated Summary Report for the Spent Fuel Pool Instrumentation System. These reports, which contain vendor proprietary information, were made available for NRC review.
(a) Environmental qualification testing was performed in accordance with Institute of Electrical and Electronics Engineers, Inc. (IEEE) Std. 323-2003, and electromagnetic compatibility (EMC) qualification testing was performed in accordance with the technical requirements of Regulatory Guide 1.180.
Attachment 2 L-15-208 Page 23 of 39 Temperature and Humidity- Thermal aging and steam testing were performed on the coaxial cables and couplers using a thermal aging oven at a temperature of 212°F for the calculated age duration of 311 hours0.0036 days <br />0.0864 hours <br />5.142196e-4 weeks <br />1.183355e-4 months <br /> plus 10 percent margin, or 343 hours0.00397 days <br />0.0953 hours <br />5.671296e-4 weeks <br />1.305115e-4 months <br /> and at 219°F for 206.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> plus a 10 percent margin, or 228 hours0.00264 days <br />0.0633 hours <br />3.769841e-4 weeks <br />8.6754e-5 months <br />. The coaxial cables and couplers were coiled and set on separate racks in the thermal oven. The coupler was required to be threaded into the non-preconditioned end of the cable and aged as one assembly. Steam testing was performed in accordance with IEEE Std. 323-2003. The test specimen was exposed to 212°F (+/- 1.8°F),
100 percent saturated (+O, -2 percent) for a duration including 10 percent margin of 185 hours0.00214 days <br />0.0514 hours <br />3.058862e-4 weeks <br />7.03925e-5 months <br />. In addition, the connectors were splash tested to determine the appropriate torque level and sealing.
Radiation - The coaxial cable and coupler underwent radiation aging in accordance with IEEE Std. 323-2003 for service in post-accident radiation conditions. Test specimens were required to be exposed to a minimum of 11 Mrad of Co60 gamma rays at a dose rate minimum of 0.2 - 0.5 Mrad/hour.
EMC - Susceptibility, emissions and harmonics testing was performed and the guidance and limits provided in Regulatory Guide 1.180 were used. Continuous monitoring was performed to monitor the performance during the application of EMC susceptibility testing. Performance Criterion for this system is determined to be Criterion B.
(b) Seismic qualification testing was performed in accordance with IEEE Std. 344-2004, which is endorsed by NRG Regulatory Guide 1.100, Revision 3, and IEEE Std. 323-2003. The electronics enclosure was mounted to the test fixture with four 3/8-inch Grade 5 bolts, lock washers, flat washers, and nuts torqued snug tight. The sensor head unit mounting bracket was mounted to the fixture with four 3/8-inch Grade 5 bolts, lock washers, and flat washers torqued snug tight. The sensor head unit was mounted to the sensor head unit mounting bracket with two 1/4 inch-20 bolts and lock washers torqued to 75 in-lbs. The coaxial coupler was torqued hand tight. The launch plate was mounted to the fixture with four 5/16-inch Grade 5 bolts and lock washers torqued snug tight. The sensor head unit mounting bracket was mounted to the coupler using the integral threads in the probe and a lock washer to snug tight. Terminal block attachments within the rear of the sensor head unit were torqued to 8 in-lbs.
Seismic testing was performed on a 4x4-foot independent triaxial test table using random, multi-frequency acceleration time history inputs. Accelerometers were mounted on the test table and equipment under test. The table drive signal was applied separately and simultaneously in both the horizontal and vertical directions for a duration of 30 seconds with a minimum of 20 seconds of strong motion. The response from the table and the response accelerometers were analyzed at 5 percent critical dampening for each operating basis earthquake (QBE) and safe shutdown earthquake (SSE) test and were plotted at one twelfth octave intervals over the frequency range of 1 to 100 Hz.
Attachment 2 L-15-208 Page 24 of 39 Seismic testing of the instrumentation was performed in accordance with IEEE 344-2004. The required response spectra (RRS) included a 10 percent margin recommended by IEEE 323-2003. Seismic testing was performed to the defined SSE and hard rock high frequency (HRHF) spectra. The QBE RRS at 5 percent critical damping was at least 70 percent of the respective SSE seismic level. At a minimum, five successful QBE level tests were required, followed by two successful SSE level tests and one successful HRHF level test. In addition, static pull tests were performed on the Radial! connectors (straight and 90 degree) to address seismic qualification of the connectors.
(c) The equipment under test (EUT) was powered on during QBE seismic test runs, but was not electrically monitored during the test runs. Functional testing was performed before and after the five successful QBE test runs. The system maintained accuracy after five successful QBE level tests and no loss of power was noted during the test runs. The EUT was powered on during all SSE and HRHF seismic test runs, but was not electrically monitored during the test runs. Functional testing was also performed before and after each successful SSE and HRHF test run. The system maintained accuracy after all SSE and HRHF level tests and no loss of power was noted during the test runs.
During the SSE 2, the alternating current (AC) power was removed from the system approximately 15 seconds into the run. This operation was performed to ensure that the uninterruptible power supply (UPS) was able to switch from line power to battery power during a seismic event. The system performed without issue. The EUT met all of the required performance and acceptance criteria and maintained structural integrity during all acceptable QBE test runs, acceptable SSE test runs, and the acceptable HRHF test run to the RRS. Acceptable functionality of the EUT was confirmed upon completion of seismic testing. The post-test inspection performed upon completion of all seismic tests revealed no major structural issues or damage to the EUT.
RAl-8:
For RAI 7 above, please provide the results from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
Response
The NRC staff audited the Westinghouse SFP instrumentation design verification analyses and performance test results in support of its review of TVA's overall integrated plan for the WBN facility (ADAMS Accession No. ML14211A346) for compliance to EA-12-051. The NRC staff found the SFP instrumentation design and qualification process reasonable.
Westinghouse test results for the SFP level instrumentation system are described in Westinghouse report EQ-QR-269, Revision 1, Design Verification Testing Summary
Attachment 2 L-15-208 Page 25 of 39 Report for the Spent Fuel Pool Instrumentation System and Westinghouse report EQ-QR-264, Revision 0, Equipment Qualification Abbreviated Summary Report for the Spent Fuel Pool Instrumentation System. These reports, which contain vendor proprietary information, were made available for NRC review.
Temperature and Humidity - Thermal aging was performed within the required temperature parameters and for the required duration and a post-thermal aging functional test was successfully performed. During steam testing, functional tests were performed, which verified that the test equipment was functioning within the required accuracy, as well as confirmed that the enclosure display correctly identified the simulated pool level. Acceptable functional test results were obtained during functional testing. Post-test baseline testing was conducted upon completion of environmental testing with successful functional results.
Westinghouse concluded that the probe, coaxial cable, 90 degree and straight connector, and stainless steel coupler are able to perform in abnormal conditions in the SFP area for up to seven days. In addition, Westinghouse tests demonstrated that the level sensor electronics with the coupler and the coaxial cable attached performs accurately when the probe, coupler, and coaxial cable are exposed to a temperature range of 1O to 100°C (50-212°F) and up to 100 percent relative humidity (RH).
Regarding components outside the SFP area, Westinghouse concluded the aggregate of the environmental verification activities for the SFP instrumentation demonstrate that the instrumentation operates reliably in accordance with the service environmental requirements specified for both the harsh and outside SFP area conditions. The level sensor electronics housing was also verified to meet IP67 rating per EPSILON 08 TEST 2373, which will prevent water ingress and withstand 100 percent humidity.
In addition, Westinghouse completed their 10-year aging test. The purpose of the testing was to extend the existing qualified life from 15 months to 10 years. The system with the 90 degree connector passed the test and is now qualified to a 10-year life. The BVPS design uses the 90 degree connector.
Shock and Vibration - Seismic testing consisted of five successful QBE tests, two successful SSE tests, and one successful HRHF test. During the second successful SSE level test (281 SSE 2), AC power was cut off to the SFP instrumentation system to ensure that the UPS would reliably switch during a seismic event. No equipment failures were noted as a result of the seismic test runs. Westinghouse performed functional testing of the equipment before and after each SSE and HRHF runs, and the equipment maintained its functionality. In addition, Westinghouse inspected the equipment after the seismic testing and no damage was found. Westinghouse concluded that the system met all requirements, maintaining structural integrity during and after all OBEs, SSEs and HRHF tests.
Radiation - The coaxial signal cable and coupler were subjected to thermal and radiation aging prior to seismic testing. Two sets of identical specimens were aged, and the components performed to the limits of 2.5 years for thermal aging and
Attachment 2 L-15-208 Page 26 of 39 10 MRad + 10 percent margin for radiation aging. The coaxial cable and coupler were visually inspected after radiation resting. It was identified that a lock washer was missing from the probe attachment point of the coupler. Westinghouse noted that the absence of this lock washer had no effect on the thermal or radiation aging performed, and that the inspection did not reveal any noticeable degradation. A baseline functional test was performed and did not show any change in performance as a result of the radiation aging performed.
EMC - The system met all of the identified performance requirements before, during and after each EMC susceptibility test and demonstrated compliant emission levels. No modifications or deviations were required to achieve compliance during EMC testing.
RAl-9:
Please provide the following:
(a) A description of how the two channels of the proposed level measurement system meet this requirement so that the potential for 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.
(This information was previously requested as RAl-5 in the NRC letter dated June 25, 2013.)
Response
The response to this RAI was provided by FENOC letter dated February 27, 2014.
Subsequently, by FENOC letter dated February 26, 2015, the design for BVPS-1 progressed from conceptual design to final design. As a result, some of the locations of the instrumentation and conduit routing were changed. An amended response to part (a) for BVPS-1 is hereby provided.
(a) Within the Unit 1 SFP area, the brackets were mounted as close to the northeast (primary sensor) and southeast (back-up sensor) corners of the SFP, as permanent plant structures allow. Placing the brackets and probes in the corners allows for natural protection from a single event or missile from disabling both systems. The cabling within the SFP area will be routed in separate hard-pipe conduit. All conduit routing and location of system components will be selected such that there will not be any seismic 2-over-1 hazard. Site safety related separation requirements will be followed.
Attachment 2 L-15-208 Page 27 of 39 RAl-10:
Please provide the following:
(a) A description of the electrical ac power sources and capabilities for the primary and backup channels.
(b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.
(This information was previously requested as RAl-6 in the NRC letter dated June 25, 2013. However, based on feedback from the licensees, it was revised as above.)
Response
The response to part (a) of this RAI was provided by FENOC letter dated February 27, 2014.
(b) The back-up battery is designed to last a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The vendor's calculation has determined that the battery will last from a full charge for greater than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per Section 5.2.1 of Westinghouse calculation WNA-CN-00300-GEN, Revision 0, Spent Fuel Pool Instrumentation System Power Consumption.
RAl-11:
Please provide the following:
(a) An estimate of the expected instrument channel accuracy performance (e.g.,
in percent of span) under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BOB 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.
(This information was previously requested as RAl-7 in the NRC letter dated June 25, 2013.)
Response
Attachment 2 L-15-208 Page 28 of 39 (a) The design accuracy is 3 inches or less for both normal and BOB conditions and the calculated accuracy for BVPS of 1.60 inches is within the design range. The calculated accuracy of the instrumentation is 0.54 percent.
(b) A periodic calibration verification will be performed within 60 days of a refueling outage considering normal testing scheduling allowances (for example, 25 percent).
Calibration verification will not be required to be performed more than once per 12 months. These calibration requirements are consistent with the guidance provided in Nuclear Energy Institute (NEI) 12-02, Section 4.3. Per Westinghouse procedures, should the calibration verification indicate that the instrument is out of tolerance by more than the designed 3-inch tolerance, a recalibration will be performed.
RAl-12:
Please provide the following:
(a) A description of the capability and provisions the proposed level 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.
(This information was previously requested as RAl-8 in the NRC letter dated June 25, 2013.)
Response
(a) A periodic calibration verification will be performed in-situ to verify that the transmitter is in calibration using a calibration verification tool provided by the manufacturer and in accordance with the plant procedures and manufacturer's recommendations (Reference RAI 14 response for more detail). Should the calibration verification indicate that the transmitter is out of calibration, a full-range calibration adjustment will be completed using a calibration test kit. The portable test kit is composed of a replicate probe, coupler and launch plate equivalent to those installed, a replicate coaxial cable of the same electrical length as installed in
Attachment 2 L-15-208 Page 29 of 39 the pool, a bracket to hold the weight end of the probe cable, simulated pool liner, and a moveable metal target. To perform the calibration, the installed SFP instrumentation system coaxial cable is disconnected from the sensor and the replicate test kit coaxial cable is connected. A metal target is used to measure several points along the length of the probe to perform the full-range calibration.
The readings displayed on the output display at each point along the probe will be compared to the physical distance measured along the length of the probe cable to determine calibration acceptance. Each component in the instrument channel can be replaced (transmitter included) to restore the instrument loop to service in the event a component failure occurs.
(b) A channel check is not conducted as part of 1LCP-20-L200A, Calibration of Fuel Pool Level Instrumentation Loop L-1 FC-200A, and 1LCP-20-L200B, Calibration of Fuel Pool Level Instrumentation Loop L-1 FC-2008, to ensure that upon completion of the calibration check or calibration that the two channels compare within acceptable limits. The SFP level indication is located in the main control room. To aid in early detection of any "off normal" readings, which could indicate that channel adjustment may be required, a daily channel check using this indication of SFP level has been added to 10M-54.3.L5, Surveillance Verification Log. The channel check confirms that the two SFP level instruments are reading within one foot of each other. As installed, the level instruments typically read within approximately 1/2 foot of each other (+/-3 inches calibration tolerance for each instrument) and the instrument scale reading is in 1/2 foot increments, establishing the basis of one scale unit divergence (1/2 foot) for the one foot channel check acceptance criteria.
The channel check periodicity and acceptance criteria are controlled within BVPS-1 operating procedures and periodic maintenance programs and may change based on equipment operating experience. Testing to validate instrument functionality per NEI 12-02, Section 4.3, is based on the instrument calibration periodicity as noted in response to RAl-12(c).
(c) FENOC will perform periodic calibration verifications using periodic maintenance procedures and manufacturer's guidelines. The periodic calibration verification will be performed within 60 days of a refueling outage considering normal testing scheduling allowances (for example, 25 percent). Calibration verification will not be required to be performed more than once per 12 months. These calibration requirements are consistent with the guidance provided in NEI 12-02, Section 4.3.
(d) Preventive Maintenance (PM) procedures will be in place for periodic replacement of the backup batteries based on manufacturer recommendations and for calibration verification.
RAl-13:
Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is
Attachment 2 L-15-208 Page 30 of 39 requested to include a brief description of the specific technical objectives to be achieved within each procedure.
Response
The modification review process will be used to ensure all necessary procedures are developed for maintaining and operating the spent fuel level instruments upon installation. These procedures will be developed in accordance with the FENOC procedural control process.
The objectives of each procedural area are described below:
Inspection. Calibration. and Testing - Guidance on the performance of periodic visual inspections, as well as calibration and testing, to ensure that each SFP channel is operating and indicating level within its design accuracy.
Preventative Maintenance - Guidance on scheduling of, and performing, appropriate preventative maintenance activities necessary to maintain the instruments in a reliable condition.
Maintenance - To specify troubleshooting and repair activities necessary to address system malfunctions.
Programmatic controls - Guidance on actions to be taken if one or more channels is out of service.
System Operations - To provide instructions for operation and use of the system by plant staff.
Response to inadequate levels -Action to be taken on observations of levels below normal level will be addressed in site Off Normal procedures and/or FLEX [Diverse and Flexible Coping Strategies] Support Guidelines (FSGs).
The following procedures have been identified to date:
- 1/20M-53C.4A.100.4, Spent Fuel Pool
- 1OM-20.1.E, Specific Instrumentation and Controls
- 1OM-20.3.C, Power Supply and Control Switch List
- 1OM-20.4.AAC, Spent Fuel Pool Level Low
- 1OM-20.4.AAI, Spent Fuel Pool Level High
- 1OM-38.5.B.3, Table 38-3 Vital Bus Load List
- 1OM-53C.4.1.20.1, Spent Fuel Pool Cooling Trouble
- 1 LCP-20-L200A, Calibration of Fuel Pool Level Instrumentation Loop L-1 FC-200A
Attachment 2 L-15-208 Page 31 of 39
- 1LCP-20-L200B, Calibration of Fuel Pool Level Instrumentation Loop L-1FC-200B
- 1/20M-53E.1.FSOA-8, Honda EU 1OOOi 120V Gen Operating Aid
- 600978919, Calibration Verification Check (once every 18 months, within 60 days after a refueling outage)
- 600981219, Primary Level Sensor (transmitter) replacement (6 years)
- 600981219, Backup Level Sensor (transmitter) replacement (6 years)
- 600981219, Primary Electronics Enclosure replacement (10 years)
- 600981219, Backup Electronics Enclosure replacement (10 years)
- 600981219, Primary Battery replacement (3 years)
- 600981219, Backup Battery replacement (3 years)
- 600981219, Primary Coaxial Cable, Coupler, and Coaxial Connector replacement (10 years)
- 600981219, Backup Coaxial Cable, Coupler, and Coaxial Connector replacement (10 years)
RAl-14:
Please provide the following:
(a) Further information describing the maintenance and testing 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 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.
(This information was previously requested as RAl-11 in the NRC letter dated June 25, 2013.)
Response
(a) SFP instrumentation channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness will be established in accordance with FENOC's processes and procedures. The design
Attachment 2 L-15-208 Page 32 of 39 modification process will take into consideration the vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit).
Once the maintenance and testing program requirements for the SFP are determined, the requirements will be documented in maintenance program documents.
Performance checks, described in the vendor operator's manual, and the applicable information will be contained in plant procedures. Operator performance tests will be performed periodically as recommended by the vendor.
Channel functional tests with limits established in consideration of vendor equipment specifications will be performed at appropriate frequencies.
Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications are planned to be performed at frequencies established in consideration of vendor recommendations.
(b) Both primary and backup SFP instrumentation channels incorporate permanent installation (with no reliance on portable, post-event installation) of relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) is (are) out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:
Compensatory Action if Required Restoration
- Channel(s) Action not completed Out-of-Service Required Restoration Action within Specified Time 1 Restore channel to Immediately initiate functional status within action in accordance with 90 days (or if channel Note below restoration not expected within 90 days, then proceed to Compensatory Action) 2 Initiate action within Immediately initiate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one action in accordance with channel to functional status Note below and restore one channel to functional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
Attachment 2 L-15-208 Page 33 of 39 Notes:
- 1. Present a report to the on-site safety review committee within the following 14 days. The report shall outline the planned alternate method of monitoring, the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.
(c) A condition report will be initiated and addressed through FENOC's Corrective Action Program. Provisions associated with out of service (OOS) or non-functional equipment, including allowed outage times and compensatory actions, will be consistent with the guidance provided in Section 4.3 of NEI 12-02. If one OOS channel cannot be restored to service within 90 days, appropriate compensatory actions, including the use of alternate suitable equipment, will be taken. If both channels become OOS, actions would be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels to operable status and to implement appropriate compensatory actions, including the use of alternate suitable equipment and/or supplemental personnel, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
RAl-15:
Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.
Response
The calibration verification involves attaching a sliding plate to the flat surface above the launch plate of the fixed bracket and placing a metal target against the probe cable above the water level. To complete this method, the water level must be a sufficient distance below the 100 percent level mark, which is nominally 12 inches below the launch plate. The differences in distances imparted by this standard can be physically determined and compared to the distance difference observed on the level display of the sensor electronics. The second portion of this calibration verification is a visual waveform check to verify proper signal operation. If the calibration verification check falls within the required calibration tolerance (+/-3 inches) and the waveform check meets the criteria outlined, the calibration verification is successful and the equipment may be returned to the normal operating setup. If an anomaly with the calibration is observed during this calibration verification, the electronic verification or calibration adjustment is to be followed for further investigation. This verification shall be performed on both channels (primary and backup) of the SFP instrumentation system independently.
Attachment 2 L-15-208 Page 34 of 39 WestingliO use l2Y **Topic Parametei::Summary
,'* *. Reference Document#.
~dditional Comment Test or Analysis. Results
/
. Licensee Evaluatfon
/ .
1 Design Specification SfPIS Requirements WNA-DS-02957-GEN Contains technical SFPIS NIA Acceptable. FENOC derived from requirements based on NRC provided a supplemental References 1, 2, & 3 order, NEI guidance, and the Technical Requirements ISG listed above. Document in the Equipment Purchase Order 2 Test Strategy Per Requirements. WNA-PT-00188-GEN Strategy for performing the NIA Acceptable testing and verification of the SFPIS and pool-side bracket.
3 Environmental 50° F to 140° F, EQ-QR-269 and Results are summarized in Test passed conditions Acceptable qualification for Oto 95%RH WNA-TR-03149-GEN EQ-QR-269 and WNA-TR- described.
electronics enclosure for all conditions. 03149-GEN.
with Display TID S 1E03 Ry normal (outside SFP Radiation Aging verification area) summarized in Section 5 of WNA-TR-03149-GEN.
TID::; 1E03 Ry abnormal (outside SFP area) 4 Environmental Testing 50°F to212°Fand EQ-QR-269, Rev. 1 Testing summarized in Passed Acceptable for Level Sensor 100% humidity Section 5.7.
components in SFP area
- Saturated Steam & 1E03 Ry normal (SFP WNA-TR-03149-GEN Thermal Aging & radiation Passed Acceptable Radiation area) aging verification summarized in Sections 4.1 and 5 (entire system) of WNA-TR-03149-GEN.
I E07 Ry BDB (SFP EQ-TP-354 (procedure) Additional thermal & Additional aging program Acceptable area) Actual test report is in radiation aging programs is in progress to achieve progress. being conducted under test longer life.
procedure EQ-TP-354.
5 Environmental Testing 50° F to 140° F, EQ-QR-269, Rev. 1 Testing summarized in Passed Acceptable for Level Sensor 0 to 95% RH Section 5.5.
Electronics Housing -
Attachment 2 L-15-208 Page 35 of 39
,;\Vestinghouse
- Topi~ , , Paranieb~r Suniinarf Additional Comment Test or Analysis Results Licensee Evaluation
' . Reference Document# * . .
outside SFP 100% RH WNA-TR-03149-GEN 100% humidity addressed in Passed Section 7.5.
TID S 1E03 Ry WNA-TR-03149-GEN Radiation Aging verification Passed normal (outside SFP summarized in Section 5.
area)
TIDS 1E03 Ry abnormal (outside SFP area) 6 Thermal & Radiation 1E03 R y normal (SFP EQ-QR-269, Rev. 1 and Thermal Aging & radiation Passed Acceptable with the Aging - organic area) WNA-TR-03149-GEN aging verification exception of the 10-year components in SFP area summarized in Sections 4.1 aging test failure and 5 (entire system) of documented per WNA-TR-03149-GEN. Westinghouse Letter L TR-1E07 Ry BDB (SFP EQ-TP-354 (procedure) Additional thermal & Additional aging program EQ-14-149, steam test area) Actual test report is in radiation aging programs is in progress to achieve failure using the straight progress. being conducted under test longer life. connector (affects Peny) procedure EQ-TP-354.
7 Basis for Dose SFPNormal LTR-SFPIS-13-35 and Explanation of Basis for Passed for all conditions Acceptable Requirement Conditions: WNA-DS-02957-GEN Radiation Dose Requirement 1E03 Ry TID (above (includes the clarification of pool) production equivalency of electronics enclosure used for 1E09 Ry TID (1' Seismic and EMC Testing) above fuel rack)
SFPBDBE Conditions:
1E07 Ry TID (above pool)
< 1E07 R y TID (I' above fuel rack)
Attachment 2 L-15-208 Page 36 of 39
- Topic .Parameter
. .* . * .. *. Summary*
. Westinghou.~~
.1 Reference ..*.... *** ... *****.*'*I Additional Comment*
Do.cument# Test.or Analysis Results £icellse~ Evaluation 8 Seismic Qualification Per Spectra in WNA-DS-02957-GEN I EQ-QR-269, Rev. I Isummarizes EQ-QR-269, Rev. 1 the testing Passed Acceptable performed by Westinghouse.
WNA-TR-03149-GEN WNA-TR-03149-GEN Passed provides high level summary of the pool-side bracket analysis and optional RTD.
EQ-QR-269, Rev. I Seismic Pull test for new Passed connectors documented in Section 4 .4.
9 I Sloshing NIA LTR-SEE-Il-13-47 Calculation to demonstrate I Passed Acceptable that probe will not be sloshed out of the SFP.
WNA-TR-03149-GEN Sloshing is also addressed in I Passed Section 7.2.
10 I Spent Fuel Pool Acceptance Criteria I WNA-TP-04613-GEN Test procedure used to See applicable EQ test. Acceptable Instrumentation System for Performance demonstrate that SFPIS meet Functionality Test during EQ testing its operational and accuracy Procedure requirements during Equipment Qualification Testing programs.
11 I Boron Build-Up Per requirement in I WNA-TR-03149-GEN Boron build up demonstrated Passed Acceptable WNA-DS-02957-GEN through Integrated Functional Test (IFT).
12 I Pool-side Bracket NIA I CN-PEUS-13-25, Rev. I Also includes hydrodynamic Passed Acceptable Seismic Analysis (Davis Besse and Beaver forces, as appropriate.
Valley)
CN-PEUS-13-27, Rev. 2 (Perry) 13 I Additional Brackets NIA I WNA-DS-02957-GEN Weights provided to NIA Acceptable (Sensor Electronics and licensees for their own Electronics Enclosure) evaluation.
Attachment 2 L-15-208 Page 37 of 39 i- '.*
Westinghouse
- Topic Parameter Surillllary ;
AdditionafComment Test or Analysis Results Licensee Evaluatio~
.* .. *.* R~ference Document #
14 Shock & Vibration WNA-DS-02957-GEN WNA-TR-03149-GEN Section 7 provides rationale NIA and summary ofRTD.
15 Requirements Maps Requirements to WNA-VR-00408-GEN The RTM maps the Complete Acceptable Traceability Matrix documentation I requirements of the NRC evidence that order, NEI guidance, ISG to Requirement is met the applicable technical requirements in the SFPIS design specification and maps the design specification requirements to the documentation demonstrating the requirement is met.
16 Westinghouse Factory IFT Functional WNA-TP-04752-GEN The Integrated Functional Pilot IFT executed/passed Acceptable Acceptance Test, Requirements from Test (IFT) demonstrates including testing of WNA-DS-02957-GEN functionality of the full Beaver Valley IFT dead-zones system for each customer's executed/passed FAT, which includes calibration of each channel. Davis Besse IFT executed/passed Perry IFT executed/passed 12" dead-zone at top WNA-TP-04 752-GEN Dead-zone tests are in NIA of probe Section 9.6.2.
4" dead-zone at bottom of probe 17 Channel Accuracy +/- 3 inches per WNA- WNA-CN-00301-GEN Channel accuracy from Passed Acceptable DS-02957-GEN measurement to display.
18 Power Consumption 3 day battery life WNA-CN-00300-GEN NIA Passed Acceptable (minimum) 0.257 Amps power consumption
Attachment 2 L-15-208 Page 38 of 39
- Topic
- Par,.lrieter Summary Westillglioµs~ ...
Additional Comment' Test or Analysis.Results
. J,,ic~nsee Evaluation ReferenceDl>cuOient #
19 Technical Manual NIA WNA-G0-00127-GEN Information and instructions NIA Acceptable for Operation, Installation, use, etc. are included here.
20 Calibration Routine WNA-TP-04 709-GEN Also, includes preventative NIA Acceptable Testing/calibration maintenance actions such as verification and those for Boron buildup and Calibration method cable probe inspection.
21 Failure Modes and NIA WNA-AR-00377-GEN Addresses mitigations for the NIA Acceptable Effects Analysis potential failure modes of the (FMEA) system.
22 Emissions Testing RG 1.180 Rl test EQ-QR-269, Rev. 1 Documented in Section 5.6. Passed Acceptable conditions
References:
- 1) ML12056A044, NRC Order EA-12-051, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION," Nuclear Regulatory Commission, March 12, 2012.
- 2) ML12240A307, NEI 12-02 (Revision 1), "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" August, 2012.
- 3) ML12221A339, Revision 0, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", August 29, 2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate.
- 4) Westinghouse Proprietary Document, WNA-DS-02957-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System Design Specification," Revision 4 reviewed by NRC in April 2014; current revision is Revision 4.
- 5) Westinghouse Proprietary Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy," Revision 1 reviewed by NRC in February 2014; NRC did not review in April; current revision is Revision 2.
- 6) Westinghouse Proprietary Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation,"
Revision 1 reviewed by NRC in April 2014; current revision is Revision 1.
- 7) Westinghouse Proprietary Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report," Revision 1 reviewed by NRC in April 2014; current revision is Revision 1.
L-15-208 Page 39 of 39
- 8) Westinghouse Proprietary Document, LTR-SFPIS-13-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronics Enclosure Used for Seismic Testing," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 1.
- 9) Westinghouse Proprietary Document, LTR-SEE-11-13-47, "Determination ifthe Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out of the Spent Fuel Pool during a Seismic Event," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.
- 10) Westinghouse Proprietary Document, WNA-TP-04613-GEN, "Spent Fuel Pool Instrumentation System Functionality Test Procedure," Revision 5 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 5.
- 11) Westinghouse Proprietary Document, CN-PEUS-13-25, "Seismic Analysis of the SFP Mounting Bracket at Davis Besse and Beaver Valley Nuclear Stations," Revision 1; never reviewed by the NRC.
- 12) Westinghouse Proprietary Document, CN-PEUS-13-27, "Seismic Analysis of the SFP Mounting Bracket at Perry Nuclear Power Plant,"
Revision 2; never reviewed by the NRC.
- 13) Westinghouse Proprietary Document, WNA-VR-00408-GEN, "Spent Fuel Pool Instrumentation System Requirement Traceability Matrix,"
Revision 0 reviewed by the NRC in April 2014; current revision is Revision 1.
- 14) Westinghouse Proprietary Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Procedure," Revision 1 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 1.
- 15) Westinghouse Proprietary Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 1.
- 16) Westinghouse Proprietary Document, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation,"
Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 1.
- 17) Westinghouse Proprietary Document, WNA-G0-00127-GEN, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual,"
Revision 1 reviewed by the NRC in April 2014; current revision is Revision 1.
- 18) Westinghouse Proprietary Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure," Revision 3 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.
- 19) Westinghouse Proprietary Document, WNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis,"
Revision 2 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 3.