ML13154A166
| ML13154A166 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/29/2013 |
| From: | Beltz T Plant Licensing Branch III |
| To: | Millen M Point Beach |
| References | |
| EA-12-051, TAC MF0729, TAC MF0730 | |
| Download: ML13154A166 (10) | |
Text
NRR-PMDAPEm Resource From: Beltz, Terry Sent: Wednesday, May 29, 2013 10:26 AM To: Millen, Michael Cc: Hanneman, Harv; Jerry.Phillabaum@fpl.com; Wasik, Chris; Larry.Meyer@nexteraenergy.com; Carlson, Robert; Wyman, Stephen; Roque-Cruz, Carla
Subject:
Point Beach Nuclear Plant, Units 1 and 2 - Draft Requests for Additional Information re:
Integrated Plan for Reliable SFP Instrumentation (Order No. EA-12-051) (TAC Nos. MF0729 and MF0730)
Attachments: Point Beach Nuclear Plant, Units 1 and 2 - Draft RAIs Regarding Order EA-12-051.docx
Dear Mr. Millen:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated February 22, 2013 (Agencywide Documents Access and Management System Accession No. ML13053A399), NextEra Energy Point Beach, LLC submitted an Overall Integrated Plan for the Point Beach Nuclear Plant, Units 1 and 2, in response to the March 12, 2012, Commission Order modifying licenses with regard to requirements for Reliable Spent Fuel Pool (SFP)
Instrumentation (Order Number EA-12-051).
The NRC staff in the Balance of Plant Branch and the Instrumentation & Controls Branch of the Office of Nuclear Reactor Regulation have identified additional information that is needed to complete its technical review. The NRC staffs draft Request for Additional Information is enclosed.
You may accept this as a formal request for additional information and respond to the questions by July 5, 2013. Alternatively, you may request to discuss the content of these RAIs with the NRC staff in a conference call, including any change to the proposed response date.
Please let me know if you have any questions or concerns.
Sincerely, Terry A. Beltz, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-3049 Terry.Beltz@nrc.gov 1
Hearing Identifier: NRR_PMDA Email Number: 714 Mail Envelope Properties (7E9EA9BB82325E46B07B0F04F99B40D87C5603838A)
Subject:
Point Beach Nuclear Plant, Units 1 and 2 - Draft Requests for Additional Information re: Integrated Plan for Reliable SFP Instrumentation (Order No. EA-12-051) (TAC Nos.
MF0729 and MF0730)
Sent Date: 5/29/2013 10:26:13 AM Received Date: 5/29/2013 10:26:00 AM From: Beltz, Terry Created By: Terry.Beltz@nrc.gov Recipients:
"Hanneman, Harv" <Harv.Hanneman@nexteraenergy.com>
Tracking Status: None "Jerry.Phillabaum@fpl.com" <Jerry.Phillabaum@fpl.com>
Tracking Status: None "Wasik, Chris" <Chris.Wasik@fpl.com>
Tracking Status: None "Larry.Meyer@nexteraenergy.com" <Larry.Meyer@nexteraenergy.com>
Tracking Status: None "Carlson, Robert" <Robert.Carlson@nrc.gov>
Tracking Status: None "Wyman, Stephen" <Stephen.Wyman@nrc.gov>
Tracking Status: None "Roque-Cruz, Carla" <Carla.Roque-Cruz@nrc.gov>
Tracking Status: None "Millen, Michael" <Michael.Millen@nexteraenergy.com>
Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 1365 5/29/2013 10:26:00 AM Point Beach Nuclear Plant, Units 1 and 2 - Draft RAIs Regarding Order EA-12-051.docx 47354 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
REQUEST FOR ADDITIONAL INFORMATION OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-051, RELIABLE SPENT FUEL POOL INSTRUMENTATION NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-266 AND 50-301 (TAC NOS. MF0729 AND MF0730)
1.0 INTRODUCTION
By letter dated February 22, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13053A399), NextEra Energy Point Beach, LLC (NextEra, the licensee) submitted an Overall Integrated Plan (OIP) for the Point Beach Nuclear Plant, Units 1 and 2, in response to the March 12, 2012, U.S. Nuclear Regulatory Commission (NRC) Order modifying licenses with regard to requirements for Reliable Spent Fuel Pool (SFP)
Instrumentation (Order Number EA-12-051; ADAMS Accession No. ML12054A679). The NRC staff endorsed Nuclear Energy Institute (NEI) 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, to Modify Licenses with Regard to Reliable SFP Instrumentation, Revision 1, dated August 2012 (ADAMS Accession No. ML12240A307), with exceptions as documented in Interim Staff Guidance (ISG) 2012-03, Compliance with Order EA-12-051, Reliable SFP Instrumentation, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339).
The NRC staff has reviewed the licensees February 22, 2013, response and determined that the following requests for additional information (RAI) are needed to complete its technical review. If any part of this information is not available by the July 5, 2013, response date for these RAIs, please provide the date this information will be submitted.
2.0 LEVELS OF REQUIRED MONITORING
RAI-1
The OIP states, in part, that
- 1. Level adequate to support operation of the normal spent fuel pool cooling system - lndicated level on either the primary or backup instrument channel of greater than or equal to 23 feet (plant elevation 60 feet 9 inches) above the top of the irradiated fuel assemblies seated in the storage racks. This level is above the spent fuel pool cooling suction and return connections' siphon breaker at 21 feet 11 inches (plant elevation 59 feet 8 inches) above the active fuel.
Enclosure
- 2. Level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck - lndicated level on either the primary or backup instrument channel of greater than 10 feet (plant elevation 47 feet 9 inches) above the top of the irradiated fuel assembles seated in the storage racks. This monitoring level ensures there is adequate water level to provide substantial radiation shielding for personnel to respond to Beyond-Design-Basis External Events and to initiate SFP makeup strategies.
- 3. Level where fuel remains covered - Indicated level on either the primary or backup instrument channel of greater than 2 feet 11 inches (plant elevation 40 feet 8 inches) above the top of the irradiated fuel assemblies seated in the storage racks. This monitoring level assures that there is adequate water level above the stored fuel seated in the rack. This monitoring level is where actions to implement makeup water addition should no longer be delayed. The top of the fuel assemblies is located at plant elevation 37 feet 9 inches. The top of the east west oriented wall opening that separates the northern and southern areas of the SFP is at plant elevation 40 feet 8 inches (see Section XVlll Drawing). Once the water level drops below this point, the single SFP has effectively been segregated into two separate pools. Consequently, plant elevation 40 feet 8 inches is the level at which actions to initiate water make-up should not be further delayed.
Please provide the following:
a) For level 1, specify how the identified location represents the HIGHER of the two points described in the NEI 12-02 guidance for this level. For level 3, specify whether the east/west oriented wall may be altered as to further segregate the north/south pool areas by the use of a gate or temporary wall section and if so, the conditions of its use.
b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of 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. 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.
3.0 INSTRUMENTATION DESIGN FEATURES
RAI-2
3.3 Mounting The OIP states, in part, that Mounting will be Seismic Class I. Installed equipment will be seismically qualified to withstand the maximum seismic ground motion considered in the design of the plant area in which it is installed.
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.
RAI-3
3.4 Qualification The OIP states, in part, that Components of the instrument channels will be qualified for shock and vibration using one or more of the following methods:
- Components are supplied by manufacturers using commercial quality programs (such as 1S09001, Quality management systems - Requirements) with shock and vibration requirements included in the purchase specification at levels commensurate with portable hand-held device or transportation applications,
- Components have a substantial history of operational reliability in environments with significant shock and vibration loading, such as portable hand-held device, or transportation applications, or
- Components are inherently resistant to shock and vibration loadings, such as cables.
The effects of postulated seismic events on installed instrument channel components (with the exception of battery chargers and replaceable batteries), will be verified to ensure that the equipment design and installation is robust. Applicable components of the instrument channels will be qualified by the manufacturer (or otherwise tested) for seismic effects at response levels commensurate with the equipment mounting location.
Instrument channel qualification will be based on the guidance provided in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard. In addition, any of the below may also be used to provide additional assurance that the equipment will perform as designed during and following a seismic event: . . .
Please provide the following:
a) A description of the specific method or combination of methods you intend to apply to demonstrate the reliability of the permanently installed equipment under Beyond-Design-Basis (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 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) Please provide a description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment during and following seismic conditions to maintain its required accuracy.
RAI-4
3.5 Independence The OIP states, in part, that The primary instrument channel will be redundant to and independent of the backup instrument channel. Independence will be obtained through separation of the sensors, indication, backup battery power supplies, associated cabling and channel power feeds.
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 precluded.
b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RAI-5
3.6 Power Supplies The OIP states, in part, that Both channels will be powered from dedicated batteries and local battery chargers. The battery chargers for both channels will normally be powered from non-safety related 120V AC power. Minimum battery life of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will be provided. The battery systems will include provision for battery replacement should the battery charger be unavailable following the event. Spare batteries will be readily available. In the event of a loss of normal power the battery chargers could be connected to another suitable power source.
If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BDB event for the minimum duration needed, consistent with the plant FLEX Program plans.
RAI-6
3.7 Accuracy The OIP states, in part, that Instrument channels will be designed such that they will maintain their design accuracy following a power interruption or change in power source without recalibration.
Accuracy will consider SFP conditions, e.g., saturated water, steam environment, or concentrated borated water. Additionally, instrument accuracy will be sufficient to allow trained personnel to determine when the actual level exceeds the specified lower level of each indicating range (levels 1, 2 and 3) without conflicting or ambiguous indication. The accuracy will be within the resolution requirements of Figure 1 of NEI 12-02.
Please provide the following:
a) An estimate of the expected instrument channel accuracy performance (e.g., in % of calibrated 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- 7 3.8 Testing The OIP states, in part, that Instrument channel design will provide for routine testing and calibration consistent with Order EA-12-051 and the guidance in NEI 12-02. Instrument channel testing and calibration will be performed using existing plant work control processes. Details will be determined during the engineering and design phase.
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 functional checks will be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.
d) A description of what preventative 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-8
3.9 Display The OIP states, in part, that Remote indication will be provided in the Primary Auxiliary Building. This provides an indication that will be accessible during post accident conditions.
This location will ensure that it meets the following criteria:
- Promptly accessible to the appropriate plant staff giving appropriate consideration to various drain down scenarios,
- Outside of the area surrounding the SFP floor, e.g., an appropriate distance from the radiological sources resulting from an event impacting the SFP,
- Inside a structure providing protection against adverse weather, and
- Outside of any very high radiation areas or LOCKED HIGH RAD AREA during normal operation.
Please provide the following:
a) A justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.
b) The reasons justifying why the locations selected enable the information from these instruments to be considered promptly accessible to various drain-down scenarios and external events.
4.0 PROGRAM FEATURES
RAI-9
4.2 Procedures The OIP states, in part, that Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation, and abnormal response issues associated with the new SFP instrumentation.
Procedures will address a strategy to ensure SFP water level addition is initiated at an appropriate time consistent with implementation of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.
Please provide a description of the standards, guidelines and/or criteria that will be utilized to develop procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments.
RAI-10
4.3 Testing and Calibration The OIP states, in part, that Processes will be established and maintained for scheduling and implementing necessary testing and calibration of the primary and backup spent fuel pool level instrument channels to maintain the instrument channels at the design accuracy.
Testing and calibration of the instrumentation will be consistent with vendor recommendations and any other documented basis. Calibration will be specific to the mounted instrument and the monitor.
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) A description of how the guidance in NEI 12-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.