ML13157A097
| ML13157A097 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, McGuire  |
| Issue date: | 06/13/2013 |
| From: | James Kim Plant Licensing Branch II |
| To: | Capps S Duke Energy Carolinas |
| Kim J NRR/DORL/LPL2-1 | |
| References | |
| EA-12-051, TAC MF1062, TAC MF1063 | |
| Download: ML13157A097 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 13, 2013 Mr. Steven D. Capps Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-051, "RELIABLE SPENT FUEL POOL INSTRUMENTATION" (TAC NOS. MF1062 AND MF1063)
Dear Mr. Capps:
By letter dated February 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13086A095), Duke Energy submitted an Overall Integrated Plan (OIP) in response to the March 12,2012, U.S. Nuclear Regulatory Commission (NRC, Commission) Order modifying licenses with regard to requirements for Reliable Spent Fuel Pool (SFP) Instrumentation (Order Number EA-12-051) for McGuire Nuclear Station, Units 1 and 2.
The NRC staff endorsed Nuclear Energy Institute (NEI) 12-02, "Industry Guidance for Compliance with U.S. Nuclear Regulatory Commission (NRC) Order EA-12-051, to Modify Licenses with Regard to Reliable SFP Instrumentation," Revision 1, dated August 2012, 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.
The NRC staff has determined that the additional information, as requested in the enclosure, is needed to complete its review. Please provide a response to the questions within 30 days of the date of this letter. If any part of this information is not available within 30 days of this request, please provide the date that this information will be provided.
S. Capps -2 If you have any questions regarding this request, please contact me at 301-415-4125 or via e-mail at James.Kim@nrc.gov.
Sincerely, Ie-James Kim, Project Manager Plant Licensing Branch II Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-051, "RELIABLE SPENT FUEL POOL INSTRUMENTATION" DUKE ENERGY MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370 1.0 Introduction By letter dated February 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13086A095), Duke Energy submitted an Overall Integrated Plan (OIP) in response to the March 12, 2012, U.S. Nuclear Regulatory Commission (NRC),
Commission Order modifying licenses with regard to requirements for Reliable Spent Fuel Pool (SFP) Instrumentation (Order Number EA-12-051; ADAMS Accession No. ML12054A679) for McGuire Nuclear Station, Units 1 and 2. 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 February 28, 2013, response by the licensee and determined that the following Request for Additional Information (RAI) is needed to complete its Technical Review. If any part of this information is not available by the July 5, 2013, response date for this RAI, please provide the date this information will be submitted.
2.0 Levels of Required Monitoring The 01 P states, in part, that
- Level 1 - Level adequate to support operation of the normal fuel pool cooling system. The minimum required level to provide adequate pump suction (769' Elevation).
- Level 2 - Level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck 756' (10 +/-01 feet above the top of the highest point of any fuel rack seated in the SFP). This level provides SUbstantial personnel radiation shielding that would allow implementation of local SFP make-up strategies for a beyond deSign bases event.
- Level 3 - Level where fuel remains covered and actions to implement makeup water addition should no longer be deferred (approximately 746' +/-1 foot Enclosure
- 2 the highest point of any fuel rack seated in the SFP).
RAI-1
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.
b) The OIP states: "If applicable, adjacent hardware stored in the SFP will be evaluated to ensure it cannot adversely interact with SFP level instrumentation." Given the potential for varied dose rates from adjacent hardware stored in the SFP, describe how level 2 will be adjusted to other than the elevation provided in Section 2 above.
c) 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 3.1 Arrangement The OlP states, in part, that In accordance with the guidance in NEI 12-02, the level instruments/channels will be installed in diverse locations and physically arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.
The associated cabling, power supplies and indication each level instrument/channel will be routed separately from each other. Cable routings will be specified to provide reasonable protection from missiles that may result from damage to the structure over the SFP and refuel floor, as applicable. The conduit and cable routing will be determined by the detailed design.
RAI-2
Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locationsl placement of the primary and back-up SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
- 3 3.2 Mounting The OIP states, in part, that Permanently installed instruments will be mounted to retain the component design configuration during and following the maximum seismic ground motion considered in the design SFP structure or applicable structure in which the component is located.
If applicable, adjacent hardware stored in the SFP will be evaluated to ensure it cannot adversely interact with SFP level instrumentation.
RAI-3
Please provide the following:
a) A clearly labeled sketch or marked-up plant drawing of the plan view of the SFP 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 the sensors toward the location of the read-out/display device.
b) Address how adjacent hardware stored in the SFP will not create adverse interaction with the fixed instrument location(s).
3.3 Qualification The 01 P states, in part, that The level instrumentation shall remain functional and maintain required accuracy capability after a Safe shutdown Earthquake, and!or after exposure to any applicable harsh environmental conditions for the equipment location. The level instrumentation and associated cabling will be specified to be reliable at the maximum temperature, humidity, and radiation levels predicted during an extended loss of AC power (ELAP) event at their installed locations.
The instrumentation reliability will be demonstrated by appropriate combination of design, analyses, operating experience, and!or testing as outlined by NEI 12-02.
RAI-4
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
- 4 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) 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.
3.4 Independence The OIP states, in part, that The level instruments and any associated cabling (for each Unit SFP) will be physically separated and electrically independent of one another.
RAI-S 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.
3.S Power Supplies The OIP states, in part, that Power supplies (if required) for each SFP instrument/channel shall be electrically separate. If powered, the level instrumentation shall have provisions for emergency back-up power source such as batteries, which are rechargeable or replaceable. The back-up power source(s) must have sufficient capacity to maintain the level indication function until offsite power or other offsite emergency resources provided by FLEX procedures becomes available, consistent with the guidance of NEI 12-02.
- 5 RAI-S If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), 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 BOB event for the minimum duration needed, consistent with the plant FLEX Program plans.
Include the duration needed to power the SFP Instrument channel until the FLEX mitigation strategy is in place.
3.S Accuracy The OIP states, in part, that a) The new SFP level instrumentation will be designed to maintain their design accuracy without recalibration following a power interruption or change in power source.
b) Accuracy will consider SFP post-event conditions, e.g., saturated water, steam environment, or concentrated borated water, or applicable limiting environmental conditions for the installed location.
c) Instrument accuracy will be suitable to allow trained personnel to determine when the actual level exceeds the specified lower level of each indicating range (critical levels 1, 2, 3 as identified by NEI 12-02 guidance) without conflicting or ambiguous indication.
RAI-7
Please provide the following:
a) An estimate of the expected instrument channel accuracy performance under both a) normal SFP level conditions (approximately Level 1 or higher) and b) at the BDB conditions (Le., 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 desjgn accuracy.
- 6 3.7 Testing DIP states, in part, that The instrument channel design shall provide for routine testing and calibration.
Testing will be consistent with the guidelines of NRC JLD-ISG-2012-03 and NEI 12-02.
RAI-S 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 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.
3.S Display The DIP states, in part, that The instrument displays for each SFP level instrument will be provided in the main control room or other accessible location. The displays will be consistent with the guidelines of NRC JLDISG-2012-03 and NEI12-02.
RAI-9
Please provide the following:
a) The specific location for the primary and backup instrument channel display.
b) If the primary or backup display location is other than the main control room, then provide 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
-7 decision makers for the various SFP drain down scenarios and external events.
c) 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 4.1 Procedures The OIP states, in part, that Station procedures will be developed using guidelines and vendor instructions to address the maintenance, operation and abnormal response issues associated with the SFP level instrumentation.
Procedures will be developed to address strategy to ensure SFP water addition is initiated at an appropriate time consistent with implementation of NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.
RAI-10
Please provide a description of the standards, guidelines and/or criteria that will be used 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.
4.2 Testing and Calibration The OIP states, in part, that Testing and calibration of the instrumentation will be consistent with vendor recommendations or other documented basis. Calibration will be specific to the mounted instrument(s) and the display(s).
Station procedures and preventive maintenance will be developed to perform required instrumentation maintenance, testing, periodic calibrations, and/or functional checks.
Existing station work control processes will be utilized to control maintenance and testing.
RAI-11
Please provide the following:
a) Further information describing the maintenance and testing program the licensee will
- 8 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 NE112-02 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.
S. Capps -2 If you have any questions regarding this request, please contact me at 301-4154125 or via e-mail at James.Kim@nrc.gov.
Sincerely, IRA!
James Kim, Project Manager Plant Licensing Branch II Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
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- memo d aet d May 30 , 2013 OFFICE DORLlLPL2-1/PM DORLlLPL2-1/LA DSS/SBPB/BC DORULPL2-'I/BC DORLlLPL2-1/PM NAME JKim SFigueroa GCasto* RPascarelii JKim DATE 06/12/13 06/10/13 05/30/13 06/13/13 06/13/13 OFFICIAL RECORD COPY