ML13164A381
| ML13164A381 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/19/2013 |
| From: | Thomas Wengert Plant Licensing Branch III |
| To: | Weber L Indiana Michigan Power Co |
| Wengert T | |
| References | |
| EA-12-051, TAC MF0761, TAC MF0762 | |
| Download: ML13164A381 (12) | |
Text
Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 19, 2013 Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNITS 1 AND 2-REQUEST FOR ADDITIONAL INFORMATION ON THE OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-051 CONCERNING RELIABLE SPENT FUEL POOL INSTRUMENTATION (TAC NOS. MF0761 AND MF0762)
Dear Mr. Weber:
By letter dated February 27, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13071A323), Indiana Michigan Power Company (I&M, the licensee) submitted an Overall Integrated Plan in response to the Mar.ch 12, 2012, U.S. Nuclear Regulatory Commission (NRC), Order to modify licenses with regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051; ADAMS Accession No. ML12054A679) for the Do'nald C. Cook Nuclear Plant, Units 1 and 2. The NRC s~aff endorsed Nuclear Energy Institute 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 2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339).
The NRC staff has reviewed the licensee's February 27, 2013, response and determined that additional information is needed to complete the review, as described in the enclosure, request for additional information (RAI). The NRC staff had discussed the RAI in draft form with your staff on June 12, 2013. During that discussion, the NRC staff agreed to clarify certain draft questions and, subsequent to the conference call, requested a response date of July 12, 2013.
If any part of this information is not available by the July 12, 2013, response date for this RAI, please provide the date that this information will be submitted.
Please feel free to contact me if you need any 'further clarification of the questions in the enclosure.
Docket Nos. 50-315 and 50-316
Enclosure:
Request for Additional Information cc: Distribution via ListServ Sincerely,
~te~~
Thomas J. Wengert, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
REQUEST FOR ADDITIONAL INFORMATION OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-051. "RELIABLE SPENT FUEL POOL INSTRUMENTATION" INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-315AND 50-316
1.0 INTRODUCTION
By letter dated February 27, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13071A323), Indiana Michigan Power Company (I&M, the licensee) submitted an Overall Integrated Plan (OIP) in response to the March 12, 2012, U.S. Nuclear Regulatory Commission (NRC), Order to modify licenses with regard to Reliable Spent Fuel Pool (SFP) Instrumentation (Order No. EA-12-051; ADAMS Accession No. ML12054A679) for the Donald C. Cook Nuclear Plant (CNP), 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 Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339).
The NRC staff has reviewed the licensee's February 27, 2013, response and has determined that the following additional information is needed to complete its technical review. If any part of this information is not available by the July 12, 2013, ~esponse date for this request for additional information (RAI), please provide the date. that this information will be submitted.
2.0 LEVELS OF REQUIRED MONITORING The OIP states, in part, that:
- 1) Level adequate to support operation of the normal fuel pool cooling system Level 1: Normal spent fuel pool level is 645'-1-1/2". The CNP Spent Fuel Pool Instrumentation (SFPI) system will meet or exceed the Level1 monitoring requirements (a resolution of 1 foot) provided in NEI 12-02, Section 2.3, Figure 1.
- 2) Level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck-Level 2: 630'-3-1/2" is approximately 1 0'-0" above the highest point of the fuel racks. The CNP SFPI system will meet or exceed the Level 2 monitoring requirements (a resolution of 3.5 foot) provided in NEI 12-02, Section 2.3, Figure 1.
Enclosure
RAI-1 3) Level where fuel remains covered-Level 3: 620'-3-1/2" is the nominal level of the highest fuel rack.
Please provide the following:
(a) The specific functional reasons for identification of the elevation of Level 1. Specify how the identified elevation represents the HIGHER of the two points described in the NEI 12-02 guidance for this level.
(b) Provide 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.
(c) The OIP refers to drawings 12-3801, OP-12-5136, and DC-06033. Provide these drawings and, if they do not provide the necessary information requested in this RAI, please provide additional drawings.
3.0 INSTRUMENTATION DESIGN FEATURES 3.2 Arrangement The OIP states, in part, that:
RAI-2
SFP level sensors will be installed near the Northwest and Northeast corners of the SFP to maintain separation within the SFP area. These locations will provide reasonable protection against missiles. The primary and backup channels signal processors will be located in the Auxiliary Building in independent locations and installed with seismic supports. I&M has not determined the exact location for the level sensors at this time.
The design of the sensor and sensor support will allow the fuel handling machine to pass over it without interference. Cabling for the primary and backup channel instruments will be routed in separate raceways and seismically mount~d.
Cables from the sensors in the SFP area will be routed in dedicated rigid steel conduits and routed to minimize interference with fuel handling activities.
Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the inside dimensions, the planned locations/ placement of the primary and back-up level sensors, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
3.3 Mounting The OIP states, in part, that
RAI-3
Mounting of the primary and backup channel instruments 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 roof and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a drawing the portions of the level sensor that will serve as points of attachment for mechanical/mounting and 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.
3.4 Qualification The OIP states, in part, that:
Components of the instrument channels installed in the SFP area will be qualified for shock and vibration using one or more of the following methods:
- a. components are supplied by manufacturers using commercial quality programs with shock and vibration requirements included in the purchase specification at levels commensurate with portable hand~held device or transportation applications;
- b. 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
- c.
components are inherently resistant to shock and vibration loadings, such as cables.
RAI-4 Applicable components of the instrument channels are rated by the manufacturer (or otherwise tested) for seismic impact at levels commensurate with those of postulated design basis event conditions in the area of instrument channel component usage (with the exception of battery chargers and replaceable batteries). The following measures will be used to verify that the design and installation is adequate:
- a. Demonstration of seismic motion consistent with that of existing design basis loads at the installed location;
- b. Substantial history of operational reliability in environments with significant vibration, such as for portable hand-held devices or transportation applications. Such a vibration design envelope will be inclusive of the effects of seismic motion imparted to the components proposed at the location of the installation;
- c. Adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7,8,9, and 10 of IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1 E Equipment for Nuclear Power Generating Stations, or a substantially similar industrial standard;
- d. Demonstration that proposed devices are substantially similar in design to models that have been previously tested for seismic effects in excess of the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges); or
- e. Seismic qualification using seismic motion consistent with that of existing design basis loading at the installation lo.cation.
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 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: (1) the level sensor mounted in the SFP area, and (2) 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.
3.5 Independence The OIP states, in part, that:
RAI-5
The primary instrument channel will be independent of the backup instrument channel.
The primary and backup instrument channel sensors will be located near separate
- corners of the SFP and the signal processors will be located in separate locations of the Auxiliary Building, placed to optimize access by personnel in normal, event, or post-event conditions. Cabling for the primary and backup instrument channels will be routed separately. The power sources for the primary and backup channels will be from separate 120VAC buses/switchgear.
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 practicable.
(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, independence of signals sent to the location(s) of the readout devices, and the.
independence of the displays.
3.6 Power Supplies The OIP states, in part, that:
\\ RAI-6 The primary and backup instrument channels will each be powered from independent 120V AC power sources and will have a dedicated battery backup.
A 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 to allow for power restoration from portable equipment.
Please provide the following:
(a) If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply), 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 mitigation strategies for BOB external events (Order EA-12-049).
(b) The location where the batteries will be located, indicating the accessibility, and the distance from the related instrument display.
- 3. 7 Accuracy The OIP states, in part, that:
RAI-7
The primary and backup instrument channels will be designed such that they will maintain their design accuracy without recalibration following a power interruption or change in power source.
The accuracy of the primary and backup instrument channels will be consistent with the guidelines of JLO-ISG-2012-03 and NEI12-02. 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 percent of span) under both: (1) normal SFP level conditions (approximately Level 1 or higher),
and (2) 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.
3.8 Testing The OIP states, in part, that:
Instrument channel design will provide for routine testing and calibration
. consistent with the guidelines of JLO-ISG-2012-03 and NEI 12-02 and provide for in situ testing.
RAI-8
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 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 the calibration and functional checks that will be performed, the frequency at which they will be conducted with a discussion on the measures taken to detect when the instrumentation is operable but degraded, and how these surveillances will be incorporated into the plant surveillance program.
(d) A description of the preventative maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to
- ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
3.9 Display The OIP states, in part, that:.
RAI-9
The primary and backup SFP level displays will be continuously provided at the associated signal processing units. The signal processing unit will be located to allow personnel access during normal, event, and post-event conditions and to facilitate display observation during normal operation and during implementation of post-event FLEX strategies.
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 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 4.2 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 level instrumentation.
Procedures will address the following situations:
- i.
if, at the time of an event or thereafter until the unit is returned to normal service, an instrument channel ceases to function, its function will be recovered within a period of time consistent with the emergency conditions that may apply at the time; ii.
if, at the time of an event or thereafter until the unit is returned to normal service, an instrument channel component needs to be replaced, a commercially available component may be used even if it does not meet all of the qualifications to maintain the instrument channel functionality; and iii.
CNP will utilize 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.
RAI-10
Please provide the following:
A list of the operating (both normal and abnormal response) procedures, calibration/test procedures, maintenance procedures, and inspection procedures that will be developed for use of the spent fuel pool instrumentation in a manner that addresses the Order requirements.
Please include a brief description of the specific technical objectives to be achieved within each procedure. If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to. the storage location and provisions for installation of the portable components, when needed.'
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 SFP level instrument channels to maintain the instrument channels at the design accuracy. Testing and calibration of the instrumentation wil! be consistent with vendor recommendations or other documented basis. Calibration will be specific to the mounted instrument and the monitor.
RAI-11
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.
- RAI transmitted by memo OFFICE LPL3-1/PM LPL3-2/LA DSS/SBPB/BC LPL3-1/BC LPL3-1/PM NAME TWengert SRohrer GCasto*
RCarlson /SWa/1 for TWengert DATE 6/18/13 6/17/13 05/17/13 6/18/13 6/19/13