HNP-13-085, Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13225A494
Person / Time
Site:	Harris
Issue date:	08/12/2013
From:	Kapopoulos E Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, HNP-13-085
Download: ML13225A494 (11)

Text

Ernest J. Kapopoulos, Jr.

Vice President

ENERGY, Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2000 10 CFR 50.4 August 12, 2013 Serial: HNP-13-085 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400

Subject:

Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. Letter from Benjamin Waldrep to the U.S. Nuclear Regulatory Commission (Serial:

RA-1 3-002), Carolina Power & Light Company's Overall Integrated Plans in Response to March 12, 2012, Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-05 1), dated February 28, 2013, ADAMS Accession Number ML13086A096

2. NRC Letter from E. J. Leeds to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, Issuance of Order to Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012, ADAMS Accession Number ML12054A679

3. 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, Adams Accession Number ML12240A307

4. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ADAMS Accession Number ML12221A339

5. NRC Letter from Araceli T. Billoch Col6n (USNRC) to Ernie Kapopoulos (Progress Energy Carolinas, Inc.), Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC No. MF0792), dated July 11, 2013, ADAMS Accession Number ML13189A225 Ladies and Gentlemen:

By letter dated February 28, 2013, (i.e., Reference 1), Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company, submitted an Overall Integrated Plan in response to the March 12, 2012, Commission Order modifying licenses with regard to requirements for reliable spent fuel pool instrumentation (i.e., Reference 2) for the Shearon Harris Nuclear Power Plant (SHNPP), Unit 1. Further, the staff endorsed NEI 12-02 (i.e., Reference 3), with exceptions, as documented in Interim Staff Guidance (i.e., Reference 4).

U.S. Nuclear Regulatory Commission Page 2 Serial HNP-13-085 On July 11, 2013, the NRC provided a request for additional information (RAI) (i.e., Reference 5) concerning the referenced Overall Integrated Plan. In addition, for any part of the information that is not available within the 30-day response period for the RAI, the NRC asked SHNPP to provide the date the information would be submitted. The response to the NRC request for additional information is enclosed.

This document contains no new regulatory commitments.

Please refer any questions regarding this submittal to Mr. David H. Corlett at (919) 362-3137.

I declare, under penalty of perjury, that the foregoing is true and correct.

Executed on August 12, 2013.

Sincerely, Ernest J. Kapopoulos, Jr.

Enclosure:

Response to Request for Additional Information cc:

Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Ms. A. T. Billoch Col6n, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II

Serial: HNP-13-085 Enclosure Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400 / Renewed License No. NPF-63 Response to Request for Additional Information Regarding Overall Integrated Plan Submitted in Response to the Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

U.S. Nuclear Regulatory Commission Page 1 of 8 Serial HNP-13-085 Enclosure By letter dated February 28, 2013, Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company, submitted an Overall Integrated Plan in response to the March 12, 2012, Commission Order modifying licenses with regard to requirements for reliable spent fuel pool (SFP) Instrumentation for the Shearon Harris Nuclear Power Plant (SHNPP), Unit 1.

Further, the staff endorsed NEI 12-02, with exceptions, as documented in Interim Staff Guidance.

On July 11, 2013, the NRC provided a request for additional information (RAI) concerning the referenced Overall Integrated Plan. In addition, for any part of the information that is not available within the 30-day response period for the RAI, the NRC asked SHNPP to provide the date the information would be submitted. Responses to the NRC questions are provided below.

NRC RAI-1 Provide the following:

a. For 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. 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 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.

c. A detailed description of the circumstances when the pools are separated with gates, and identify the maximum time duration for which pools A, B, or C will be monitored by only one pool level channel. Identify the compensatory measures that will be taken in the event that the single pool channel fails while the pools are separated by gates.

SHNPP Response to RAI-1 INSTRUMENT CHANNEL DESIGN OVERVIEW/ BACKGROUND The SHNPP new wide range SFP level instrumentation will consist of one permanently fixed instrument channel in each of the three interconnected SFPs. The spatially separated channels will be used to monitor the SFP water level over the continuous span from normal operating down to the level of the highest point of any fuel rack. Per NEI 12-02 guidance, none of these channels requires access to the SFP area during a Beyond Design Bases (BDB) event.

Each instrument channel will utilize through air (non-contact) wave radar technology, which has a wave guided pipe and receiving horn located in the SFP area. The wave guided pipe and receiving horn antenna contain no organic materials and are not susceptible to radiation induced degradation. There is no portion of the Through Air Radar level sensor that contacts the SFP water, nor is there any connection to the pool liner. The associated channel electronics will be remotely located, away from the SFP area. Each channel will have a back-up battery and shall provide main control room (MCR) level monitoring capability.

U.S. Nuclear Regulatory Commission Page 2 of 8 Serial HNP-13-085 Enclosure

a.

In accordance with NEI 12-02, SFP Level 1 is set at 282 feet elevation to assure that the pool suction line inlets are covered. This is based on the following:

The SFP cooling pump test report indicates that required net positive suction head (NPSHR) is 18 feet. The SFP cooling pump total discharge head calculation assumes that NPSHR is 19 feet. A NPSHR of 19 feet corresponds to 257.8 feet elevation.

The pool suction line inlets are located at 277.5 feet elevation for pool "A" and at 278.5 feet elevation for pools "B" and "C."

282 feet elevation corresponds to the current SFP Io-lo level alarm and provides margin above the pool suction line inlets and NPSHR.

The February 28, 2013, submittal1 identified SFP Level 1 as 284.5 feet elevation. Based on the above information SFP Level 1 is revised to 282 feet elevation.

b.

See sketch on the following page.

c.

The installation and removal of SFP gates are controlled by plant procedures. Site procedures specify:

After an activity that requires an SFP gate to be installed, the gate should be deflated and removed to comply with the site-specific SFP mitigation strategy of B.5.b.

SFP gates can be installed in various combinations for various reasons. (e.g., refueling operations, maintenance, decontamination activities) For example, Gates 1 and 2 are installed as a prerequisite to refueling operations. (See Figure 1 in the February 28, 2013, submittal1 for gate locations relative to active SFPs A, B, and C.)

Depending on the activity, various combinations of gates can be installed for as little as hours or up to several weeks. Before the requirements of EA-12-051 are fully implemented at SHNPP, procedural controls will be enacted to track gate installation to ensure that a single active SFP is not isolated from another active SFP for greater than 90-days.

Compensatory measures if an isolated active SFP's associated level channel fails comprise of:

Expedited repair/replacement of the failed instrument.

Removal of the gate(s) isolating the SFP from a functional level channel as soon as practicable.

Duke Energy letter, Carolina Power & Light Company's Overall Integrated Plans 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 February 28, 2013, (ADAMS Accession Number ML13086A096)

U.S. Nuclear Regulatory Commission Page 4 of 8 Serial HNP-13-085 Enclosure NRC RAI-2 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 locations/placement of the primary and backup SFP level sensors, and the proposed routing of the cables that will extend from the sensors toward the location of the local electronics cabinets and read-out/display devices in the main control room or alternate accessible location.

SHNPP Response to RAI-2 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-2 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-3 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.

SHNPP Response to RAI-3 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-3 for SHNPP in the August 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-4 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

U.S. Nuclear Regulatory Commission Page 5 of 8 Serial HNP-13-085 Enclosure loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

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

SHNPP Response to RAI-4 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-4 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-5 Provide the following:

a. A description of how the two channels of the proposed level measurement system in each pool 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 describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. 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.

SHNPP Response to RAI-5 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-5 for SHNPP in the August 2014, Six Month Status Report for the Implementation of Order EA-12-051.

NRC RAI-6 Provide the following:

a. A description of the electrical alternate current power sources and capacities for the primary and backup channels.

b. If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply), 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 mitigation strategies for BDB external events (Order EA-12-049).

U.S. Nuclear Regulatory Commission Page 6 of 8 Serial HNP-13-085 Enclosure SHNPP Response to RAI-6 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-6 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-7 Provide the following:

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

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

SHNPP Response to RAI-7 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-7 for SHNPP in the August 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-8 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 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.

U.S. Nuclear Regulatory Commission Page 7 of 8 Serial HNP-13-085 Enclosure SHNPP Response to RAI-8 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-8 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-9 Provide the following:

a. The specific location for the primary and backup instrument channel display.

b. Since both the primary and backup display locations are not in the main control room, please provide a description of the location for the primary and backup 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 will enable the information from these instruments to be considered "promptly accessible." Include consideration of various drain-down scenarios.

SHNPP Response to RAI-9 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-9 for SHNPP in the August 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

NRC RAI-10 Provide the following:

a. 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 SFP instrumentation in a manner that addresses the order requirements.

b. 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.

SHNPP Response to RAI-10 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-10 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-12-051.

U.S. Nuclear Regulatory Commission Page 8 of 8 Serial HNP-13-085 Enclosure NRC RAI-11 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 nonfunctioning channels will be addressed.

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

SHNPP Response to RAI-1 1 Information is not available within the 30-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-1 1 for SHNPP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.