ML13226A534
| ML13226A534 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/29/2013 |
| From: | Thadani M Plant Licensing Branch 1 |
| To: | Forbes J Entergy Nuclear Operations |
| Thadani M | |
| References | |
| EA-12-051, TAC MF1076 | |
| Download: ML13226A534 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 August 29, 2013 Mr. Jeffrey Forbes Executive Vice President, Nuclear Operations and CNO Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 31995 Jackson, MS 39286*1995
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT* REQUEST FOR ADDITIONAL INFORMATION REGARDING OVERALL INTEGRATED PLAN FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER EA-12-051) (TAC NO. MF1076)
Dear Sir or Madam:
By letter dated February 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13063A267), Entergy Operations Inc. submitted an Overall Integrated Plan 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 Instrumentation (Order Number EA-12-051; ADAMS Accession No. ML12054A679) for the James A. FitzPatrick Nuclear Power Plant.
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 Spent Fuel Pool 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 submittal and identified additional information that is needed to complete the NRC staffs technical review. Please provide a response to the enclosed Request for Additional Information (RAI) by September 23, 2013. If any part of this information is not available by the September 23,2013, response date for this RAI, please provide the date this information will be submitted.
If you have any questions regarding this RAI, please contact me at (301) 415-1476, or email mohan.thadani@nrc.gov.
Sincerely, f)1Jcda1tC-~
Mohan C. Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
Request for Additional Information cc w/encls: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA-12-0S1, "RELIABLE SPENT FUEL POOL INSTRUMENTATION" ENTERGY OPERATIONS INC.
JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. SO-333
1.0 INTRODUCTION
By letter dated February 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13063A267), Entergy Nuclear Operations, Inc. submitted an Overall Integrated Plan (OIP) 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-12-0S1; ADAMS Accession No. ML 120S4A679) for James A. Fitzpatrick Nuclear Power Plant. The U.S. Nuclear Regulatory Commission (NRC) staff endorsed Nuclear Energy Institute (NEI) 12-02 "Industry Guidance for Compliance with NRC Order EA-12-0S1, to Modify Licenses with Regard to Reliable Spent Fuel Pool 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-12-0S1, Reliable Spent Fuel Pool 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 within the 30-day response period 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 1 is the level adequate to support operation of the normal fuel pool cooling system. It will be increased for instrument uncertainty and is the higher of the following two points:
- 1) The level at which reliable suction loss occurs due to uncovering the coolant inlet pipe or any weirs or vacuum breakers associated with suction loss. For JAF, this level, (1) is established based on the weir plate/siphon break elevation which is 368 feet 4-S/8 inches.
- 2) The level at which the normal fuel pool cooling pumps lose required Net Positive Suction Head (NPSH) assuming saturated conditions in the pool.
The trip of the SFP cooling pump is based on the level in the skimmer surge tank. This level will be below the level determined in (1) above.
Enclosure
- 2 The higher of the above points is point (1). Therefore, LEVEL 1 is elevation 368 feet 4-5/8 inches.
LEVEL 2: Level 2 is the level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck. Level 2 will be based on... the following:
10 feet +/- 1 foot above the highest point of any fuel rack seated in the spent fuel pool. The elevation associated with this level is 355 feet 10-3/8 inches +/-
1 foot (i.e., Level 3 + 10 feet).
Therefore, LEVEL 2 is elevation 355 feet 10-3/8 inches +/- 1 foot (i.e., 10 feet above Level 3).
LEVEL 3: The highest point of any fuel rack seated in the spent fuel pool is elevation 345 feet 10-3/8 inches. Therefore, Level 3 is elevation 345 feet 10-3/8 inches.
The SFP level instrument span will extend down to at least 3 inches below the upper limit of the range of LEVEL 3 to account for accuracy or instrument loop uncertainty. Therefore, the SFP level probe will extend down to at least elevation 346 feet 7-3/8 inches.
RAI-1
Please provide the following:
a) 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.
b) The OIP states, "Other hardware stored in the SFP will be evaluated to ensure that it does not adversely interact with the SFP instrument probes during a seismic event".
Given the potential for varied dose rates from other materials stored in the SFP, describe how level 2 will be adjusted to other than the elevation provided in section 2 above.
- 3 3.0 INSTRUMENTATION DESIGN FEATURES 3.2 Arrangement The alP states, in part, that Level instruments will be installed in the approximate locations shown on. Separation of the channels/probes reduces the potential for falling debris or missiles affecting both channels of instrumentation. This placement coupled with separate routing paths for cables and use of rigid conduit provides reasonable protection against falling debris and structural damage.
RAI-2
Please modify the marked-up plant drawing in Attachment 1 of the plan view of the spent fuel pool area, to clearly depict the spent fuel pool inside dimensions, the approximate separation in feet of the planned locations/placement of the primary and back-up spent fuel pool 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.
3.3 Mounting The OIP states, in part, that Both the primary and backup system will be installed as Category I to meet the NRC JLD-ISG-2012-03 and NEI 12-02 guidance requirements.
Other hardware stored in the SFP will be evaluated to ensure that it does not adversely interact with the SFP instrument probes during a seismic event.
RAI-3
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.
-4 c) A description of the manner by which the mechanical connections will attach the level instrument to permanent spent fuel pool structures so as to support the level sensor assembly.
d) Please describe how other material stored in the SFP will not create adverse interaction with the fixed instrument location(s).
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 will be supplied by manufacturers that implement commercial quality programs (such as IS09001, Quality Management Systems Requirements) with shock and vibration requirements included in the purchase specification at levels commensurate with portable hand-held devices or transportation applications; Components have a 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.
For seismic effects on instrument channel components used after a potential seismic event for only installed components (with the exception of replaceable batteries and chargers), the following measures will be used to verify that the design and installation is adequate:
Components will be rated by the manufacturer (or otherwise tested) for seismic effects at levels commensurate with those of postulated design basis event conditions in the area of instrument channel component use using one or more of the following methods.
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.
- 5 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 spent fuel pool 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.
3.5 Independence The OIP states, in part, that The primary instrument channel will be independent of the backup instrument channel. Independence is obtained by physical separation of components between channels and the use of normal power supplied from separate 600V buses. Independence of power sources is described in Section 11. The two (2) permanently mounted instruments in the pool will be physically separated as described in Sections 6 and 7.
RAI-5
Please 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) Additional information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout 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.
3.6 Power Supplies The OIP states, in part, that The power supplies for the instrument channels are shown on Attachment 2 and arranged as follows:
- Each instrument channel will be normally powered from a 120VAC 60 Hz plant distribution panel to support continuous monitoring of SFP level. The distribution panel for the primary channel receives power from a different 600V bus than the distribution panel for the backup channel. Therefore, loss
- 6 of anyone 600V bus does not result in loss of normal 120VAC power for both instrument channels.
- On loss of normal 120VAC power, each channel's UPS automatically transfers to a dedicated backup battery. If normal power is restored, the channel will automatically transfers back to the normal AC power.
- The backup batteries will be maintained in a charged state by commercial grade uninterruptible power supplies. The batteries will be sized to be capable of supporting intermittent monitoring for a minimum of 3 days of operation. This provides adequate time to allow the batteries to be replaced or until oft-site resources can be deployed by the mitigating strategies resulting from Order EA-12-049 Revision O.
- An external connection permits powering the system from any portable OC source.
RAI-6
Please provide the following:
a) Additional description of the 600 VAC bus configuration providing the normal electrical AC power source and capacities for the primary and backup channels.
Please confirm that these sources are independent sources and confirm that they may be independently re-powered following a loss of AC power event per the plant mitigation strategies for BOB external events (Order EA 12-049).
b) 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).
c) Please describe what is meant by "An external connection permits powering the system from any portable OC source.>> What are the voltages of OC power that may be used to power the equipment, and what provisions (staging, resources, training, etc.) will be made to bring such external power sources to the equipment?
3.7 Accuracy The OIP states, in part, that Accuracy will be consistent with the guidelines of NRC JLO-ISG-2012-03 Revision 0 and NEI 12-02 Revision 1. Accuracy and indication features are as follows:
- Accuracy: The absolute system accuracy will be better than +/- 3 inches. This accuracy is applicable for normal conditions and the temperature, humidity, chemistry, and radiation levels expected for BOBE event conditions.
- 7 Restoration after Loss of Power: The system automatically swaps to available power (backup battery power or external DC source) when normal power is lost. Neither the source of power nor system restoration impact accuracy.
RAI-7
Please provide the following:
a) An estimate of the expected instrument channel accuracy performance (e.g., in percent of span) under both a) normal spent fuel pool 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 design accuracy.
3.8 Testing The OIP states, in part, that Testing and calibration will be consistent with the guidelines of NRC JLD-ISG 2012-03 Revision 0 and NEI 12-02 Revision 1 and vendor recommendations.
Station procedures and preventive maintenance tasks will be developed to perform required surveillance testing, calibration, backup battery maintenance, functional checks, and visual inspections of the probes.
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 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 spent fuel pool 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.
- 8 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.
3.9 Display The alP states, in part, that The primary and backup instrument displays will be located in the relay room located in the Control Building as shown on Attachments 1 and 2.
RAI-9
Please provide the following:
a) 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 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 will enable the information from these instruments to be considered "promptly accessible." Include consideration of various drain-down scenarios.
4.0 PROGRAM FEATURES 4.2 Procedures The alP states, in part, that Procedures for maintenance and testing will be developed using regulatory guidelines and vendor instructions.
BDBE event operation guidance will also address the following:
- A strategy to ensure SFP water addition is initiated at an appropriate time consistent with implementation of NEI 12-06 Revision 1.
Restoration of non-functioning SFP level channels after an event.
Restoration timing will be consistent with the emergency condition. After an event, commercially available components that may not meet all qualifications may be used to replace components to restore functionality.
- 9
RAI-10
Please 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 spent fuel pool 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.
4.3 Testing and Calibration The OIP states, in part, that Testing and calibration will be consistent with the guidelines of NRC JLO-ISG-2012-03 Revision 0 and NEI 12-02 Revision 1 and vendor recommendations.
Station procedures and preventive maintenance tasks will be developed to perform required surveillance testing, calibration, backup battery maintenance, functional checks, and visual inspections of the probes.
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 the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.
ML12054A679) for the James A. FitzPatrick Nuclear Power Plant.
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 Spent Fuel Pool 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 submittal and identified additional information that is needed to complete the NRC staff's technical review. Please provide a response to the enclosed Request for Additional Information (RAI) by September 23,2013. If any part of this information is not available by the September 23, 2013, response date for this RAI, please provide the date this information will be submitted.
If you have any questions regarding this RAI, please contact me at (301) 415-1476, or email mohan. thadani@nrc.gov.
Sincerely, lraJ Mohan C. Thadani, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
Request for Additional Information cc w/encls: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL1-1 Reading RidsAcrsAcnw MailCTR RidsNrrDorlLpl1-1 RidsNrrDssSbpb Resource RidsNrrDeEicb Resource RidsNrrLAKGoldstein Resource SWyman RidsNrrPMFitzPatrick Resource RidsRgn1-MailCenter Resource CRogue-Cruz RidsNrrDssSbpr Resource RidsNrrDeEicb Resource ADAMS Accession No.: ML13226A534
(*) see Memo M L 13220A390 OFFICE LPL1-1/PM LPL1-1/LA NRRISBPB/BC(*)
LPL1-1/BC {A)
LPL1-1/PM NAME MThadan KGoldstein GCasto RBeali ror"L I.L.
MThadani DATE 8/19/13 8/19/13 8/9113 8/29/13 8/29/13