ML13281A648

Interim Staff Evaluation and Request for Additional Information (RAI) - Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13281A648
Person / Time
Site:	North Anna
Issue date:	11/01/2013
From:	V Sreenivas Plant Licensing Branch II
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Sreenivas V, NRR/DORL 415-2597
References
EA-12-051, TAC MF0986, TAC MF0987
Download: ML13281A648 (30)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 1, 2013 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2: INTERIM STAFF EVALUATION AND REQUEST FOR ADDITIONAL INFORMATION REGARDING THE OVERALL INTEGRATED PLAN FOR IMPLEMENTATION OF ORDER EA-12-051, RELIABLE SPENT FUEL POOL INSTRUMENTATION (TAC NOS. MF0986, MF0987)

Dear Mr. Heacock:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-051 ,

"Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A679), to all power reactor licensees and holders of construction permits in active or deferred status. This order requires the licensee to have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A017), Virginia Electric and Power Company (the licensee) provided the Overall Integrated Plan (OIP) for North Anna Power Station, Units 1 and 2, describing how it will achieve compliance with Attachment 2 of Order EA-12-051 by fall 2014. By letter dated May 28,2013 (ADAMS Accession No. ML13177A194),

the NRC staff sent a request for additional information (RAI) to the licensee. The licensee provided supplemental information by letters dated July 2, 2013 (ADAMS Accession No. ML13190A310), and August 23,2013 (ADAMS Accession No. ML13242A015).

The NRC staff has reviewed these submittals with the understanding that the licensee will update its OIP as implementation of the Order progresses. With this in mind, the staff has included an interim staff evaluation with this letter to provide feedback on the OIP. The staff's findings in the interim staff evaluation are considered preliminary and will be revised as the OIP is updated. As such, none of the staff's conclusions are to be considered final. A final NRC staff evaluation will be issued after the licensee has provided the information requested.

The interim staff evaluation also includes RAls, response to which the NRC staff needs to complete its review. The licensee should provide the information requested in the 6-month status updates, as the information becomes available. However, the staff requests that all information be provided by March 3, 2014, to ensure that any issues are resolved prior to the date by which the licensee must complete full implementation of Order EA-12-051. The

D. Heacock -2 licensee should adjust its schedule for providing information to ensure that all this information is provided by the requested date.

If you have any questions regarding this letter, please contact me at 301-415-2597 or via e-mail at v.sreenivas@nrc.gov.

Sincerely, V. Sreenivas, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

Interim Staff Evaluation and Request for Additional Information cc w/encl: Distribution via Listserv

INTERIM STAFF EVALUATION AND REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE OVERALL INTEGRATED PLAN IN RESPONSE TO ORDER EA 12 051, RELIABLE SPENT FUEL POOL INSTRUMENTATION VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339

1.0 INTRODUCTION

On March 12,2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-0S1, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 120S4A679), to all power reactor licensees and holders of construction permits in active or deferred status. This Order requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range Spent Fuel Pool (SFP) levels to support effective prioritization of event mitigation and recovery actions in the event of a Beyond-Design-Basis (BDB) external event. The Order required all holders of operating licenses issued under Title 10 of the Code of Federal Regulations (10 CFR) Part SO, "Domestic Licensing of Production and Utilization Facilities," to submit to the NRC an Overall Integrated Plan (OIP) by February 28, 2013.

By letter dated February 28,2013 (ADAMS Accession No. ML13063A017), Virginia Electric and Power Company (Dominion or the licensee) provided the OIP for North Anna Power Station (NAPS), Units 1 and 2, describing how it will achieve compliance with Attachment 2 of Order EA-12-0S1 by Fall 2014. By letter dated May 28,2013 (ADAMS Accession No. ML13177A194),

the NRC staff sent a Request for Additional Information (RAI) to the licensee. The licensee provided supplemental information by letters dated July 2, 2013 (ADAMS Accession No. ML13190A310), and August 23, 2013 (ADAMS Accession No. ML13242A015).

2.0 REGULATORY EVALUATION

Order EA-12-0S1 requires all holders of operating licenses issued under 10 CFR Part SO, notwithstanding the provisions of any Commission regulation or license to the contrary, to comply with the requirements described in Attachment 2 to the Order except to the extent that a more stringent requirement is set forth in the license. Licensees shall promptly start implementation of the requirements in Attachment 2 to the Order and shall complete full implementation no later than two refueling cycles after submittal of the OIP or December 31, 2016, whichever comes first.

Enclosure

-2 Order EA-12-051 required the licensee, by February 28,2013, to submit to the Commission an OIP, including a description of how compliance with the requirements described in Attachment 2 of the Order will be achieved. of Order EA-12-051 requires the license to have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred. of Order EA-12-051 , states that the SFP level instrumentation shall include the following design features:

1.1 Instruments

The instrumentation shall consist of a permanent, fixed primary instrument channel and a backup instrument channel. The backup instrument channel may be fixed or portable. Portable instruments shall have capabilities that enhance the ability of trained personnel to monitor spent fuel pool water level under conditions that restrict direct personnel access to the pool, such as partial structural damage, high radiation levels, or heat and humidity from a boiling pool.

1.2 Arrangement

The spent fuel pool level instrument channels shall be 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 spent fuel pool. This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure.

1.3 Mounting

Installed instrument channel equipment within the spent fuel pool shall be mounted to retain its design configuration during and following the maximum seismic ground motion considered in the design of the spent fuel pool structure.

1.4 Qualification

The primary and backup instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for an extended period.

This reliability shall be established through use of an augmented quality assurance process (e.g., a process similar to that applied to the site fire protection program).

1.5 Independence

The primary instrument channel shall be independent of the backup instrument channel.

-3 1.6 Power supplies: Permanently installed instrumentation channels shall each be powered by a separate power supply. Permanently installed and portable instrumentation channels shall provide for power connections from sources independent of the plant [alternating current (ac)] and [direct current (dc)] power distribution systems, such as portable generators or replaceable batteries. Onsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.

1.7 Accuracy

The instrument channels shall maintain their designed accuracy following a power interruption or change in power source without recalibration.

1.8 Testing

The instrument channel design shall provide for routine testing and calibration.

1.9 Display

Trained personnel shall be able to monitor the spent fuel pool water level from the control room, alternate shutdown panel, or other appropriate and accessible location. The display shall provide on demand or continuous indication of spent fuel pool water level. of Order EA-12-051 , states that the SFP instrumentation shall be maintained available and reliable through appropriate development and implementation of the following programs:

2.1 Training

Personnel shall be trained in the use and the provision of alternate power to the primary and backup instrument channels.

2.2 Procedures

Procedures shall be established and maintained for the testing, calibration, and use of the primary and backup spent fuel pool instrument channels.

2.3 Testing and Calibration: Processes shall 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.

On August 29,2012, the NRC issued an Interim Staff Guidance document (the ISG),

..ILD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. ML12221A339), to describe methods acceptable to the NRC staff for complying with Order EA-12-051. The ISG endorses, with exceptions and clarifications, the methods described in the Nuclear Energy Institute (NEI) guidance document NEI12-02, Revision 1, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" dated August 2012 (ADAMS Accession No. ML12240A307). Specifically, the ISG states:

The NRC staff considers that the methodologies and guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, subject to the clarifications

- 4 and exceptions in Attachment 1 to this ISG, are an acceptable means of meeting the requirements of Order EA-12-051.

3.0 TECHNICAL EVALUATION

3.1 Background and Schedule North Anna Power Station (NAPS), Units 1 and 2, share a common SFP.

The licensee submitted its OIP on February 28, 2013. The OIP states that installation of the SFP level instrumentation at NAPS, Units 1 and 2, will be completed by fall 2014 based on the end of the second refueling outage following submittal of this integrated plan.

The NRC staff has reviewed the licensee's schedule for implementation of SFP level instrumentation provided in its alP. If the licensee completes implementation in accordance with this schedule, it would appear to achieve compliance with Order EA-12-051 within two refueling cycles after submittal of the alP and before December 31,2016.

3.2 Spent Fuel Pool Water Levels of Order EA-12-051 states, in part, that All licensees identified in Attachment 1 to this Order shall have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system [Level 1], (2) level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck [Level 2],

and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred [Level 3].

NEI 12-02 states, in part, that Level 1 represents the HIGHER of the following two points:

• The level at which reliable suction loss occurs due to uncovering of the coolant inlet pipe, weir or vacuum breaker (depending on the design), or

• The level at which the water height, assuming saturated conditions, above the centerline of the cooling pump suction provides the required net positive suction head speci'fied by the pump manufacturer or engineering analysis.

In the alP, the licensee stated that Level 1 is the indicated level on either the primary or back up instrument channel of greater than approximate elevation 286 feet (f1.) 7 inches (in.), based on the elevation at which the top of the SFP cooling pump suction lines penetrate the pool walls.

- 5 In its letter dated, July 2,2013, the licensee stated, in part, that The level at which the required I\JPSH is lost, assurning a saturated condition in the pool, is approximately 292 feet. This level is slightly above the top of the pool walls. The distance from the normal pool water level to the purnp suction centerline is approximately 39 feet. (Refer to the SFP elevation diagram in the response to item b below.) The head loss from the SFP coolant intake to the pump suction is approximately 19 feet at a flow rate of 2700 gpm. Therefore, for a saturated pool with normal water level, the available net positive suction head is approximately 20 feet. The manufacturer's required NPSH is 22 feet.

Consequently, the level required to provide adequate NPSH with a saturated pool and normal flow is approximately 2 feet above the nominal water level, which is slightly above the top of the SFP walls.

In its letter dated, August 23, 2013, the licensee stated that the formal calculation performed to verify that adequate water level is available to support Net Positive Suction Head (NPSH) had been completed and independently reviewed. The licensee also stated that results of the calculation confirmed that the Level 1 value of 286.6 ft. specified in the RAI response is HIGHER than the minimum NPSH value of 284.4 ft.

The NRC staff notes that there is a slight variation with the licensee's identified Level 1. In its OIP, the licensee stated that Level 1 was the indicated level on either the primary or back-up instrument channel of greater than approximate elevation 286 ft. 7 in., and in its letter dated August 23, 2013, the licensee identified Level 1 at an elevation of 286.6 ft. The staff has concerns with the licensee's lack of consistency with regards to the identified Level 1. The staff has identified this request as:

RAI #1 Please specify which of the two identified values is the correct elevation for Level 1.

NEI 12-02 states, in part, that Level 2 represents the range of water level where any necessary operations in the vicinity of the spent fuel pool can be completed without significant dose consequences from direct gamma radiation from the stored spent fuel. Level 2 is based on either of the following:

• 10 feet (+/- 1 foot) above the highest point of any fuel rack seated in the spent fuel pools, or

• a designated level that provides adequate radiation shielding to maintain personnel radiological dose levels within acceptable limits while performing local operations in the vicinity of the pool. This level shall be based on either plant-specific or appropriate generic shielding calculations, considering the emergency conditions that may apply at the time and the scope of necessary local operations, including installation of portable SFP instrument channel components.

-6 In its OIP, the licensee stated that Level 2 is the indicated level on either the primary or back-up instrument channel of greater than approximate elevation 274 ft. 2 in., which corresponds to approximately 10ft. above the top of the SFP fuel storage rack.

In its letter dated July 2, 2013, the licensee provided a sketch showing the approximate location of the elevations identified as Levels 1,2 and 3, the top of the tallest fuel storage rack and SFP instrumentation span. The NRC staff notes that Level 2 at an elevation of 274ft. 2 in. is approximately 10ft. above the top of the fuel rack. The staff also notes that the licensee designated Level 2 using the first of the two options described in NEI 12-02 for Level 2.

NEI 12-02 states, in part, that Level 3 corresponds nominally (Le., +/- 1 foot) to the highest point of any fuel rack seated in the spent fuel pool. Level 3 is defined in this manner to provide the maximum range of information to operators, decision makers and emergency response personnel.

In its OIP, the licensee stated that Level 3 is the indicated level on either the primary or back-up instrument channel of greater than approximate elevation 264 ft. 2 in.

In its letter dated July 2, 2013, the licensee provided a sketch showing the approximate location of the elevations identi'fied as Levels 1, 2 and 3, the top of the tallest fuel storage rack and SFP instrumentation span. The NRC staff notes that Level 3 at an elevation of 264 ft. 2 in. is above the highest point of any spent fuel storage rack seated in the SFP.

The licensee's proposed plan, with respect to identification of Levels 2 and 3, appears to be consistent with NEI 12-02, as endorsed by the ISG.

3.3 Design Features: Instruments of Order EA-12-0S1, states, in part, that The instrumentation shall consist of a permanent, fixed primary instrument channel and a backup instrument channel. The backup instrument channel may be fixed or portable. Portable instruments shall have capabilities that enhance the ability of trained personnel to monitor spent fuel pool water level under conditions that restrict direct personnel access to the pool, such as partial structural damage, high radiation levels, or heat and humidity from a boiling pool.

NEI 12-02 states, in part, that A spent fuel pool level instrument channel is considered reliable when the instrument channel satisfies the design elements listed in Section 3

[Instrumentation Design Features] of this guidance and the plant operator has fully implemented the programmatic features listed in Section 4 [Program Features].

-7 In its OIP, the licensee stated that the primary and back-up channels will use a fixed instrument providing continuous level measurement over the entire range. The measured range will be from approximately elevation 290 ft. 4 in. to elevation 264 ft. 2 in., for a total indicated range of approximately 26 ft. 2 in. (314 in.).

The NRC staff notes that the range specified for the licensee's instrumentation will cover Levels 1,2, and 3 as described in Section 3.2 above. The licensee's proposed plan, with respect to the number of channels and the range of the instrumentation for its SFP, appears to be consistent with NEI12-02, as endorsed by the ISG.

3.4 Design Features: Arrangement of Order EA-12-0S1 , states, in part, that The spent fuel pool level instrument channels shall be 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 sPlnt fuel pool. This protection may be provided by locating the primary instrument channel and the fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure.

NEI 12-02 states, in part, that The intent of the arrangement requirement is to specify reasonable separation and rnissile protection requirements for permanently installed instrumentation used to meet this order. Although additional missile barriers are not required to be installed, separation and shielding can help minimize the probability that damage due to an explosion or extreme natural phenomena (e.g., falling or wind driven missiles) will render fixed channels of SFP instrumentation unavailable.

Installation of the SFP instrument channels shall be consistent with the plant specific SFP design requirements and should not impair normal SFP function.

Channel separation should be maintained by locating the installed sensors in different places in the SFP area.

In its OIP, the licensee stated that the primary instrument channel level sensing components will be located on the east wall of the SFP and the back-up instrument channel level sensing cornponents will be located in the southwest corner of the SFP.

Additionally, in its OIP, the licensee stated, in part, that The primary and back-up channel level sensor probes will be installed on opposite sides of the SFP to maintain adequate channel separation. In the conceptual design, the SFP probes bolt to a triangular mounting plate for installation at the corner of the SFP or a rectangular plate for mounting at the side of the SFP ... Existing barriers and physical separation will be used to provide a level of protection for the sensor and interconnecting cable. These

-8 physical barriers will protect the instrument sensors and cables from potential missiles generated by an event. The final sensor mounting design and cable routing will maintain a low profile to ensure that there is no interference with the existing fuel handling equipment. Specific details will be developed during the detailed design phase.

Vendor electronics will be located in a mild environment of the Auxiliary Building providing adequate protection from temperature, humidity, and radiation. Level indicators will be located in the Cable Spreading Room.

Cables associated with a channel's sensor, power supply and indicator will be independently routed in separate raceways from cables associated with the other channel.

In its letter dated July 2, 2013, the licensee stated, in part, that The final locations for the level sensor, electronics and display units have not been determined. The final system component locations will be available upon completion of the final design, scheduled for December 2013, and will be forwarded to the NRC during the subsequent scheduled status update.

The NRC staff notes that in its letter dated July 2,2013, the licensee stated that the final system cornponent locations will be available upon completion of the final design, scheduled to be completed by December 2013. The licensee indicated that the information will be forwarded to the staff in the February 2014 six month status update. The staff has identified this request as:

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 locations/placement of the primary and back-up SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-ouVdisplay device.

(This information was previously requested as RAI-2 in the NRC letter dated May 28,2013) 3.5 Design Features: Mounting of Order EA-12-051 states, in part, that Installed instrument channel equipment within the spent fuel pool shall be mounted to retain its design configuration during and following the maximum seismic ground motion considered in the design of the spent fuel pool structure.

NEI 12-02 states, in part, that The mounting shall be designed to be consistent with the highest seismic or safety classification of the SFP. An evaluation of other hardware stored in the SFP shall be conducted to ensure it will not create adverse interaction with the fixed instrument location(s).

- 9 The basis for the seismic design for mountings in the SFP shall be the plant seismic design basis at the time of submittal of the Integrated Plan for implementing NRC Order EA-12-0S1.

In its OIP, the licensee stated that both the primary and backup systems will be installed as Seismic Category I to meet the NRC ISG JLD-ISG-2012-03 and NEI 12-02 guidance requirements. The licensee also stated that in the conceptual design, the SFP probes bolt to a triangular mounting plate for installation at the corner of the SFP or a rectangular plate for mounting at the side of the SFP. According to the licensee, the mounting options will allow the probe to be installed within a few inches of the SFP liner, minimizing the chances of interference with other structures, and occupying limited space on the SFP deck.

In its July 2, 2013, letter, the licensee stated, in part, that a) The design criteria to be used to estimate the total loading on the mounting devices is an item to be supplied by the vendor per the Dominion procurement speCification ... Further details of the hydrodynamic/seismic evaluation will be provided by the vendor in accordance with the final procurement specification. It is anticipated that the full qualification will be available upon completion of the final design, scheduled for December 2013, and will be forwarded to the NRC during the subsequent scheduled status update.

b) Because of the lightweight and flexible design of the Guided Wave Radar (GWR) probe, a stilling well is not required. The lack of probe mass and the probe's reaction to seismic loading permit the pool mount to be very simple, lightweight, and require a very small footprint. It can be mounted on the curb's horizontal surface or curb face in most pool situations. Mounting on the curb face results in the cable conduit from the mount to the transmitter enclosure being the only protrusion above the curb. The transmitter enclosures will be located in either the Fuel Building or the Auxiliary Building depending on the final locations of the GWR probes ...

The probe is comprised of a three-eighths inch braided stainless cable secured at the top by a connector and flange. The bottom of the probe has a uniquely designed approximate two pound weight surrounded by a radiation and chemical resistant shock absorbent materiaL ..

The final mounting details will be available upon completion of the final design, scheduled for December 2013, and will be forwarded to the NRC during the subsequent scheduled status update.

The NRC staff notes that in its letter dated July 2, 2013, the licensee stated that final mounting details will be available upon completion of the final deSign, scheduled to be completed by December 2013. The licensee indicated that the information will be forwarded to the staff in the February 2014 six month status update. The staff has identified these requests as:

- 10 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 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.

(This information was previously requested as RAI-3 in the NRC letter dated May 28,2013)

In addition, the staff plans to verify the results of the licensee's seismic testing and analysis when it is completed based on the licensee's response to the following RAI.

RAI #4 For RAI 3(a) above, please provide the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

RAI #5 For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

3.6 Design Features: Qualification of Order EA-12-051 states, in part, that The primary and backup instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for an extended period. This reliability shall be established through use of an augmented quality assurance process (e.g. a process similar to that applied to the site fire protection program).

- 11 NEI 12-02 states, in part, that The instrument channel reliability shall be demonstrated via an appropriate combination of design, analyses, operating experience, and/or testing of channel components for the following sets of parameters, as described in the paragraphs below:

• conditions in the area of instrument channel component use for all instrument components,

• effects of shock and vibration on instrument channel components used during any applicable event for only installed components, and

• seismic effects on instrument channel components used during and following a potential seismic event for only installed components ...

The NRC staff assessment of the instrument qualification is discussed in the following subsections below: (3.6.1) Augmented Quality Process, (3.6.2) Post Event Conditions, (3.6.3)

Shock and Vibration, and (3.6.4) Seismic Reliability.

3.6. 1 Augmented Quality Process Appendix A-1 of the guidance in NEI 12-02 describes a quality assurance process for non safety systems and equipment that is not already covered by existing quality assurance requirements. Within the ISG, the NRC staff found the use of this quality assurance process to be an acceptable means of meeting the augmented quality requirements of Order EA-12-051.

In its OIP, the licensee stated that augmented quality requirements consistent with NEI 12-02, Appendix A-1 will be applied to this project.

The licensee's proposed augmented quality assurance process appears to be consistent with I\lEI 12-02, as endorsed by the ISG.

3.6.2 Post Event Conditions NEI 12-02 states, in part, that The temperature, humidity and radiation levels consistent with conditions in the vicinity of the [SFP] and the area of use considering normal operational, event and post-event conditions for no fewer than seven days post-event or until off site resources can be deployed by the mitigating strategies resulting from Order EA-12-049 should be considered. Examples of post-event (beyond-design basis) conditions to be considered are:

• radiological conditions for a normal refueling quantity of freshly discharged (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuel with the SFP water level 3 as described in this order,

• temperatures of 212 degrees F and 100% relative humidity environment,

- 12

• boiling water and/or steam environment

• a concentrated borated water environment, and ...

In its OIP, the licensee stated, consistent with NEI 12-02, that:

Temperature, humidity and radiation levels consistent with conditions in the vicinity of the SFP and the area of use considering normal operational, event and post-event conditions will be addressed in the engineering and design phase.

These conditions will be considered for no fewer than seven days post-event or until off-site resources can be deployed by the mitigating strategies resulting from Order EA-12-049 (Reference 5). Examples of post-event (beyond-design-basis) conditions that will be considered are:

• radiological conditions for a normal refueling quantity of freshly discharged (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuel with Level 3 SFP water level as described in Section III,

• temperatures of 212 degrees F and 100% relative humidity environment,

• boiling water and/or steam environment,

• a concentrated borated water environment, In its letter dated July 2, 2013, the licensee stated, in part, that Equipment that will be located in the spent fuel pool will be certified for use in post-event conditions including temperatures in excess of 100° Centigrade, 100 percent condensing atmosphere, submerged operation at elevated chemical concentrations, and exposure to postulated radiation levels with the fuel storage rack uncovered for an extended period of time. The new NEMA 4X transmitter enclosure will be installed in either the Fuel Building and/or the Auxiliary Building depending on the final GWR probe locations. The transmitter will be qualified for use at temperatures up to 60° Centigrade, 100 percent condensing atmosphere, and 1x1 04 rads integrated dose. The inherent shielding of the structures along the line of sight between the fuel and the transmitter will result in negligible doses to the transmitter, even for uncovered fuel. For the transmitter located in the fuel building, thermal analyses will be performed to demonstrate that, for boiling conditions in the pool, the temperature at the transmitter enclosure does not exceed the 60° Centigrade qualification limit.

The NRC staff has concerns with the licensee's lack of information regarding the capability of the SFP level instrumentation to continuously perform its required functions under post even conditions. The staff has identified these requests as:

- 13 RAI #6 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the equipment (including transmitters, control boxes, and display panels) will be exposed. Also, please provide documentation indicating how it was determined that the electronics for the 8FP level instrumentation is capable of withstanding a total integrated dose of 1X104 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

RAI #7 Please provide information indicating (a) what are the temperature ratings and whether the temperature ratings for the system electronics (including transmitters, control boxes, and display panels) are continuous duty ratings; and, (b) what will be the maximum expected ambient temperature in the rooms in which the system electronics will be located under BOB conditions in which there are no AC power available to run Heating Ventilation and Air Conditioning (HVAC) systems?

RAI #8 Please provide information indicating the maximum expected relative humidity in the rooms in which the system electronics will be located under BOB conditions, in which there are no AC power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing its required functions under this expected humidity condition.

3.6.3 Shock and Vibration 1\1 EI 12-02 states, in part, that Applicable components of the instrument channels are rated by the manufacturer (or otherwise tested) for shock and vibration 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:

• instrument channel components use known operating principles, are supplied by manufacturers with commercial quality programs (such as 1809001) with shock and vibration requirements included in the purchase specification and/or instrument design, and commercial design and testing for operation in environments where significant shock and vibration loadings are common, such as for portable hand-held devices or transportation applications;

• substantial history of operational reliability in environments with significant shock and vibration loading, such as transportation applications, or

• use of component inherently resistant to shock and vibration loadings or are seismically reliable such as cables.

In its OIP, the licensee stated, in part, that components of the instrument channels will be qualified for shock and vibration using one or more of the methods identified in NEI 12-02.

- 14 In its letter dated July 2, 2013, the licensee stated, in part, that Reliability of the permanently installed equipment under BDB ambient temperature, humidity, shock, vibration, and radiation conditions will be demonstrated through the equipment desjgn, testing, or analysis.

The NRC staff has concerns with the licensee's lack of information regarding the capability of the SFP level instrumentation to continuously pertorm its required functions under the expected shock and vibration conditions. The staff has identified these requests as:

RAI #9 Please provide information describing the evaluation of the comparative sensor desjgn, the shock test method, test results, and forces applied to the sensor applicable to its successful tests demonstrating that the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of severe shock.

RAI #10 Please provide information describing the evaluation of the comparative sensor design, the vibration test method, test results, and the forces and their frequency ranges and directions applied to the sensor applicable to its successful tests, demonstrating that the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

RAI #11 Please provide information describing the evaluation of the comparative system electronics (including transmitters, control boxes, and display panels) ratings against postulated plant conditions. Also provide results of the manufacturer's shock and vibration test methods, test results, and the forces and their frequency ranges and directions applied to the system electronics and display panel associated with its successful tests.

3.6.4 Seismic Reliability The ISG recommends the use of Sections 7,8,9, and 10 of IEEE 344-2004 for seismic qualification of the SFP level instrumentation.

In its OIP, the licensee stated that For seismic effects on the installed instrument channel components, the following measures will be used to verify that the design and installation are adequate.

Applicable components of the instrument channels are rated by the manufacturer (or otherwise tested) for seismic effects at levels commensurate with those of postulated design basis event conditions at the location of the instrument channel component using one or more of the following methods:

- 15

• 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 proposed installation;

• 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 1E Equipment for Nuclear Power Generating Stations ... or a substantially similar industrial standard; or

• 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-Ievels and frequency ranges). These requirements will be used as design input for the detailed design, vendor selection, and final implementation.

In its letter dated July 2, 2013, the licensee stated that the installed equipment will be tested and analyzed to meet the Seismic Qualification Reporting & Testing Standardization (SQURTS) seismic envelope for plants in the United States. The licensee also stated that the equipment mounts will be seismically configured for the specific conditions and locations determined by the final design. The licensee indicated that they will perform site-specific analysis to certify the mount's performance at the selected location. In addition, the licensee stated that testing will be performed to confirm .that the system maintains its design accuracy after a seismic event.

Regarding the transmitter and display, in this same letter, the licensee stated that these components are currently planned to be located in either the Fuel Building or the Auxiliary Building and the Service Building, respectively, which are all Seismic Class I Structures.

In addition, in its letter dated July 2, 2013, the licensee stated, in part, that Further details of the qualification and test program used to confirm the reliability of the permanently installed equipment during and following seismic conditions will be available upon completion of the final design, scheduled for December 2013, and will be forwarded to the NRC during the subsequent scheduled status update.

The NRC staff notes that the licensee's planned approach with respect to the seismic reliability of the instrumentation appears to be consistent NEI 12-02, as endorsed by the ISG. The staff also notes that further information regarding reliability and qualification of the permanently installed SFP level instrumentation equipment during and following seismic conditions will be available upon completion of the final design and that the licensee will forward this information to the staff in the February 2014, six month status report. The staff has identified these requests as:

- 16 RAI #12 Please provide the following:

a) 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.

b) 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.

(This information was previously requested as RAI-4 Item b and Item c in the NRC letter dated May 28,2013)

In addition, the staff plans to verify the results of the licensee's testing and analysis used to demonstrate the qualification and reliability of the installed equipment when it is completed based on the licensee's response to the following RAI.

RAI #13 For RAI #12 above, please provide the results for the selected methods, tests and analyses used to demonstrate the quali'fication and reliability of the installed equipment in accordance with the Order requirements.

3.6.5 Qualification Evaluation Summary Upon acceptable resolution of the RAls in Section 3.6, the NRC staff will be able to make a conclusion regarding the instrument qualification.

3.7 Design Features: Independence of Order EA-12-051 states, in part, that The primary instrument channel shall be independent of the backup instrument channel.

NEI 12-02 states, in part, that Independence of permanently installed instrumentation, and primary and backup channels, is obtained by physical and power separation commensurate with the hazard and electrical isolation needs. If plant AC or DC power sources are used then the power sources shall be from different buses and preferably different divisions/channels depending on available sources of power.

- 17 In its OIP, the licensee stated, in part, that Independence will be achieved through physical separation of the final installed instruments. The two (2) permanently installed instrument sensors will be separated by a distance comparable to the shortest length of a side of the pool, to the extent practical, based on the existing SFP geometry and construction.

The cables associated with each channel will follow separate and independent routes from the instruments to each electronics' enclosure and from the enclosures to the displays. The normal AC or DC power source for each channel will be provided from independent and separate sources.

In its letter dated July 2, 2013, the licensee stated, in part, that Each system provides two completely independent channels of level instrumentation. Each channel is comprised of the GWR flexible probe, the probe mount, the transmitter enclosure, the instrument enclosure containing the DC power source and charger, sensor conditioning and communication circuitry, and is equipped with appropriate enclosure connections to remote displays and alternate power sources.

The sensors are located at opposite ends of the SFP, the transmitters will be located in either the Fuel Building or the Auxiliary Building, and the instrument enclosures are located in the Service Building. Dominion's standard separation criteria for instrument cable will be applied.

The power source for each level channel is based on 24-volt DC sealed batteries and a charging source connected to AC power from different sources. Therefore, the loss of one power source will not result in the loss of both channels. In addition to the normal DC power supply to each channel, a back-up power source will also be provided to each channel in the form of a portable back-up battery and connections to alternate power sources independent of the normal AC or DC power sources.

The NRC staff notes that with this arrangement, the loss of one backup power supply will not affect the operation of the independent channel under BOB event conditions. The implementation of such design provisions appears to be consistent with NEI 12-02, as endorsed by the ISG, and the electrical functional performance of each level measurement channel would be considered independent of the other channel. However, the NRC staff plans to verify the final electrical power supply design information when it is provided. The NRC staff has identified this request as:

RAI #14 a) A description of the electrical AC power sources and capabilities for the primary and backup channels.

b) Please provide the NRC staff with the final configuration of the power supply source for each channel so that the staff may conclude that the two channels are independent from a power supply assignment perspective.

- 18 3.8 Design Features: Power Supplies of Order EA-12-051, states in part, that Permanently installed instrumentation channels shall each be powered by a separate power supply. Permanently installed and portable instrumentation channels shall provide for power connections from sources independent of the plant ac and dc power distribution systems, such as portable generators or replaceable batteries. Onsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.

NEI 12-02 states, in part, that The normal electrical power supply for each channel shall be provided by different sources such that the loss of one of the channels primary power supply will not result in a loss of power supply function to both channels of SFP level instrumentation.

All channels of SFP level instrumentation shall provide the capability of connecting the channel to a source of power (e.g., portable generators or replaceable batteries) independent of the normal plant AC and DC power systems.' For fixed channels this alternate capability shall include the ability to isolate the installed channel from its normal power supply or supplies. The portable power sources for the portable and installed channels shall be stored at separate locations, consistent with the reasonable protection requirements associated with NEI 12-06 (Order EA-12-049). The portable generator or replaceable batteries should be accessible and have sufficient capacity to support reliable instrument channel operation until off-site resources can be deployed by the mitigating strategies resulting from Order EA-12-049.

If adequate power supply for either an installed or portable level instrument credits intermittent operation, then the provisions shall be made for quickly and reliably taking the channel out of service and restoring it to service. For example, a switch on the power supply to the channel is adequate provided the power can be periodically interrupted without significantly affecting the accuracy and reliability of the instrument reading. Continuous indication of SFP level is acceptable only if the power for such indication is demonstrably adequate for the time duration specified in section 3.1 [.]

In its OIP, the licensee stated, in part, that The normal power supply for each channel will be provided by different power sources such that loss of one power source will not result in the loss of both channels. In addition to the normal plant AC and/or DC power supply to each channel, a back-up power source will also be provided to each channel in the form of a back-up battery independent of the normal AC or DC power sources.

- 19 In its letter dated July 2,2013, the licensee stated, in part, that The power source for each level channel is based on 24-volt DC sealed batteries and a charging source connected to AC power from different sources. The seismically qualified batteries are designed to supply power for the entire level monitoring channel for at least seven days after a station black out (SBO). The enclosure and associated electronics are qualified for continuous operation in an operating environment of 0-50° Centigrade and 95 percent humidity, non condensing atmosphere without the need for cooling fans.

Since the system is designed to support continuous operation over a seven-day or longer SBO period, there is sufficient time to either restore or provide a back up source of AC power to recharge the 24-volt batteries. Deployment of an AC power source to recharge the level monitoring channel batteries will be included in the FLEX implementing procedures. As such, each channel will be available to run reliably and continuously following the onset of a BOB event for seven days, which is greater than the minimum duration needed.

The NRC staff notes that the proposed criteria for sizing of the battery backup appears to be consistent with NEI 12-02, as endorsed by the ISG. However, the staff plans to verify the results of the licensee's calculation for required duty cycle given the final design load of the instrument channel for its installed configuration. The staff has identified this request as:

RAI #15 Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

3.9 Design Features: Accuracy of Order EA-12-051 states, in part, that The instrument channels shall maintain their designed accuracy following a power interruption or change in power source without recalibration.

NEI 12-02 states, in part, that Accuracy should consider operations while under SFP conditions, e.g., saturated water, steam environment, or concentrated borated water. Additionally, instrument accuracy should 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.

In its OIP, the licensee stated, in part, that The instrument channels will maintain their design accuracy following a power interruption or change in power source without requiring recalibration. Since the instrumentation is generally commercial off the shelf supplied components, the

- 20 vendor published instrument accuracies will be verified as acceptable and will be used as a basis for final configuration and calibration I procedures.

Accuracy requirements will consider SFP conditions, e.g., saturated water, steam environment, and 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.

Specific details regarding accuracy will be obtained from the supplier during the detailed design phase.

In its letter dated July 2,2013, the licensee stated, in part, that a) The selected North Anna SFP level instrumentation system has a design accuracy of +/- 2 inches and will maintain this accuracy over the full range of operating conditions, including beyond-design-basis conditions. It will maintain its design accuracy following a power interruption without the need for recalibration.

b) Calibration of the SFP level system is performed in-situ. Channel check and calibration tolerances will be developed as part of the detailed design. The final calibration methodology will be available upon completion of the final design, scheduled for December 2013, and will be forwarded to the NRC during the subsequent scheduled status update.

The NRC staff notes that the estimated instrument channel design accuracies appear to be sufficient to maintain the instrument channels to within their designed accuracies before significant drift can occur. The staff plans to verify that the licensee's proposed instrument performance is consistent with these estimated accuracy values. Further, the staff plans to verify that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power. The staff has identified this request as:

RAI #16 Provide the following:

a) 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.

b) Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BOB values. Please demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

- 21 (Item a of this information was previously requested as RAI-7, Item b in the NRC letter dated May 28,2013) 3.10 Design Features: Testing of Order EA-12-0S1 states, in part, that The instrument channel design shall provide for routine testing and calibration.

NEI 12-02 states, in part, that Static or non-active installed (fixed) sensors can be used and should be designed such that testing anc:llor calibration can be performed in-situ. For microprocessor based channels the instrument channel design shall be capable of testing while mounted in the pool.

In its OIP, the licensee stated, in part, that Instrument channel design will provide for routine testing and calibration consistent with Order EA-12-0S1and the guidance in NEI12-02. The installed sensors will be designed to allow testing and/or calibration via in-situ methods while mounted in the pool. Removal of the sensor from the pool will not be required for calibration or testing.

In addition, in its letter dated July 2,2013, the licensee stated, in part, that a) The SFP level instrumentation system is capable of individual channel in-situ calibration and cross-calibration of the two independent level indication channels. In-situ calibration is performed at the transmitter enclosure using internal displays. The GWR determines pool depth by measuring the time of flight of a pulse from the transmitter to the water interface and back to the transmitter's receiver. A calibration device, provided by the manufacturer, incorporates time of flight delays equal to various pool levels. The device is connected to the transmitter and is exercised for each level. Following calibration certification, the depth indication for both pool level sensors is compared as a final functional check of the level measurement capabilities.

b) The two independent channels of the SFP level instrumentation system will be cross-checked against each other. Since the two wide range level channels are independent, a channel check tolerance based on the design accuracy of each channel will be applied for cross comparison between the two channels. The tolerance is determined as the square root of the sum of the squares of the design accuracy value, which is +/- 2 inches. (Reference the response to RAI-7.) Therefore, the channel check tolerance is 2.8 inches.

- 22 Local level indication is provided by a ruled scale mounted on the east side of the SFP counterfort. Normal SFP level is indicated by the 0 inch mark on the scale and corresponds to the 289.83 foot elevation. Level is normally maintained between the 0 and +3 inch mark. The wide range level instrument may also be cross-checked against this visual indication.

The NRC staff notes that by comparing the levels in the instrument channels and the acceptance criteria described in Section 3.9 above, the operators can determine if recalibration or troubleshooting is needed. The licensee's proposed design, with respect to routine in-situ instrument channel functional and calibration tests, appears to be consistent with NEI 12-02, as endorsed by the ISG.

3.11 Design Features: Display of Order EA-12-051 states, in part, that Trained personnel shall be able to monitor the spent fuel pool water level from the control room, alternate shutdown panel, or other appropriate and accessible location. The display shall provide on-demand or continuous indication of spent fuel pool water level.

NEI 12-02 states, in part, that The intent of this guidance is to ensure that information on SFP level is reasonably available to the plant staff and decision makers. Ideally there will be an indication from at least one channel of instrumentation in the control room.

While it is generally recognized (as demonstrated by the events at Fukushima Daiichi) that SFP level will not change rapidly during a loss of spent fuel pool cooling scenario more rapid SFP drain down cannot be entirely discounted.

Therefore, the fact that plant personnel are able to determine the SFP level will satisfy this requirement, provided the personnel are available and trained in the use of the SFP level instrumentation (see Section 4.1) and that they can accomplish the task when required without unreasonable delay.

SFP level indication from the installed channel shall be displayed in the control room, at the alternate shutdown panel, or another appropriate and accessible location (reference NEI 12-06). An appropriate and accessible location shall have the following characteristics:

• occupied or 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,

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• inside a structure providing protection against adverse weather, and

• outside of any very high radiation areas or LOCKED HIGH RAD AREA during normal operation.

If multiple display locations beyond the required "appropriate and accessible location" are desired, then the instrument channel shall be designed with the capability to drive the multiple display locations without impacting the primary "appropriate and accessible" display.

In its alP, the licensee stated that the conceptual design located the electronics enclosure and primary display in the Cable Spreading Room and that specific details regarding the display and display location(s) would be finalized during the detailed design phase.

In its letter dated July 2, 2013, the licensee stated, in part, that The current conceptual design places the display units for both channels in a Seismic Category Class 1 portion of the Service Building, which is accessible from the Main Control Room (MCR) via a stairwell. Alternate access to the current conceptual display location is also available from the MCR via the Turbine Building.

Final design details for the display units, including justification for prompt accessibility from the MCR and habitability, are scheduled to be completed by December 2013 and will be forwarded to the NRC during the subsequent scheduled status update.

In its letter dated August 23, 2013, the licensee stated, in part, that The location of the display units provided in the RAI response [letter dated July 2, 2013] was based on conceptual design information and indicated that the display units would be located in the Cable Spreading Room in the Service Building.

The location indicated in the RAI response is being updated to indicate that the display units are now being relocated to within the boundary of the Main Control Room.

The !'JRC staff notes that the NEI guidance for "Display" speci'fically mentions the control room as an acceptable location for SFP instrumentation displays as it is occupied or promptly accessible, outside the area surrounding 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. The licensee's proposed location for the primary and backup SFP instrumentation displays appears to be consistent with !'JEI 12-02, as endorsed by the ISG.

3.12 Programmatic Controls: Training of Order EA-12-0S1 states, in part, that Personnel shall be trained in the use and the provision of alternate power to the primary and backup instrument channels.

- 24 NEI 12-02 states, in part, that The personnel performing functions associated with these SFP level instrumentation channels shall be trained to perform the job specific functions necessary for their assigned tasks (maintenance, calibration, surveillance, etc.).

SFP instrumentation should be installed via the normal modification processes.

In some cases, utilities may choose to utilize portable instrumentation as a portion of their SFP instrumentation response. In either case utilities should use the Systematic Approach to Training (SAT) to identify the population to be trained. The SAT process should also determine both the initial and continuing elements of the required training.

In its OIP, the licensee stated, in part, that The Systematic Approach to Training (SAT) will be used to identify the population to be trained and to determine both the initial and continuing elements of the required training. Training will be completed prior to placing the instrumentation in service.

The licensee's proposed plan, with respect to the training personnel in the use and the provision of alternate power to the primary and backup instrument channels, including the approach to identifying the population to be trained, appears to be consistent with NEI 12-02, as endorsed by the ISG.

3.13 Programmatic Controls: Procedures of Order EA-12-051 states, in part, that Procedures shall be established and maintained for the testing, calibration, and use of the primary and backup spent fuel pool instrument channels.

NEI 12-02 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.

In its OIP, the licensee stated 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.

In its leUer dated July 2, 2013, the licensee stated, in part, that Procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation will be developed in accordance with existing station administrative and technical procedures that govern procedure development. These procedures ensure standardization of format and terminology and ease of use, and assurance of a

- 25 consistent level of quality in the procedures developed for the SFP level instrumentation.

The !\IRC staff has concerns with the licensee's lack of information about its plans to develop procedures. The staff previously requested this information as RAI-10 in NRC letter dated May 28, 2013. However, based on feedback from licensees, the staff revised this RAI as follows:

RAI #17 Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

3.14 Programmatic Controls: Testing and Calibration of Order EA-12-051 states, in part, that Processes shall 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.

I\lEI 12-02 states, in part, that Processes shall 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. The testing and calibration of the instrumentation shall be consistent with vendor recommendations or other documented basis.

In its OIP, the licensee stated, in part, that Processes will be established and maintained for scheduling and implementing necessary testing and calibration of the primary and back-up 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.

In its letter dated July 2, 2013, the licensee stated, in part, that a) The maintenance and testing of the SFP level instrumentation system will be incorporated into the normal station surveillance and work control processes based on vendor recommendations for maintenance and periodic testing.

The calibration and maintenance program will include surveillances or testing to validate the functionality of each instrument channel within 60 days of a planned refueling outage conSidering normal test scheduling allowances (e.g., 25%).

- 26 b) The preventive maintenance, test and calibration program will be developed consistent with the vendor's recommendations.

c) In the event a channel of SPF level instrumentation is out of service for any reason, an administrative action statement will be entered to restore the channel to service within 90 days. Functionality of the other channel will be confirmed via appropriate surveillance measures until the non-functioning channel is restored to service. As with Item a) above, the frequency of these actions will be developed consistent with vendor recommendations.

In the event that a channel cannot be restored to service within the 90 day period, expedited actions to restore the channel would be initiated and tracked via Dominion's Corrective Action System. If both channels are determined to be non-functional, Dominion will initiate appropriate compensatory actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The appropriate compensatory actions have not been specified at this time.

The determination of these actions is part of the overall effort to develop the BDB Program administrative and implementation procedures. The BDB Program will incorporate the guidance of NEI 12-02, including the requirements associated with out of service time. The BDB Program is currently scheduled for completion in September 2014. A summary of the compensatory measures will be forwarded to the NRC in a subsequent scheduled status update.

The licensee's proposed plan, with respect to testing and calibration, as well as, compensatory actions for instruments out of service, appears to be consistent with NEI 12-02, as endorsed by the ISG. The NRC staff notes that the final information regarding SFP level instrumentation testing and calibration program and compensatory actions is not currently available for review.

The licensee indicated that the BDB Program will incorporate the guidance of NEI 12-02; including the requirements associated with out of service time and that the BDB Program is currently scheduled for completion in September 2014. The licensee will forward this information to the staff in a subsequent scheduled status update. The staff has identified this request as:

RAI #18 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. Please include a description of the 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) Information describing compensatory actions when both channels are out-of-order, and the implementation procedures.

~ 27 ~

c) Additional information describing expedited and compensatory actions in the maintenance procedure to address when one of the instrument channels cannot be restored to functional status within 90 days.

3.15 Instrument Reliability NEI 12~02 states, in part, that A spent fuel pool level instrument channel is considered reliable when the instrument channel satisfies the design elements listed in Section 3 [Instrument Design Features] of this guidance and the plant operator has fully implemented the programmatic features listed in Section 4 [Program Features].

In its alP, the licensee stated that the channel design would meet the !\lEI guidance and that reliability will be assured through implementation of the programmatiC controls that are consistent with the applicable guidance in NEI 12-02.

Upon acceptable resolution of the RAls noted above, the NRC staff will be able to make a conclusion regarding the reliability of the SFP instrumentation.

4.0 CONCLUSION

The NRC staff is unable to complete its evaluation regarding the acceptability of the licensee's plans for implementing the requirements of Order EA~12-051 due to the need for additional information as described above. The staff will issue an evaluation with its conclusion after the licensee has provided the requested information.

13281 A648 'via email dated 10/4/13 OFFICE NRRlDORULPL2-1/PM NRR/DORULPL2-1/LA NRRlDSS/SBPB/BC NAME VSreenivas SFigueroa GCasto DATE 10/24/13 10/24/13 10/4113 OFFICE NRR/DE/EICB/BC NRRlDORULPL2-1/BC NRRlDORULPL2-1/PM NAME JThorp RPascarelli VSreenivas DATE 10/4/13 11/1/13 11/1/13