ML14115A315

Plan for the Onsite Audit of Mohr Regarding Implementation of Reliable Spent Fuel Pool Instrumentation Related to Order EA-12-051

ML14115A315
Person / Time
Site:	Cook
Issue date:	04/28/2014
From:	Boska J NRC/NRR/DPR/MSD/MSPB
To:	Weber L Indiana Michigan Power Co
Boska J, NRR/DPR, 415-2901
References
EA-12-051, TAC MF0761, TAC MF0762
Download: ML14115A315 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 28, 2014 Mr. Lawrence J. Weber Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, Ml 49106

SUBJECT:

DONALD. C. COOK NUCLEAR PLANT, UNITS 1 AND 2 - PLAN FOR THE ONSITE AUDIT OF MOHR REGARDING IMPLEMENTATION OF RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDER EA-12-051 (TAC NOS. MF0761 AND MF0762)

Dear Mr. Weber:

On March 12, 2012, the U.S. Nuclear Regula~ory Commission (NRC) issued Order EA-12-051, "Issuance of Order to Modify 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. The 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 external event. The order required all holders of operating licenses issued under Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, "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 27, 2013 (ADAMS Accession No. ML13071A323), as supplemented by letters dated July 11, 2013 (ADAMS Accession No. ML13196A250), August 26, 2013 (ADAMS Accession No. ML13247A050) and February 27, 2014 (ADAMS Accession No. ML14063A041),

Indiana Michigan Power Company submitted its OIP for Donald C. Cook Nuclear Power Plant, Units 1 and 2 (D.C. Cook).

The NRC staff's review led to the issuance of the D.C. Cook interim staff evaluation (ISE) and request for additional information (RAI) dated November 13, 2013 (ADAMS Accession No. ML13310B499). By eportal document dated March 27, 2014, Indiana Michigan Power Company submitted their response to the RAis.

By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-051 in accordance with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). The purpose of the staff's audit is to determine the extent to which the licensees are proceeding on a path towards successful implementation of the actions needed to achieve full compliance with the order.

L. Weber The ongoing audit process, to include in-office and on site portions, allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation. The audit allows the staff to review additional information provided following issuance of the ISE, supplements to the licensee's integrated plan, implementation design aspects and feasibility, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the onsite, licensee audit process that will provide the NRC staff more detailed understanding of the licensee's implementation strategy and determine if further information is needed to make a safety determination. The staff plans to conduct an onsite audit of specific aspects of the D.C. Cook OIP, as supplemented, at the licensee's vendor facility in accordance with the enclosed audit plan from May 28-29, 2014.

If you have any questions, please contact me at 301-415-2901 or by e-mail at john.boska@nrc.gov.

Sincerely, Ckv~

~n B~~ka, Senior Project Manager Project Management Branch Mitigating Strategies Directorate Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316

Enclosures:

1. Audit plan

2. Generic Design Information Template cc w/encl: Distribution via Listserv

Audit Plan Donald C. Cook Nuclear Power Plant, Units 1 and 2 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-051, "Issuance of Order to Modify 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. The 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 external event. The order required all holders of operating licenses issued under Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50, "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 27, 2013 (ADAMS Accession No. ML13071A323), as supplemented by letters dated July 11, 2013 (ADAMS Accession No. ML13196A250), August 26, 2013 (ADAMS Accession No. ML13247A050) and February 27, 2014 (ADAMS Accession No. ML14063A041),

Indiana Michigan Power Company submitted its OIP for Donald C. Cook Nuclear Power Plant, Units 1 and 2 (D.C. Cook).

The NRC staff's review led to the issuance of the D.C. Cook interim staff evaluation (ISE) and request for additional information (RAI) dated November 13, 2013 (ADAMS Accession No. ML13310B499). By eportal document dated March 27, 2014, Indiana Michigan Power Company submitted their response to the RAis.

By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-051 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). The purpose of the staff's audit is to determine the extent to which the licensees are proceeding on a path towards successful implementation of the actions needed to achieve full compliance with the order.

The ongoing audit process, to include in-office and on site portions, allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation. The audit allows the staff to review additional information provided following issuance of the ISE, supplements to the licensee's integrated plan, implementation design aspects and feasibility, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the onsite, licensee audit process that will provide the NRC staff more detailed understanding of specific aspects of the D.C. Cook OIP, as supplemented, at the licensee's vendor facility and determine if further information is needed to make a safety determination.

Enclosure 1

During the review of the D.C. Cook OIP, the licensee identified that Mohr Test and Measurement LLC (Mohr) was selected as the vendor providing the SFP level instrumentation.

As part of the NRC staff's ongoing audit and review of the D.C. Cook OIP, the NRC staff will conduct this audit at the licensee's vendor facility, per the audit process described above, to review information concerning the design features of the Mohr SFP level instrumentation as it pertains to the D.C. Cook plant with an awareness that the Mohr SFP instrumentation (SFPI) design may have generic applicability and be utilized in other licensees' site specific SFP instrumentation implementation.

Following the licensee's declaration of order compliance, the NRC staff will evaluate the OIP as supplemented, and, as appropriate, other licensee submittals based on the requirements in Order EA-12-051. The staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) developed guidance document NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC interim staff guidance (ISG) JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"'

(ADAMS Accession No. ML12221A339) as providing one acceptable means of meeting the order requirements. Other methods that deviate from the guidance may be found acceptable, but will require additional staff review and attention.

AUDIT SCOPE As discussed, onsite audits will be performed per NRR Office Instruction LIC-111, "Regulatory Audits," to support the development of safety evaluations.

The purpose of the NRC audit is to provide the NRC staff a more detailed understanding of specific aspects of the D.C. Cook OIP, as supplemented, at the licensee's vendor facility, review the licensee's vendor design information concerning the Mohr SFP level instrumentation, and determine if further information is needed to make a safety determination.

This onsite audit has two primary purposes:

(1) Review the licensee's Mohr SFP level instrumentation design specification and test results information that are anticipated to be provided in response to the NRC staff's RAis, and (2) Confirm NRC staff understanding of the installation requirements, operation, and required maintenance of the licensee's Mohr SFP level instrumentation.

The NRC staff will conduct an evaluation of the licensee's vendor and design information that addresses the topics in the enclosed generic design information template. The NRC audit team requests for the licensee to arrange for a presentation on the vendor's SFP level instrumentation design per the proposed schedule at the end of this plan.

NRC AUDIT TEAM Title Team Member Organization Telephone number Team Lead Carla Roque-Cruz NRC/NRR/MSD/MRSB 301-415-1455 Technical Support Steve Wyman NRC/NRR/MSD/MRSB 301-415-3041 Technical Support Gursharan Singh NRC/NRR/MSD/MESB 301-415-2962 Technical Support Khoi Nguyen NRC/NRR/MSD/MESB 301-415-6839 Branch Chief Sheena Whaley NRC/NRR/MSD/MRSB 301-415-0213 LOGISTICS The audit will be conducted onsite at the licensee's vendor's Mohr facility, Richland, WA on May 28-29, 2014. Entrance and exit briefings will be held with the licensee at the beginning and end of the audit, respectively, as well as daily briefings of team activities. Additional details will be addressed over the phone. A more detailed schedule is provided below.

A private conference room is requested for NRC audit team use with access to audit documentation upon arrival and as needed.

DELIVERABLES An audit report/summary will be issued to the licensee within 45 days from the end of the audit.

INFORMATION NEEDS The NRC staff will review the vendor design information, test results, and analysis supporting the D.C. Cook reliable SFP level instrumentation OIP submittal. The NRC staff requests that the licensee provide the applicable information contained in the attached generic design information template for discussion while onsite. In further preparation for this onsite audit in the coming weeks, the NRC staff may request further information be posted to the eportal prior to the audit following continuing licensee vendor design document review.

Below is the preliminary list of documents the staff plans to review during the audit.

MOHR Test and Measurement Drawings 1-0430-19.1A MOHR Test and Measurement Drawings 1-0430-19.1B 1-0410-1 MOHR EFP-IL SFPI System Temperature and Humidity Test Report 1-0410-2 MOHR SFP-1 Level Probe Assembly Materials Qualification Report 1-0410-3 MOHR EFP-IL System Proof of Concept Report 1-0410-4 MOHR EFP-IL SFPI System EMC Test Report

1-0410-5 MOHR EFP-IL SFPI System Shock and Vibration Test Report 1-0410-6 MOHR EFP-IL SFPI System Seismic Test Report 1-0410-7 MOHR EFP-IL SFPI System Battery Life Report 1-0410-8 MOHR EFP-IL SFPI System Boric Acid Deposition Report 1-0410-9 MOHR SFP-1 Level Probe Assembly Seismic Analysis Report 1-041 0-9.1 MOHR SFP-1 Site-Specific Seismic Analysis Report: D. C. Cook Nuclear Plant (D.C Cook) 1-0410-10 MOHR EFP-IL SFPI System Power Interruption Report Mohr Vendor Operator's Manual

Proposed Schedule Onsite Day 1, Wednesday, May 28, 2014 0800 Check in at site; Badging 0900 Entrance meeting 0930 Vendor (Mohr) Design Presentation 1230 Lunch 1330 NRC Audit Team Activities commence:

• Review test results and analysis per the generic design information template

• Review vendor documents 1600 Audit Team meeting 1630 Team lead daily debrief with licensee Onsite Day 2, Thursday, May 29, 2014 0800 NRC Audit Team Activities continue:

• Review test results and analysis per the generic design information template

• Review vendor documents 1200 Lunch 1300 Continue NRC Audit Team Activities 1500 Audit Team meeting 1600 NRC/Licensee pre-exit meeting 1630 NRC/Licensee formal exit meeting 1700 Audit closeout/departure

REFERENCES

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Instrumentation," dated March 12, 2012 (ADAMS Accession No. ML12054A679)

2. Nuclear Energy Institute (NEI) guidance document NEI 12 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)

3. NRC Final Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA 051, Reliable Spent Fuel Pool Instrumentation," dated August 29, 2012 (ADAMS Accession No. ML12221A339)

4. Letter from Indiana Michigan Power Company to NRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ),"dated February 27, 2013 (ADAMS Accession No. ML13071A323)

5. Letter from NRC to Indiana Michigan Power Company, "Donald C. Cook Nuclear Power Plant, Units 1 and 2- Request for Additional Information on the Overall Integrated Plan in Response to Order EA-12-051 Concerning Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0761 and MF0762)," dated June 19, 2013 (ADAMS Accession No. ML13164A381)

6. Letter from Indiana Michigan Power Company to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"," dated July 11, 2013 (ADAMS Accession No. ML13196A250)

7. Letter from Indiana Michigan Power Company to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 )," dated August 26, 2013 (ADAMS Accession No. ML13247A050)

8. Letter from NRC to Indiana Michigan Power Company, "Donald C. Cook Nuclear Plant, 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. MF0761 and MF0762)," dated November 13, 2013 (ADAMS Accession No. ML133108499)

9. Letter from Indiana Michigan Power Company to NRC, "Donald C. Cook Nuclear Plant Units 1 and 2 Six Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

(Order Number EA-12-051)," dated February 27, 2014 (ADAMS Accession No. ML14063A041)

10. Eportal document from Indiana Michigan Power Company to NRC, "Donald C. Cook Nuclear Power Plant Units 1 and 2 Response to Request for Additional Information,"

dated March 27, 2014.

Generic Design Information Template

1. Topic Parameter Vendor Additional Test or Licensee Summary Design Comments Analysis Evaluation Reference Results Document 1 Design Specification 2 Test Strategy 3 Environmental qualification for electronics enclosure with display 4 Environmental testing for level sensor components in SFP area-Saturated steam &

Radiation 5 Environmental testing for level sensor electronics housing-outside SFP 6 Thermal &

Radiation Aging-organic components in SFP area 7 Basis for Dose Requirements 8 Seismic Qualification 9 Sloshing 10 Spent Fuel Pool instrumentation system functionality test_Qrocedure Enclosure 2

11 Boron Build-Up 12 Pool-side Bracket Seismic Analysis 13 Additional Brackets (Sensor Electronics and Electronics Enclosure) 14 Shock &

Vibration 15 Requirements Traceability Matrix 16 Factory Acceptance Test 17 Channel Accuracy 18 Power Consumption 19 Technical Manual 20 Calibration 21 Failure Modes and Effects Analysis (FMEA) 22 EMI Testing

References:

L. Weber The ongoing audit process, to include in-office and on site portions, allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation. The audit allows the staff to review additional information provided following issuance of the ISE, supplements to the licensee's integrated plan, implementation design aspects and feasibility, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns.

This document outlines the onsite, licensee audit process that will provide the NRC staff more detailed understanding of the licensee's implementation strategy and determine if further information is needed to make a safety determination. The staff plans to conduct an onsite audit of specific aspects of the D.C. Cook OIP, as supplemented, at the licensee's vendor facility in accordance with the enclosed audit plan from May 28-29, 2014.

If you have any questions, please contact me at 301-415-2901 or by e-mail at john. boska@nrc.gov.

Sincerely, IRA!

John Boska, Senior Project Manager Project Management Branch Mitigating Strategies Directorate Office of Nuclear Reactor Regulation Docket Nos.: 50-315 and 50-316

Enclosures:

1. Audit plan

2. Generic Design Information Template cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsAcrsAcnw_MaiiCTR Resource MSD R/F JBoska, NRR/MSD RidsNrrDorlllpl3-1 Resource CRoqueCruz, NRR/MSD RidsNrrPMDCCook JBowen, NRR/MSD RidsNrrLASLent Resource RidsRgn3MaiiCenter Resource ADAMS Accession No ML14115A315 OFFICE NRR/MSD/MRSB NRR/MSD/LA NRR/MSD/MESB/BC NRR/MSD/MRSB/BC NAME CRoque-Cruz Slent SBailey SWhaley DATE 04/28/14 04/25/14 04/28/14 04/28/14 OFFICE NRR/MSD/MSPB/BC NRR/MSD/MSPB/PM NAME JBowen JBoska DATE 04/28/14 04/28/14 OFFICIAL AGENCY RECORD