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Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
	ML16041A070
Person / Time
Site:	Davis Besse
Issue date:	02/09/2016
From:	Boles B; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-051, L-16-003
	Download: ML16041A070 (9)
	v • d • e

FENOC^

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Fi rstEnergy Nuclear

@erating Company 5501 North State Route 2 Oak Harbon Ohio 43449 419-321-7676 Brirn D. fules Wce President, Nuelear February 9, 2016 L-16-003 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.2A2

SUBJECT:

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 FirstEnerqy_Nyclear Operating Company's (FENOC's\\ S.ixth Six-Month Status Report in

Response

to March 12. 2012 Commission Order Modilyino Licenses with Reoard to Reliable Spent-F-uel Pool Instrumentation (Order Number EA-12-051)

(CAC No. MF0960)

On March 1 2,2A12, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference

1) to FENOC. Reference 1 was immediately effective and directs FENOC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section lV, Condition C. Referen ce 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-A2, Revision 1 (Reference

3) with clarifications and exeeptions identified in Reference

2. Referen e 4 provided the FENOC initial status report regarding requirements for reliable spent fuel pool instrumentation.

Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station (BVPS),

Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station (DBNPS),

and Perry Nuclear Power Plant (PNPP).

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the sixth

Davis-Besse Nuclear Power Station L-16-003 Page 2 six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The attached report for DBNPS provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

The NRC staff also issued an interim staff evaluation (Reference

6) that included requests for additional information (RAls). The NRC staff subsequently indicated the intention to complete the ongoing review of the responses to Reference 1 by conducting audits and utilizing the ePortal system for review of RAl responses (Reference 7). The attached report has been updated to reflect this process change.

This letter contains no new regulatory commitments. lf you have any questions regarding this report, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-0810.

I declare un{er penalty of perjury that the foregoing is true and correct. Executed on February

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Respectfully,

- /#e^

Brian D. Boles

Attachment:

Davis-Besse Nuclear Power Station Six'th Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

References:

1.

NRC Order Number EA-12-051

, Order Modifoing Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.

2.

NRC Interim Staff Guidance JLD-ISG

-2012-A3, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool lnstrumentation, Revision 0, dated August 29, 2412.

3.

NEI 1 2-02,Industry Guidance for Compliance with NRC Order EA-12-A51, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 1, dated August 2012.

FirstEnergy Nuclear Operating Company's (FENOC's)

Initial Status Report in Response to March 12,2012, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool lnstrumentation (Order Number EA-1 2-051), dated October 26, 2012.

FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in Response to March 12,2012 Commission Order lssuance of Order to Modify 4.

5.

Davis-Besse Nuclear Power Station L-16-003 Page 3 cc:

6.

7.

Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated February 27, 2013.

Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for f mpfementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated December 11,2013.

NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26,2014,

Director, Office of Nuclear Reactor Regulation (NRR)

NRC Region lll Administrator NRC Resident Inspector NRC Project Manager Ms. Lisa M. Regner, NRR/JLD/PMB, NRC Mr. Blake A. Purnell, NRR/JLD/PMB, NRC Utility Radiological Safety Board (without Attachment)

Attachment L-16-003 Davis-Besse Nuclear Power Station Sixth Six-Month Status Report for the lmplementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8),

documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compfiance method, schedule, or need for relieflrelaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since July 31,2015 and are current as of January 31,2016.

o Update 5 was submitted

. Commissioning of SFP Instrumentation 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. This section provides the activity status of each item and the expected completion

date, noting any change. The dates are planning dates subject to change as design and implementation details are developed.

The milestones indicate the number assigned in the interim staff evaluation (lSE)

(Reference

3) to each request for additional information (RAl). Updates to RAI responses were posted on the ePortal as indicated in Reference 4.

There are no revised milestone target completion dates.

Attachment L-16-003 Page 2 of 6

lnstrumentation has been installed. Connection of backup power source is to be completed during the spring 2016 refueling outage.

4 Ghanges to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time.

6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item.

Overall Integrated Plan Open ltem Status None Not Applicable Milestone Target Completion Date Activity Status (as of 71311151 Revised Target Completion Date Submit Six-Month Status Updates Update I Auqust 2013 Complete Update 2, including response fo /SE RAI-I, RAI-2, RAI-3, RAI-4 (except 4b schematic),

RAI-6, RAI-9, and RALI0a February 2014 Complete Update 3 Auoust 2014 Complete Update 4 February 2015 Complete Update 5 Ausust 2015 Complete Posf response fo /SE RAI-4b schematic, RAI.s, RAI-7, RAI.8, RAI-10b, RAI-I1, RAI-I2, RAI-13, RAI-14, and RAI-I5 on ePortal September 2015 Complete Update 6 February 2016 Started Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desion 1Q15 Complete SFP Instrumentation Delivery 4Q14 Complete Besin SFP Instrumentation Installation 2Q15 Complete Commissioninq of SFP Instrumentation 3Q15 Complete*

NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal)

Sprinq 2016 Not Started Interim Staff Evaluation Open ltem Status RAI-1: Please specifv for Level t how the identified location Complete. (Provided in

Attachment L-16-003 Page 3 of 6 Interim Staff Evaluation Open ltem Status represents the higher of the two points described in the NEI 12-02 guidance for this level.

February 2014 status report.)

RAI-2: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3, datum points.

Complete. (Provided in February 2014 status report.)

RAI-3: 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.

Complete. (Provided in February 2014 status report.)

RAI-4: Please provide the following:

(a) The design criteria that will be used to estimate the total loading on the mounting device(s),

including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other etfects that could accompany such seismic forces.

(b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

(c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assemblv.

Complete. (Provided in February 2014 status report with exception of 4b schematic.

4b schematic posted on ePortal.)

RAI-S: For RAI 4(a) above, please provide the results of 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 accompanv such seismic forces.

Complete. (Response posted on ePortal.)

RAI-6: 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.

Complete. (Provided in February 2014 status report.)

RAI-7: Please provide the following:

(a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BDB ambient temperature,

humidity, shock, vibration, and radiation conditions.

(b) A description of the testinq and/or analvses that will be Complete. (Response posted on ePortal.)

Attachment L-16-003 Page 4 of 6 Interim Staff Evaluation Open ltem Status 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.

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

RAI-8: For RAI 7 above, please provide the results from the selected

methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

Complete. (Response posted on ePortal.)

RAI-9: Please provide the following:

(a) A description of the manner the two channels of the proposed level measurement system meet the independence requirement to

minimize, to the extent pacticable, the potential for a common cause event to adversely affect both channels.

(b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices.

and the independence of the displavs.

Complete. (Provided in February 2014 status report.)

RAI-10: Please provide the following:

(a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

(b) 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 availabilitv is reasonably assured.

Complete. (Provided RAI-10a response in February 2014 status report. Response to RAI-10b posted on ePortal.)

RAI-1 1. Please provide the following:

(a) An estimate of the expected instrument channel accuracy performance (e.9., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature,

humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

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

Complete. (Response posted on ePortal.)

RAI-12: Please provide the following:

(a) A description of the capability and provisions the proposed level Complete. (Response posted on ePortal.)

Attachment L-16-003 Page 5 of 6 7 Potential Interim Staff Evaluation lmpacts There are no potential impacts to the ISE identified forthis reporting period.

Interim Staff Evaluation Open ltem Status sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

(b) A description of the testing and calibration necessary to enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

(c) A description of the calibration tests and functional checks processes to be performed, and their frequency. Discuss the steps to be taken to ensure these surveillances will be incorporated into the plant surveillance program.

(d) A description of the preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

RAI-13: 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 SFP instrumentation.

The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

Complete. (Response posted on ePortal.)

RAI-14: Please provide the following:

(a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

(b) A description of the approach and process to be used by the licensee to follow guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels.

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

Complete. (Response posted on ePortal.)

RAI-15: Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration beinq maintained at its desiqn accuracv.

Complete. (Response posted on ePortal.)

Attachment L-16-003 Page 6 of 6 I

References The following references support the updates to the OIP described in this attachment.

FirstEnergy Nuclear Operating Company's (FENOC's)

Overall Integrated Plan in

Response

to March 12, 2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool lnstrumentation (Order Number EA-1 2-051), dated Febru ary 27, 2013.

Nucfear Regulatory Commission (NRC) Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.

Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for lmplementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated December 11, 2013.

NRC Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051, dated March 26,2014.

1.

2.

3.

4.