NL-13-1460, Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
| ML13199A182 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/17/2013 |
| From: | Pierce C Southern Co, Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-12-051, NL-13-1460 | |
| Download: ML13199A182 (20) | |
Text
C. R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.
40 Invemess Center Parkway Post Office Box 1295 Birming ham. AL 35242 Tel 205.992.7872 Fax 205.992.760 1 July 17, 2013 Docket Nos.: 50-424 NL-13-1460 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Ladies and Gentlemen:
By letter dated February 27.2013 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13059A386). Southern Nuclear Operating Company (SNC) submitted its Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation at the Vogtle Electric Generating Plant (VEGP) in accordance with Order Number EA-12-051. Subsequently, by letter dated June 18.2013 (ADAMS Accession Number ML13157A176), the Nuclear Regulatory Commission (NRC) submitted a Request for Additional Information (RAI) to enable completion of the review. to this letter contains the SNC response to the RAI. If there is insufficient information to respond to an RAI, it is noted in the response and an anticipated date for supplying the information to the NRC is given . Enclosures.2 and 3 provide sketches in response to RAI 1b) and RAI 2, respectively.
This letter contains no NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.
U. S. Nuclear Regulatory Commission NL-13-1460 Page 2 Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
Respectfully submitted, Mr. C. R. Pierce Regulatory Affairs Director CRP/CLl\J/lac
- z
- ::::t;;r;'J~ me this JL day of M< ,2013.
Notary Public My commission expires: /1- d -l - "Z Q ( '3
Enclosures:
- 1. Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-0S1)
- 2. Sketch in Response to NRC RAI - 1b)
- 3. Sketches in Response to NRC RAI - 2 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. E. Tynan, Vice President - Vogtle Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Vogtle Mr. L. M. Cain, Senior Resident Inspector - Vogtle State of Georgia Mr. J. H. Turner, Environmental Director Protection Division
Vogtle Generating Plant - Units 1 2 Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Enclosure 1 Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Pool Instrumentation (Order Number 2-051) to NL-13-1460 SNC Response to Request for Additional Information OF REQUIRED MONITORING
" ..... "'w, in part, that
- 1. adequate support ncr<>tir,n of the normal fuel pool pool level when suction conservatively cooling low which is above elevation at the pool cooling suction is at approximately 21 11" (References 11,1 14 through 17).
- 2. adequate to provide substantial radiation shielding for a standing on spent fuel pool operating -Elevation 1/8" is approximately 10'-0" above 193'-91/8", highest point of the fuel for both Unit 1 and 2 (plus or minus 1 foot (Reference 10 Section 9.1 1 (Sh.
1 of References 11 &12).
- 3. where fuel covered 193'-91/8" is the nominal level of the highest fuel rack (Reference 10 Section 1 and 1.2-1 (Sh. 1 of and References 11 &1 NRC RAH Please provide the following:
Level 1, specify how identified location represents the HIGHER of the two points described in NEI 12-02 guidance for this level.
b) A labeled depicting the elevation of the proposed typical mounting arrangement for portions of instrument channel consisting of permanent measurement equipment fixed sensors stilling wells, mounting brackets). Indicate on this sketch the datum values Level 1, 2, and 3 as well as top of the Indicate on this sketch the portion of the level sensor measurement range is sensitive to measurement of the fuel pool level, with to the Level 1, Level 2, and 3
Level 1 is established as cooling low level set point of 21 , which is above elevation at the top of the fuel pool cooling suction that is at approximately 214'-11". Two trains Unit 1 Unit 2 spent pool cooling water.
When adjusted for saturated steam conditions, pool level needed to meet the NPSH required is for Train A 9'- 6" for B but only one train is for operation. the two described in 12-02 for of NPSH for VEGP Spent Poolare214'-11"and21 the of the two is214'-11".
However, VEGP conservatively selects Level 1 as 217'-0" since it is set for the Cooling system.
E1 - 1 to NL-1 460 SNC Response to RAI-1b) provides a sketch that depicts an elevation of Unit 1 2 The depicts the datum representing 1, 2, Level 3, as well as the top of the rack. Per NEI 12-02, 3 corresponds nominally (i.e., 1 foot) to the highest point of any rack in spent fuel pool. of the elevation that is shown on the sketch is a nominal value that varies depending upon the fuel assembly type and fuel bundle attachments. The sensor sensitive measurement range will span from a minimum of 3 above the SFP level setpoint to 3 inches above the top of the fuel pool rack.
3.0 INSTRUMENTATION DESIGN FEATURES 3.2 Arrangement The alP states, in part, that level probes will be installed from each other in the SFP. Both and new barriers will be to provide a level of protection for the the refueling floor from falling missiles generated by the event.
Please provide a clearly labeled sketch or marked-up plant drawing of the plan view the SFP area, depicting the SFP inside dimensions, the planned locations/placement the primary and back-up sensor and mounting brackets, the proposed routing of the that will extend from sensors toward location of read-out/display device.
3 depicts a section of marked up plant drawings AX2D09A011 and AX2D09A012. attachment shows a plan view of the SFP area unit. The drawings show inside dimensions for the and the anticipated locations the level sensors and mounting brackets by the circle inside the box).
There is no designated primary or backup sensor as both serve an equal purpose.
routing of instrument from sensors to the display device will determined a for the display unit been finalized. SNC intends to provide area cable routing information in the February 4 Overall Integrated Plan 6 month update.
3.3 Mounting alP states, in part, that NEI 12-02 Mounting, the new equipment will mounted to maintain the current of the Spent Fuel Pool which is (Reference 1 Thus, the new equipment will seismically qualified to addition, the mounting of the primary backup components throughout
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Enclosure 1 to NL-13-1460 plant will the criteria of the structure it will be routed through or attached to (refer to Qualification below relating to cable and installation criteria).
NRC RAI-3 provide following:
a) criteria that will be used to estimate the including weight dynamic Describe methodology that will be used to estimate the loading, inclusive of design maximum seismic loads the hydrodynamic loads could result pool sloshing or other that could such forces.
b) A description of the manner in which level sensor stilling well, if appropriate) will attached to refueling floor and/or other support structures each point of of the assembly. in a schematic the portions of the level sensor that will serve as of attachment for mechanical/mounting or electrical c) of manner by which mechanical connections will the instrument to permanent structures so as to support the level sensor assembly.
The methodology that will used to total for the mounting will be based upon the seismic analytical methods test results performed in rvvwrl!:.nl"'>o. with I 344. Computational Fluid (CFD) will be performed to estimate the total hydrodynamic total loading on the mounting devices would include static weight, seismic, hydrodynamic, other applicable loads in accordance with the Plant Vogtle design criteria. The detailed design will be contained in the completed mount documentation package. Sloshing will be addressed by the vendor's methods, typically by resultant by an ac(~eotao percentage.
SNC Response to RAI-3b)
Details of the level sensor stilling well mounting design will be determined the SFP mechanical and requirements. walk down activities have recently been and the activities with sensor mounts began in June 2013. Completion and of the design is currently scheduled prior to February 4 Overall Plan 6 month update. SNC to provide sensor mounting design information in the February 2014 Integrated Plan 6-month update.
E1 - 3
1 to NL-13-1460 SNC Response to RAI-3c) manner by which mechanical will attach the level instrument to SFP structures so as to support the level sensor assembly would determined by SFP mechanical design and requirements. walk down activities recently been performed and the design associated with the manner by which the mechanical connection will level instrument to permanent structures began in June 1 These details will designed in accordance with Plant Vogtle design criteria. Completion and acceptance of the design is currently scheduled prior to the February 4 Overall 6 month intends to provide specific sensor mounting design information in the February 2014 Overall Plan 6 month 3.4 Qualification The OIP in part, that values to use shock and vibration qualification will phase of implementation using Design nTI"'I,rrn.:lT.r\n Components of instrument in the area for shock and using one or more of following methods (note
.tto,yor,t methods may for the various sub components of the primary and back-Up instrument channels): ..
For impact on instrument channel components required after a seismic event for installed components, the following measures will be used to verify that design and installation is adequate. Applicable components of instrument channels are by the manufacturer (or otherwise tested) for at levels commensurate with those of basis event in area channel use using one or more of the following methods (note methods may for the various sub of the primary back-up instrument Please following:
a) of the or combination methods which are to to demonstrate the reliability of the permanently installed equipment Beyond ambient temperature, humidity, shock, vibration, and radiation conditions.
b) A description of the and/or analyses that will conducted to provide assurance that the equipment will perform reliably worst-case basis loading at where the will a discussion reliability as it applies to level sensor mounted in the area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the information from the level sensor to the plant or emergency responders.
E1 - 4
1 to NL-1 460 c) Please provide a description of the method or combination of methods that will be used confirm the reliability of the permanently installed equipment that, following a instrument will its accuracy.
Two independent guided wave radar instrumentation systems will the monitoring. will be purchased as operate under normal and Design required by NRC Order 2-051 and the guidance of NEI 1 The equipment will be qualified seismically and environmentally (IEEE 323). The "in-pool" components and transmitter will be qualified to ANSI/ISA-S71 Class SA1 (Shock) and ANSI/ISA-S71.03 Class (Vibration). qualifications will performed to bounding conditions. part of the design process, the qualification for the eqUipment will be by SNC for location VogUe to ensure that the conditions the plant conditions.
instrument/equipment qualification calculation will be prepared to document the radiation as a function of the water covered on of spent fuel during normal operation and conditions.
and will through use of conservative design margins and a seismic qualification that will confirm accurate instrumentation performance following a seismic event. However, specific method or combination of methods that would be used to confirm the reliability of the permanently installed equipment has yet been determined by the instrumentation manufacturer.
3.5 Independence The OIP "',.....v.;>, in part, that primary and backup instrument are of the same technology, are permanently installed, separated by or barriers, and independent supplies from different buses/switchgear.
Please provide the following:
a) A description of how two channels of proposed level measurement CUC'Tom meet this requirement so potential for a common cause event to adversely affect channels is the extent oralcth:;al.
b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be and installed to address independence through the application and selection independent power sources, the use of physical and spatial separation, independence of E1 - 5
Enclosure 1 to NL-13-1460 signals sent to the location(s) of the readout Q\J't~QC and the independence of the displays.
The measurement CHe""",., for will of two identical guided wave radar channels. The SNC vendor intends to use the following qualification
- environmentally qualified for the location per I 323-2003
- for Seismic Category I 344-2004
- qualified for per ANSI/ISA-S71.03 Class
- qualified vibration per ANSIIISA-S71.03 VC2
- EMI/RFI qualified per 1.180 In addition to design requirements, providing sufficient channel separation, by distance protective barriers will minimize the that a common cause event which adversely affects both channels would occur. As noted in SNC NL-13-0173, "Cabling for power supplies and indications for each channel will be separated for protection (falling debris) and in separate conduits from cabling for the other channel".
level measurement system will be designed and installed to achieve physical and
"",.,,,,,."'-. separation and electrical Independent sources will provided from separate 120V Distribution for both level monitoring channels for Vogtle Unit. Dedicated conduit will be to provide physical separation between probes and transmitters. From the transmitters to the readouts the will in accordance with Plant Vogtle design criteria, RG 1 384. Different in the SFP room wall and walls will for the level signals from the sensors to the transmitters and to readout devices, which will be mounted in separate O"'.. . ,I"\C, 3.6 Power supplies 01 P states, in part, that Each channel will normally be powered from independent (different buses/switchgear) 120V AC power sources and will have a dedicated battery backup. The backup will dedicated to channel, should have the capability of automatically switching and operating on backup and will have manual switching as a minimum. A minimum battery life of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be provided to allow for power from portable equipment (refer to attachment 2 for a typical sketch). Refer to Safety Function Support section of SNC Plan 28, submittal for Order EA-1 for details on strategy from portable FLEX
-6
Enclosure 1 to NL-1 1460 a) a description of the normal electrical AC power sources and capacities for the primary and backup channels.
b) If the level measurement channels are to be powered through a battery system directly or through an Uninterruptible Power Supply (UPS), provide the criteria that will applied to battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of BOB event the minimum duration needed, consistent with the plant mitigation strategies for beyond-design basis external events (Order EA-12-049).
Normal electrical power will provided by different sources non-safety related AC Distribution System for each level measurement channel.
SNC Response to RAI-6b)
Each level measurement will be powered from a dedicated Uninterruptible Power (UPS) and battery system supplied by the vendor. Each battery and U will be with by the to the load at respective level monitoring channel a minimum one day hours) under Station Blackout (SBO) conditions.
The sizing criteria will based on the ambient conditions during BOB/SBO, for the location(s) for the UPS/battery. In the detailed design, vendor will provide the basis criteria which will used for battery, battery charger, and This design basis sizing criteria will reviewed for margin and to ensure that each channel will available to run reliably and continuously following the onset Beyond Design (BOB) event for minimum duration needed, consistent with plant FLEX program plans.
Accuracy The OIP in that designed such that they will maintain their design accuracy without hv..... '.ir.n following a power interruption or change in power source. plans for the instrument design accuracy to within +/- 1 inch, or as as reasonably achievable, over the range for expected environmental and process conditions. Accuracy will consider SFP event conditions, , saturated water, steam environment, or concentrated borated water.
Additionally, instrument accuracy GWR technology will be sufficient to allow personnel to determine when the level the level of indicating range 1, 2 and without conflicting or ambiguous indication. The accuracy will within the requirements Figure 1 of 1
E1 - 7
1 to NL-1 NRC RAI-7 Please provide the following:
a) An estimate expected instrument channel accuracy performance (e.g., in under both normal SFP conditions (approximately Level 1 or and b) at conditions, radiation, temperature, humidity, post-and postshock conditions) that would be if the SFP were at the Level 2 and Level 3 datum points.
b) A description of the methodology that will for determining the maximum allowed deviation from the instrument channel design accuracy that will rnrll'-'\.Icn under operating conditions as an criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition accuracy.
SNC Response to RAI-7a)
The level sensor is designed to operate under the worst case postulated BDB conditions. The accuracy of the system will be +/-3 inches of span) under all conditions which includes both normal SFP conditions and worst case conditions and the level values at Level 1, and Level 3 datum points.
methodology will consist of test components provided by vendor that will simulate a signal the transmitter and performing a calibration on an annual basis in accordance with plant procedures which will utilize vendor recommendations. The calibration will certify the equipment end-to-end accuracy of 1 inch. A deviation of more than 2 inches between channel displays and/or any other pool monitoring device constitutes reason to recalibrate all monitoring channels.
3.B Testing The alP in part, Instrument channel design will provide for routine testing and calibration consistent with Order EA-1 and the in NEI 1
.. plans for the to facilitate in-situ testing and/or calibration of the or installed (fixed) sensors.
.. SNC plans for the design to facilitate the microprocessor based channel features to capable of testing while mounted in the pool.
.. work control will be to control maintenance and (e.g., Maintenance (PM) Program, Surveillance Program, Contracts, or work orders).
.. Other testing and calibration requirements are located in Program Controls testing section below.
E1 - 8
Enclosure 1 to NL-1 1460 NRC RAI-8 Please provide following:
a) A of the capability and provisions the proposed sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to tested in-situ.
b) of how such testing calibration will enable of channel checks of independent channel and other level c) functional performed at which conducted. Describe how calibration tests will performed, and the at which they will Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.
d) A what preventative tasks are required to performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably their functions when neE~aea.
Guided wave measurement determine pool depth by the time of flight of a pulse from the transmitter to the water interface and back to the transmitter's A calibration device, provided by the manufacturer, incorporates time of flight equal to various pool The device is to transmitter and is for each test procedures will to enable A post-calibration level instruments will be completed plant procedures. permanently-installed indication is provided by a ruled scale mounted on the side of the SFP. two channels from the instruments may at cross-checked against this indication. An of the output from level instrumentation will used when determining the frequency of calibration activities on SFP level instruments.
The design system in June 2013, with completion and plant acceptance of the scheduled for February of 4.
Following of design, will start being developed. intends to provide the requested detail in the August 2014 Overall Integrated Plan 6 month update.
9
1 to NL-1 3.9 Display 01 P states, in part, that Primary and backup indication will Room, at alternate shutdown panel, or appropriate and location NEI 12-06) that complies with the NEI 1 characteristics. If multiple display locations are powered from the instrument loop, then the in NEI 1 regarding multiple displays will followed (refer to attachment 2 for a typical sketch).
NRC RAI-9 Please provide the following:
a) specific 1("I"""'flr,n for the primary and backup instrument channel display.
b) If the primary or backup display location is other main control room, then provide justification for accessibility to including primary route evaluation, habitability at display location(s), continual resource availability for personnel responsible to read displays, provisions for communications with decision the various SFP down scenarios and external events.
c) reasons justifying why the locations selected the information from instruments to conljiidered "promptly ""'-",v,",""""-' to various drain-down scenarios and external events.
SNC Response to RAI-9al, 9bl, & 9c)
The phase of the 2013, with the and plant organization ",,..,'on,Tl:Ir\,..o for intends to provide the requested information in February 20146 month Overall Integrated Plan 4.0 PROGRAM FEATURES 4.2 Procedures The OIP in part, that Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation, and abnormal response issues with the new SFP instrumentation consistent with 12-02.
will address a to ensure water level addition is initiated at an appropriate time consistent with implementation of NEI 12-06, and Flexible Coping (FLEX) Implementation Guide 5 and 7).
E1 - 10 to I\lL-13-1460 NRC RAI-10 Please provide a description of the standards, guidelines, and/or criteria that will be utilized to develop procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation.
SNC Response to RAI-10 Procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation will be developed in accordance with existing controlled station administrative and technical procedures that govern procedure development. These procedures ensure standardization of format and terminology and ease of use along with assurance of a consistent level of quality.
4.3 Testing and Calibration The 01 P states, in part, that Processes will 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.
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. Out of service time as identified in NEI 12 02 will be incorporated consistent with the programmatic process used for compliance with NRC Order EA-12-049 (Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events).
NRC RAI-11 Please provide the following:
a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration,*
and maintenance will be conducted for the level measurement system and its supporting equipment.
b) A description of how the guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.
E1 - 11
Enclosure 1 to NL-1 1460 The maintenance and testing of the level instrumentation system will incorporated into the normal station surveillance and work control based on vendor recommendations for and testing. preventive test and calibration program will developed consistent with the vendor's recommendations.
The design phase of began in June of 2013, with the design completion and plant organization acceptance the design scheduled for February 2014.
Following the of the will start developed. SNC intends to provide the description of for ensuring necessary channel checks, functional tests, periodic calibration, and maintenance to for the measurement system its supporting equipment in the August 2014 Integrated Plan 6 month update.
guidance in NEI 12-02, 1, states:
primary or instrument channel can out of testing, maintenance and/or calibration for up to 90 days provided the other channel is functional. Additionally, compensatory must if the instrumentation channel is not expected to be restored or is not restored within 90 days. If both channels become non-functioning then initiate within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels of instrumentation and implement compensatory (e.g., use of alternate suitable equipment or supplemental within hours.
In event a channel of SPF instrumentation is out of any reason, a condition report will be entered to restore the channel to service within 90 days.
Functionality the other channel will confirmed surveillance measures within following 7 and every 90 days thereafter until non-functioning channel is to If both are to non-functional, SNC will initiate appropriate 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. Procedures will be developed following guidance NEI 1 including the with compensatory actions, after issuance of the design. SNC intends to provide detail in the August 4 Overall Integrated 6 month
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Vogtle Electric Generating Plant - Units 1 and 2 Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-0S1)
Enclosure 2 Sketch in Response to NRC RAI - 1b) to NL-13-1460 ATTACHMENT 1 SKETCH IN RESPONSE TO RAI ITEM l.b EL. 220 '-6" TOP OF SFP CURB ,.........
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Vogtle Electric Generating Plant - Units 1 and 2 Southern Nuclear Operating Company Response to the Request for Additional Information Overall Integrated Enclosure 3 Sketches in Response to NRC RAI - 2
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