NRC 2015-0039, Response to Request for Information Related to Full Compliance Report for the March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Response to Request for Information Related to Full Compliance Report for the March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ML15211A533
Person / Time
Site:	Point Beach
Issue date:	07/30/2015
From:	Mccartney E Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NRC 2015-0039
Download: ML15211A533 (8)

Text

July 30, 2015 NRC 2015-0039 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Docket 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energy Point Beach, LLC, Response to Request for Information Related to Full Compliance Report for the March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

References:

(1) U.S. Nuclear Regulatory Commission, Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately)," dated March 12, 2012 [ML12056A044]

(2) NextEra Energy Point Beach, LLC's Full Compliance Report for the March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated December 19, 2014

[ML14353A047]

(3) NRC Electronic Mail to NextEra Energy Point Beach, LLC, Point Beach -Request for Additional Information RE Integrated Plan for Reliable SFP Instrumentation (Order EA-12-051), dated July 2, 2015 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order to NextEra Energy Point Beach, LLC (NextEra) (Reference 1). Reference 1 was immediately effective and directed NextEra to install reliable spent fuel pool (SFP) level instrumentation. By letter dated December 19, 2014, NextEra notified the NRC that full compliance with Order EA-12-051 had been achieved for Point Beach (Reference 2).

An onsite audit of the diverse and flexible coping strategies (FLEX) was conducted at Point Beach by NRC staff during the week of June 8- 12, 2015. During the audit, the SFP level instrumentation and associated documents were reviewed. Request for Additional Information 14 (RAI-14) was generated (Reference 3). The NRC audit team also requested additional information related to the responses previously provided for RAI-8, RAI-11 and RAI-12 to aid their review. The enclosure to this letter provides the response to RAI-14 and additional information related to RAI-8, RAI-11 and RAI-12.

This letter contains no new regulatory commitments or revisions to existing commitments.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 If you have any questions regarding the enclosed information, please contact Mr. Bryan Woyak, Licensing Manager, at {920) 755-7599.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 30, 2015.

Very truly yours, NextEra Energy Point Beach, LLC Eric McCartney Site Vice President Enclosure cc: Director, Office of Nuclear Reactor Regulation Administrator, Region Ill, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Ms. Lisa M. Regner, NRR/JLD/PMB, USNRC Mr. Blake A. Purnell, NRR/JLD/PMB, USNRC Mr. Steven R. Jones, NRR/DSS/SBPB, USNRC

ENCLOSURE NEXTERA ENERGY POINT BEACH UNITS 1 & 2 RESPONSE TO REQUEST FOR INFORMATION RELATED TO THE FULL COMPLIANCE REPORT FOR THE MARCH 12, 2012 COMMISSION ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (ORDER EA-12-051)

An onsite audit of the diverse and flexible coping strategies (FLEX) was conducted at Point Beach by NRC staff during the week of June 8 - 12, 2015. During the audit, the spent fuel pool (SFP) level instrumentation and associated documents were reviewed. Request for Additional Information 14 (RAI-14) was generated. The NRC audit team also requested additional information related to the responses previously provided for RAI-8, RAI-11 and RAI-12 to aid their review. This enclosure provides the response to RAI-14 and additional information related to RAI-8, RAI-11 and RAI-12.

REQUEST FOR INFORMATION (RAI)

RAI-14: Please provide an assessment of potential susceptibilities of electromagnetic interference (EM/) in the areas where the spent fuel pool (SFP) level instrumentation is located and how those susceptibilities will be mitigated.

NextEra Response to RAI-14 Point Beach installed the Westinghouse Guided Wave Radar Spent Fuel Pool Instrumentation System. Westinghouse performed electromagnetic compatibility (EMC) qualification of the system.

Westinghouse Report EQ-QR-269, documents the test results for the susceptibilities of the equipment and the modifications required to meet criterion B or A for the various testing performed. Point Beach reviewed the susceptibilities of the equipment and purchased the appropriate modifications to mitigate them based on the locations of the plan where it would be installed as noted below.

As noted in the response to RAI-1 0 from Letter NRC 2014-0077, the location of the equipment was chosen for its access routes and proximity to a designated watch station. Administrative controls via signs are in place to preclude the use of radios with the control panel doors open during an ELAP.

Point Beach Engineering Change (EC) 276803 installed the SFP instrumentation. The equipment and installation requirements were designed to ensure the equipment will operate reliably with consideration to electromagnetic compatibility of the system. The EC states:

"Westinghouse position is the standard base product meets criterion B and any additional modifications required to meet [criterion] A could be purchased or installed by the sites based on the testing reports. Criterion A equipment shall continue to operate during and after the event with no degradation or Joss of function. Criterion B only requires the equipment to operate following the event. NextEra chose to purchase most of the criterion A modifications. This includes routing the cable in dedicated conduit, installing an enclosure at the launch plate to house the coupler, 90 degree connector and coax cable, an enclosure to house the level sensor head and a separate enclosure at the level display to house a second surge suppressor and breaker. This second enclosure is where the main power feed connects thus the signal can be filtered prior to entering the main level display enclosure."

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Radio frequency interference (RFI) testing was conducted by Point Beach as a post-installation test.

The test included keying a radio at specified distances from the launch plate area, transmitter housing, and the electronics cabinet. All tests performed had satisfactory results with no signal disturbance.

Although the vendor and onsite test results were found to be satisfactory, to ensure personnel awareness of the instrumentation's radio frequency sensitivity, work orders were initiated to mark the areas around the indicator cabinets as "RFI sensitive."

ADDITIONAL INFORMATION RELATED TO PRIOR RAI RESPONSES RAI-8: RAI-8 requested information regarding the SFP level instrument channel accuracy. The response to the RAI was submitted to the electronic portal and was stated in the Enclosure to the SFP Full Compliance Report, dated December 19, 2014, Table 1.

During the Point Beach onsite FLEX Audit the week of June 8- 12, 2015, the auditor questioned why the Point Beach Auxiliary Building Log channel check specified an allowed maximum deviation of+/- 6 inches when the vendor documentation indicates accuracy to +/- 3 inches. Accuracy greater than +/- 3 inches could be indicative of a nonfunctioning instrument.

NextEra Additional Information Related to RAI-8 Vendor documents WNA-CN-00301 and WNA-DS-02957 -GEN describe the SFP level instrument channel accuracy under both (a) normal SFP level conditions, and (b) Beyond Design Basis (BOB) conditions that would be present if SFP level were at Level 2 and Level 3 datum points. In accordance with the vendor documentation, each instrument channel will be accurate to within +/- 3 inches during normal spent fuel pool level conditions and will retain this accuracy after BOB conditions. Point Beach did not install remote displays, consequently, the instrument design is within the +/- 3 inches accuracy reported by the vendor.

Point Beach originally specified +/- 6 inches for accuracy of the SFP level instrumentation. The +/- 6 inch value was chosen to provide margin to the Order requirement of+/- 1 foot. The out of service requirement stated in the Operations SFP level check in the Auxiliary Building Log was based on the original Point Beach specification (+/- 0.5 feet) and not the vendor's stated accuracy.

Consequently, a Condition Report was initiated and a revision will be made to the Auxiliary Building Log to perform a comparison to the opposite channel with +/- 3 inch deviation allowed. Additionally, the Log activity will perform a comparison to the local indicator, LC-00634, with a more stringent deviation allowance.

A history review was performed for the wide range SFP level instrumentation and determined that all channel verification readings were within +/- 3 inches.

No discrepancy was identified in the instrument calibration procedure.

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RAI-11: RAI-11 requested a list of procedures addressing normal and abnormal response, calibration, test, maintenance and inspection. A brief description of the technical objectives of each procedure was requested. This RAI was addressed in the Second Six-Month Status Report dated February 28, 2014. At the time of the response, procedure development was still in progress.

NextEra Additional Information Related to RAI-11 The following tables provide a list of the operating, programmatic, maintenance and preventive maintenance procedures, a summary of their technical objectives, and the specified frequency of the preventive maintenance procedures.

OPERATING PROCEDURES:

PROCEDURE NO./

TITLE TECHNICAL OBJECTIVE CURRENT REVISION 1-SOP-208Y-L04 Unit 1 Vital Train 8 Provides guidance for removing normal Revision 8 Lighting Panels power to the wide range level indicator 2-SOP-208Y-L03 Unit 2 Vital Train A Provides guidance for removing normal Revision 9 Lighting Panels power to the wide range level indicator AOP-8F Loss of Spent Fuel Pool Entered in an abnormal condition for a loss Revision 20 Cooling of SFP cooling. Provides guidance for establishing cooling and makeup to the SFP.

FSG-11 Alternate SFP Makeup Entered from AOP-8F when in a beyond Draft and Cooling design basis event and SFP makeup is required.

Form PBF-2031 Auxiliary Building Log Daily surveillance (channel check) of SFP Revision 107 wide range level.

PROGRAMMA TIC PROCEDURES:

DOCUMENT NO./

TITLE TECHNICAL OBJECTIVE CURRENT REVISION OM 3.42 Control of Wide-Range Provides programmatic requirements for Revision 0 SFP Level Determination the SFP wide range level indicators and actions to take if one or both instruments are out of service.

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MAINTENANCE PROCEDURES:

PROCEDURE NO./

TITLE TECHNICAL OBJECTIVE CURRENT REVISION ICP 03.017 Calibration of SFP Level Functional check and calibration of the Revision 0 Instrumentation Systems SFP wide range level indicators.

PREVENTIVE MAINTENANCE PROCEDURES:

Preventive maintenance activities are being developed in accordance with vendor technical manual WNA-G0-00127-GEN, Revision 3, and vendor calibration procedure WNA- TP-04709-GEN, Revision 4.

WESTINGHOUSE POINT BEACH DOCUMENT TECHNICAL OBJECTIVE ESTABLISHED RECOMMENDED FREQUENCY FREQUENCY ICP 03.017 Functional Check Within 60 days One year, with a Revision 0 of a planned Spring and Fall refueling outage, call-up to meet the Model Work Order considering 60 day refueling 40345581 normal testing outage Residual Boron Buildup scheduling requirement.

Check allowances (e.g.,

(procedure change request is 25%), but not pending to add this objective more than once to ICP 03.017 or the per 12 months.

associated Model Work Order)

Model Work Order Battery Replacement 3 years 3 years 40345840 (in planning status)

Model Work Order Level Sensor Replacement 7 years 7 years 40345843 (in planning status)

RAI-12a, b, c: RAI-12 requested the following information:

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 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.

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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.

The response to RAI-12a, b, c was provided in the Second Sixth Month Update on February 28, 2014. At the time of the response, procedure development was still in progress.

NextEra Additional Information Related to RAI-12a Performance of routine maintenance and testing will occur as prescribed in maintenance procedure ICP 03.017, and the preventive maintenance Model Work Orders described in RAI-11 response, above.

Operations Manual (OM) 3.42, Wide-Range Spent Fuel Pool Level Instrumentation, was established to ensure the wide range SFP level instrumentation is properly maintained and tested.

Refer to RAI-11 for the description of channel checks, functional tests, periodic calibration and maintenance.

NextEra Additional Information Related to RAI-12b Operations Manual (OM) 3.42 was established to provide programmatic requirements for the SFP wide range level indicators, including actions to take if one or both instruments are out of service.

NEI 12-02 is a basis document for this Operations Manual.

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CONDITION NEI12-02 REV. 1 GUIDANCE OM 3.42 GUIDANCE One Channel Wide

• The primary or back-up

• Initiate actions to restore channel to Range SFP Level instrument channel can be out of functional status within 90 days.

Instrumentation Out service for testing, maintenance

• Initiate an evaluation in accordance of Service and/or calibration for up to 90 with the Corrective Action Program.

days provided the other channel The evaluation shall determine is functional. compensatory actions if a second

• Compensatory actions must be channel becomes inoperable. The taken if the instrumentation evaluation shall include a planned channel is not expected to be schedule for restoring the restored or is not restored within instrument channel(s) to functional 90 days. status.

Two Channels Wide

• Initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to

• Initiate action to restore at least one Range SFP Level restore one of the channels of channel to functional status within Instrumentation Out instrumentation. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

of Service

• Implement compensatory actions

• Initiate compensatory actions for (e.g., use of alternate suitable monitoring wide range SFP level equipment or supplemental within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Initiate an personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. evaluation in accordance with the Corrective Action Program. The evaluation shall document compensatory actions taken or planned to be taken to implement an alternate method of monitoring and schedule required actions for restoring the instrumentation channel(s) to functional status.

A Condition Report was issued on June 9, 2015, to review the Point Beach and NextEra fleet procedures for the wide range SFP level instrumentation to ensure consistent implementation of out of service requirements following the guidance of NEI 12-02, Revision 1. As a result of the review, OM 3.42 will be revised to bring it into alignment with NEI 12-02 out of service guidance.

NextEra Additional Information Related to RAI-12c Compensatory measures are not prescribed in advance. Upon identifying a channel out of service, an evaluation will be performed in accordance with the Corrective Action Program. The evaluation will identify the necessary compensatory measures to be taken, including a planned schedule for restoring the instrument channel(s) to functional status.

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