RNP-RA/15-0040, Completion of Required Actions for NRC Order EA-12-051 with Regard to Reliable Spent Fuel Pool Level Instrumentation
| ML15187A229 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/27/2015 |
| From: | Glover R Duke Energy Corp, Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RNP-RA/15-0040 | |
| Download: ML15187A229 (32) | |
Text
U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 2 of7 GENERIC DESIGN INFORMATION TEMPLATE FOR RNP I Vendor Design Reference Additional Licensee Evaluation Topic I Parameter Summary I Document# I Comments Test or Analysis Results EC 89580, Attachment D -
Design I Customer technical requirements I NCP-Z-0006, Rev. 0- SFP Wide EA-12-051, The vendor instrumentation design was reviewed and determined to ad equately 1 1 specification for SFPLI Range Level Instrumentation N/A Specification 1 NEI-12-02 meet the specification requirements.
Remote Level Sensors.pdf Qualification is based on a Qualification analyses Doc.
combination of tests and analyses or similarity as described below.
I 51-9202556-005 Test and analyses results meet requirements of The vendor qualification documentation was reviewed and concluded to EA-12-051 , 1.4 adequately demonstrate the instrumentation could reliably function in its installed 2 Test Strategy I Qualification tests and analyses 32-9221237- NEI-12-02, 3.4 EA 21-051 , JLD-ISG-2012-03, and NEI12-02 environment(s) during a postulated Beyond Design Bases External Event are summarized in qualification 003_Calc_Qualification for a Rev. 1-(BDBEE).
analyses report 51-9202556-005. Waveguide Support and Horn End Assembly Temperature rating of Power Control Panel Environmental 149°F allowing for 9°F rise above ambient. The primary channel instrumentation electronics are located outside the SFP qualification for Qualification Analyses Doc.
area. The vendor instrumentation design temperature, humidity, and dose limits 3 electronics Temperature, humidity and dose 51-9202556-005 Section 2.3 NEI 12-02, 3.4 NEMA 4X enclosure prevents moisture bound the expected environmental conditions during a postulated BDBEE.
enclosure with intrusion.
display 3 Radiation withstand analyzed to 1x1 0 Rads Measurement capability through Initial testing (without horn cover) demonstrated saturated steam and smoke.
successful measurement capability through Testing performed to demonstrate steam and smoke. Subsequent testing of the the radar horn cover was effective radar horn and cover demonstrated adequate Environmental at preventing moisture intrusion Qualification Analyses Doc.
operation during sustained simulated SFP boiling The radar horn cover qualification testing adequately demonstrated acceptable testing for level within the horn and wave guide 51-9202556-005, Section 2.3, conditions, and that the horn cover was effective operation during exposure to simulated SFP boiling conditions.
sensor pipe. 2.4, 2.5, 2.7, Appendix Band in preventing moisture intrusion within the horn components in supporting references EA-12-051, 1.4 4 and wave guide pipe. The horn cover adhesive manufacturer radiation test data adequately SFP area- Radar horn cover (fused silica 66-9200846-002 NEI 12-02, 3.4 demonstrated the adhesive would not experience unacceptable degradation for Saturated glass), metal waveguide pipe and 51-9220845-001 The horn cover adhesive is a silicone elastomer radiation exposure in excess of that expected for the postulated beyond design steam & horn are not susceptible to 51-9221032-000 manufactured by Down Corning (Sylgard 170). bases event over the required mission time.
radiation radiation degradation. 66-9225632-000 The adhesive manufacturer radiation test data Manufacturer test data supports adequately demonstrates the adhesive would not acceptable radiation degradation experience unacceptable degradation for resistance for the radar horn 8 exposures up to 1.64 x1 0 Rads.
cover adhesive.
Qualification Analyses Doc.
51-9202556-005, Sections Environmental 2.3, 2.5, Appendix A and testing for level supporting references Sensor and indication are demonstrated to Temperature and humidity testing The level sensor electronic housing are located outside the SFP area. The sensor 38-9218218-000, withstand the manufacturer ratings 80°C (sensor) 5 and analysis of sensor and NEI 12-02, 3.4 vendor instrumentation design temperature, humidity, and dose limits bound the electronics 38-9218214-000, and 70°C (indication), 100% RH. Radiation indication 3 expected environmental conditions during a postulated BDBEE.
housing- USNRC Bulletin 79-01 B Table withstand analyzed to 1x10 Rads.
outside SFP C-1, Reg. Guide 1.209
U. S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 3 of7
- Vendor Design Reference Additional Licensee Evaluation Topic Parameter Summary Test or Analysis Results Document# Comments Thermal and radiation aging not applicable to metal waveguide in SFP area. The horn cover Radar horn cover (fused silica The glass and metallic instrumentation components located within the SFP area adhesive is a silicone elastomer manufactured glass), metal waveguide pipe and are not susceptible to aging due to thermal and/or radiation effects.
by Down Corning (Sylgard 170). The adhesive Thermal & horn are not susceptible to Qualification analyses Doc. manufacturer radiation test data adequately Radiation Aging radiation degradation. The horn cover adhesive manufacturer radiation test data adequately 51-9202556-005, Section 2.5 EA-12-051, 1.4 demonstrates the adhesive would not experience 6 - organic demonstrated the adhesive would not experience unacceptable degradation for 51-9221032-000 NEI12-02, 3.4 unacceptable degradation for exposures up to components in Horn cover adhesive manufacturer 6 radiation exposure in excess of that expected for the postulated bey?nd design 66-9225632-000 1.64 x10 Rads. The silicone adhesive is rated SFP area radiation test data and bases event over the required mission time. The horn cover adhes1ve to withstand temperatures extremes of -45 to temperature withstand temperature ratings are acceptable and readily bound the expected conditions for 200°C, which adequately bound the postulated specifications. the postulated beyond design bases event.
temperatures for sustained SFP boiling conditions.
SFPLI remote transmitter and AREVA Document No. 51 - Analyses based on operating experience Basis for Dose power control panel qualified to 9202556-005, Qualification concludes the electronics are not susceptible to A location specific dose calculation was performed for the remot~ electr?nics, 3
Requirement 1x1 0 Rads based on industry Analysis of VEGAPULS 62 ER degraded performance up to this dose threshold . which demonstrated the sensor total integrated dose (TID) over 1ts requ1red operating experience. Through Air Radar mission time is enveloped by the vendor instrumentation design limit of 1x1 03 51-9221032-000 The adhesive manufacturer radiation test data Rads.
7 Based on engineering judgment, 66-9225632-000 NEI12-02, 3.4 adequately demonstrates the adhesive would not the expected total integrated dose The horn cover adhesive manufacturer radiation test data adequately experience unacceptable degradation for demonstrated the adhesive would not experience unacceptable degradation for for the radar horn cover adhesive exposures up to 1.64 x1 06 Rads. radiation exposure in excess of that expected for the postulated beyond design 6
would not exceed 1 x1 0 Rads bases event over the required mission time.
over the required mission time for the instrumentation.
Qualification analyses Doc.
Seismic withstand capability of 51-9202556-005, Section 2.1, VEGAPULS 62 ER sensor , indicators, power VEGAPULS 62 ER sensor , The vendor instrumentation seismic testing adequately demonstrates the Seismic Appendix D and supporting control panel , mounting brackets, waveguide 8 indicators, power control panel, NEI 1-02, 3.4 equipment is capable of reliably operating during a seismic event.
Qualification references pipe are seismically qualified toRRS levels from mounting brackets, waveguide 11-9203036-000, EPRI TR-1 07330 pipe 174-9213558-006 Allowable seismic combined Sloshing NRC RAis indicated a SFP with hydrodynamic loading seismic induced sloshing analyses that the horn mounting can is required . If wave impact is withstand is analyzed in 32-predicted, then the hydrodynamic 9221237-003.
forces should be included in the Predicted loading from impact Seismic induced sloshing analyses concluded mounting design loading and drag due to slosh is that wave impact on the horn end assembly is combinations. calculated in Attachment BH N/A predicted and the expected combined The vendor horn end mounting can withstand the expected seismic and 9
9221237- hydrodynamic loading caused by sloshing during a postulated BDBEE.
hydrodynamic and seismic forces are less than 003 Calc Qualification for a the allowable hydrodynamic and seismic forces .
Waveguide Support and Horn End Assembly. verification and sensitivity study to predict slosh phenomena is evaluated in Attachment AW, NAI-1809-004 Hydraulic Response Calc.
U. S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 4 of7 AREVA Doc. 51-9228351-Spent Fuel Pool 000, "Through Air Radar The vendor factory acceptance test demonstrated reliable operation of the SFP instrumentation Functionality testing was Spent Fuel Pool Level Testing demonstrated that the SFPLI met the level instrumentation under normal conditions and under various simulated test 10 system performed during the factory N/A Instrument (SFPLI) Factory specification functional requirements. conditions (e.g. steam exposure). The testing demonstrated the instrumentation functionality test acceptance test. See #16 Acceptance Test (FAT) met design accuracy and repeatability specifications.
procedure Report for H.B. Robinson" 11 Boron Build-Up Not applicable to Robinson N/A N/A N/A N/A Qualification analyses Doc.
51-9202556-005 and I supporting reference 174-9213558-006, Waveguide horns including the mounting are Calculations seismically qualified to EPRI TR-107330 or site-32-9208751-002, specific RRS.
32-9221237-003 The test and analyses of the horn cover and adhesive demonstrate adequate Test and analyses were 51-9221 032-000 seismic withstand capability.
Testing and analyses horn cover and adhesive performed for the horn cover and 66-9225632-000 support the components can tolerate horizontal Pool-side adhesive to demonstrate adequate 66-9225469-000 The vendor horn end assembly including the mounting can withstand the and vertical accelerations up to 1OOg and SFP 12 Bracket Seismic seismic withstand capability. NEI12-02, 3.4 expected seismic and hydrodynamic loading caused by sloshing during a sloshing loads up to 3.37 psi.
Analysis Sloshing analyses was postulated BDBEE.
Perform seismic induced sloshing performed by an alternate Seismic induced sloshing analyses concluded analyses to assess hydrodynamic vendor than the vendor whom that wave impact on the horn end assembly is wave force on the radar horn. supplied the radar level predicted and the expected combined instrumentation Predicted hydrodynamic and seismic forces are less than loading from impact and drag the allowable hydrodynamic and seismic forces.
due to slosh is calculated in Attachment AW- NAI-1809-004 Hydraulic Response Calc Qualification analyses Doc.
51-9202556-005, Section 2.1, Appendix D and supporting references Additional 11-9203036-002, Brackets EPRI TR-107330, Seismic withstand of sensor 174-9213558-006 Sensor brackets and electronic enclosure Sensor brackets and electronic enclosure are qualified analytically and by seismic (Sensor 13 brackets and electronic enclosure Calculations NEI 12-02, 3.4 mounting are seismically qualified to EPRI TR- testing to adequately demonstrates the equipment is capable of reliably operating Electronics and mounting 32-9208751-002, 107330 or site-specific RRS. after a seismic event.
Electronic Enclosure) 32-9221237-003 32-9221971-000 CPL-HBR2-S-001, Rev. 10, "Specifications for standard supports"
U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 5 of7 Sensor, displays, and power control panel have been tested and/or analyzed for shock and vibration.
The test parameter values provided in IEC Standards, IEC 60068-2-6 (vibration) and IEC 60068-2-27 (shock), tables are .
recommendations and not mandatory testmg levels. The test parameter values were selected to be consistent with previous shock and vibration testing performed on the VEGA supplied equipment. The test parameter values specified envelope the expected levels for the equipment installed location, du~ to_ the fact that the equipment is mounted to se1_sm1c st.ructure~
The shock and vibration testing performed for the SFP level ins~rument~tion .
within the plant. This approach 1s cons1s~ent_w1th adequately demonstrates the sensor and power control panel Will be reliable m the similar technology used in the same application installed design location.
at other installations.
Qualification Analysis Doc. 51-9202556-005, Sections 2.2 Seismic Qualification of the VEGAPULS 62 ER syst~m, i~cluding ~he _Power The vibration testing deviated from the IEC and supporting references Control Panels and VEGADIS 62 display is summanzed m the Se1sm1c Test Shock and vibration withstand 60068-2-6 recommended frequency range and MIL-S-901 D, Report. The system was qualified to an Areva supplied OBE and SSE_ eart~quake testing and analyses for sensor, displacement magnitude for large power plant MIL-STD-167-1 which bounds site SSE. A seismic technical review of the vendor qualification displays, power control panel equipment (TABLE C.2). In-lieu of the 10-55 Hz 38-9193058-000, report per AD-EG-ALL-1126 Attachment 3 ~as p_erformed. The re~ort al~~
and minimum displacement of 0.15 mm EN 60068-2-27, contains a discussion of environmental qualification of the system m add1t1?n to Shock & Test and analyses were recommended in TABLE C.2, the power and 14 38-9218022-000, NEI 12-02, 3.4 seismic loading. Control Room Indicators are lnternationallnstrum~nt~ wh1ch Vibration performed for the horn cover and control panel vibration testing utilized a narrower EN 60068-2-6, have been used in Control Rooms for years in Safety-Related appllcat1on ..
adhesive to demonstrate adequate frequency band (5-25 Hz) and a more limiting 38-9218023-000, shock withstand. Additional displacement magnitude (1.6 mm). These 51-9221032-000 The post modification testing will demonstrate reliable op~ratio~ of_ the .
testing was performed for the values were deemed to be acceptable and 66-9225632-000 instrumentation, which confirms no damage occurred dunng sh1ppm~, handling power control panel assembly. enveloping for equipment rigidly mounted to a 32-9221237-003 and installation. Similarly, the performance of monthly channel funct1o~al Seismic Category I structure, based on 66-9225469-000 comparisons will serve to confirm proper operation of the instrume~tat1on, or engineering judgment.
38-9228047-000 provide a means of early detection of potential instrument degradation.
The shock testing deviated from the IEC 60068-The test and analyses of the horn cover and adhesive demonstrate adequate 2-27 recommended peak acceleration and capability to withstand shock and vibration.
duration for land-based permanently installed equipment. In-lieu of the 15 g's peak acceleration and duration of 11 m-sec recommended in TABLE A.1, the power and control panel vibration testing utilized an~
acceleration of 1Og with a 6 m-sec durat1on.
These values were deemed to be acceptable and enveloping for equipment rigidly mounted to a seismic Category I structure, based on engineering judgment.
Testing and analyses horn cover and adhesive support the components can tolerate horizontal and vertical accelerations up to 1OOg and SFP sloshino loads up to 3.37 psi.
U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 6 of7 Requirements 15 Not required by order N/A N/A N/A N/A Traceability AREVA Doc. 51-9228351-Inspection of waveguide, test of 000, "Through Air Radar The vendor factory acceptance test demonstrated reliable operation of the SFP Factory functionality of power transfer to Spent Fuel Pool Level Test demonstrates that specification level instrumentation under normal conditions and under various simulated test 16 Acceptance battery, sensor measurement Instrument (SFPLI) Factory N/A requirements were met. conditions (e.g. steam exposure). The testing demonstrated the instrumentation Test accuracy and effects of steam and Acceptance Test (FAT) met design accuracy and repeatability specifications.
water in waveguide Report for H.B. Robinson" EC 89580 Attachment AA - Normal conditions accuracy +/-1 inch, error due to The vendor factory acceptance test demonstrated reliable operation of the SFP 01-9228622-002_Robinson all effects including 212°F saturated steam +/-3 Channel Normal and accident conditions EA-12-051, 1.7 level instrumentation under normal conditions and under various simulated test 17 Instruction Manual inches.
Accuracy SFP level measurement accuracy NEI12-02, 3.7 conditions (e.g. steam exposure). The testing demonstrated the instrumentation Accuracy verified during factory acceptance met design accuracy and repeatability specifications.
testing.
Qualification Analysis Doc. 51-Based on vendor analyses the battery capacity is deemed sufficient to support 9202556-005, Section 2.9, EC Power Lifetime of battery backup at full EA-12-051, 1.6, reliable instrument channel operation until off-site resources can be deployed by 18 89580 Attachment AA Battery capacity at full load is expected to easily Consumption load NEI 12-02, 3.6 the mitigating strategies in response to Order EA-12-049.
9228622-002_Robinson exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Instruction Manual Section 12 Application-specific information on Attachment AA- 01-9228622- The vendor technical manual has been reviewed, accepted and incorporated in Technical N/A 19 the installation, operation, and 002_Robinson Instruction N/A Manual the engineering change package.
maintenance of the SFPLI Manual EA-12-051, 1.8 NEI 12-02, 3.8 Based on negligible drift rate of VEGA electronics experienced over Attachment AA- 01-9228622- large user base, The vendor technical manual has been reviewed, accepted and incorporated in Periodic indication checks, 002_Robinson Instruction periodic calibration the engineering change package.
20 Calibration N/A calibration checks, calibration Manual is not needed.
Sections 7.0 and 9.1 Functional verification can be achieved using cross channel checks and functional checks
- per vendor manual.
U.S . Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 7 of7 Failure Modes The instrumentation is required to function to provide SFP level indication for a and Effects beyond design bases event. Performance of a FMEA is not warranted for this 21 Analysis N/A N/A N/A type of an application . Reasonable assurance that both channels are not N/A (FMEA) susceptible to a common mode failure is provided by satisfying the NEI 12-02 guidance.
Qualification Analysis Doc. 51-9202556-005, Section 2.6 and The EMI/RFI susceptibility and emissions testing performed for the waveguide supporting references radar transmitter provides adequate assurance the instrumentation will be 58-9214362-000, compatible in the design location . The testing was conservatively performed with 38-9218963-000, unshielded interconnecting wiring.
38-9218965-000, VEGAPULS 62 ER has been tested for Emissions and susceptibility Post-modification testing will further demonstrate acceptable operation in the 22 EM! Testing 38-9218966-000, N/A emissions to both MIL and IEC standards and for testing for VEGAPULS 62 ER installed location.
38-9218962-000, susceptibility to IEC standards 38-9218967-000, 38-9218968-000, During a postulated BDBEE, it is possible that intermittent UHF radio operation 38-9218969-000, could occur in the vicinity of the radar transmitter. Successful long-term SFP 38-9218970-000, monitoring capability during a postulated BDBEE would not be inhibited by 38-9218964-000 potential intermittent radio transmission interference.