SBK-L-14042, 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)

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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)
ML14064A189
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 02/27/2014
From: Walsh K
NextEra Energy Seabrook
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, SBK-L-14042
Download: ML14064A189 (18)
v • d • e


Text

NEXTerao ENERGY P February 27, 2014 SBK-L-14042 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, LLC's 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- 12-0511)

References:

1. NRC Order Number EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12056A044)
2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 (ML12221A339)
3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA- 12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012
4. NextEra Energy Seabrook, LLC Initial 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 October 26, 2012 (ML12311A012)
5. NextEra Energy Seabrook, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (Order Number EA-12-05 1), dated February 26, 2013 (ML13063A439)
6. NRC Letter, 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 (ML13267A388)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra Energy Seabrook). Reference 1 was immediately effective and directs NextEra Energy Seabrook to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1. A DO NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 09-L

U.S. Nuclear Regulatory Commission SBK-L- 14042/Page 2 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 IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the NextEra Energy Seabrook initial status report regarding mitigation strategies. Reference 5 provided the NextEra Energy Seabrook overall integrated plan. In Reference 6, the NRC requested additional information to enable the continued technical review of the NextEra Energy Seabrook Overall Integrated Plan (OIP).

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 second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. It also provides responses to the Reference 6 request for additional information to the extent possible. Table 1 of the attachment provides a summary of the status of responses to the Request for Additional Information (RAIs) that were received on December 4, 2013. The responses to "In Progress" RAIs in the table require design information that is not available at this time. As details are developed, responses to these RAIs will be provided to the NRC as part of future six month status reports.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February * , 2014.

Sincerely, Kevin T. Walsh Site Vice President NextEra Energy Seabrook, LLC

U.S. Nuclear Regulatory Commission SBK-L-14042/Page 3 cc: NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratchmann, NRR/JLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Attachment to SBK-L-14042 NextEra Energy Seabrook, LLC's Six-Month Status Report in Response to March 12, 2012 Conmmission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 1)

Page 1 of 15

ATTACHMENT

1.0 INTRODUCTION

By letter dated February 26, 2013 (Agency wide Documents Access and Management System (ADAMS) Accession No. ML13063A439), NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) submitted an Overall Integrated Plan (OIP) for Seabrook Station in response to the March 12, 2012 U.S. Nuclear Regulatory Commission (NRC) Order modifying licenses with regard to requirements for Reliable Spent Fuel Pool (SFP) Instrumentation (Order Number EA-12-051; ADAMS Accession No. ML12056A044). This attachment provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule or need for relief/relaxation and the basis.

2.0 MILESTONE ACCOMPLISHMENTS

" Commence Engineering and Design - This milestone is in progress. Seabrook has selected SFP level instrumentation that will be used to meet the criteria delineated in the Overall Integrated Plan.

  • Submit First 6 month status report - Complete

" Submit Second 6 month status report - Complete 3.0 MILESTONE SCHEDULE STATUS There currently are no changes to the Milestone Schedule provided in the OIP (Reference 2).

Any changes to the following target dates will be reflected in the six month status reports:

The current milestones are:

  • Submit Third 6 Month status report 3Q 2014 (August)

" Complete Engineering and Design 4Q 2014 (December)

" Submit Fourth 6 Month status report 1Q 2015 (February)

" Complete Procurement of SFP Instruments 1Q 2015 (March)

  • Complete Installation/Instruments Operational 3Q 2015 (August)

" Submit Fifth 6 Month status report 3Q 2015 (August)

  • Second Refueling Outage 3Q 2015 (October)

" Training Complete 3Q 2015 (October)

Required implementation date: 3Q 2015 (Refueling Outage 17)

Page 2 of 15

4.0 CHANGES TO COMPLIANCEMETHOD There currently are no changes to the compliance method documented in the OIP (Reference 2). Consistent with the requirements of Order EA-12-051 and the Order guidance documents, the six month reports will delineate any proposed changes to compliance methods.

5.0 NEED FOR RELIEF!RELAXA TION AND BASIS NextEra Energy Seabrook is not requesting relief from the requirements of Order EA- 12-051 or guidance document JLD-ISG-2012-03 (Reference 4) at this time.

Consistent with the requirements of Order EA- 12-051 (Reference 2) and the guidance in NEI 12-02 (Reference 5), the six month reports will delineate progress made, any proposed changes in compliance methods, updates to the schedule, and if needed, requests for relief and their bases.

6.0 REQUESTS FOR ADDITIONAL INFORMATION The NRC staff determined that additional information was required to enable the continued technical review of the NextEra Energy Seabrook OIP.

Table 1 provides a summary of the status of responses to the Request for Additional Information (RAIs) that were received on December 4, 2013 (Reference 10). The responses to "In Progress" RAIs in the table require design information that is not available at this time. As details are developed, responses to these RAIs will be provided to the NRC in future six month status reports.

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Table 1 RAIs Status RAI Level Included in this report RAI Cable Routing Included in this report RAI-3 a, b, c - Mounting In progress RAI Mounting In progress RAI Mounting Included in this report RAI-6 a, b, c - Qualification In progress RAI Qualification In progress RAI Independence In progress RAI Power Supply In progress RAI Accuracy In progress RAI Testing and Calibration In progress RAI Display In progress RAI Procedures Included in this report RAI-14a, b, c - Maintenance and Testing Included in this report RAI Testing and Calibration In progress Page 4 of 15

The following RAI responses are included:

RAI-]: Please provide the final elevation for Level 3 and an updated sketch of the SFP elevation view with the SFP levels, if applicable.

NextEra Response RAI-1 Westinghouse has established that the accuracy for the Spent Fuel Pool Instrumentation System (SFPIS) will be +/- 3.0 inches. Westinghouse has also established the unmeasurable zones (instrument sensitivity bands) of the sensor probe. The instrument sensitivity band at the top of the probe will be 12 inches. Therefore, the SFP level instrument upper range will be set to a value that is at least 15 inches above Level 1 (Elev. 23 ft., 4 in.) to account for the upper instrument sensitivity band and instrument loop uncertainty. The instrument sensitivity band at the bottom of the probe will be 4 inches.

The instrument lower range will be set to a value that is at least 7 inches below Level 3 (Elev. (-)

0 ft., 6 in.) to account for the instrument sensitivity band and uncertainty. An indicated level on either the primary or backup instrument channel of greater than plant elevation (-) 0 ft., 6 in. will assure that the fuel in the pool remains covered. contains a revised elevation view of the proposed arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment. In addition, the datum values for Levels 1, 2 and 3 the revised elevation view depicts the top and bottom instrument sensitivity bands for the SFPIS probe.

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RAI-2: Please provide additional information describing how the proposed arrangement of the waveguides and routing of the cabling between the FSB through the CEB and into the PAB meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.

NextEra Response RAI-2 Since the Spent Fuel Building (SFB), Containment Enclosure Building (CEB), Primary Auxiliary Building (PAB) and Control Building (CB) Essential Switchgear Rooms are Seismic Category I structures, all equipment mountings within these buildings are designed to remain anchored during and following a seismic event. This design provides reasonable assurance that missiles will not be generated by equipment located in the areas where the new SFPIS will be installed.

As previously described, physical separation of the SFPIS level sensors, level transmitters, UPS/Remote Enclosures and instrument channel cables to the extent practicable will also be used to provide protection against missiles that may result from unexpected damage to adjacent seismically installed structures or components.

Physical separation will be maintained using Class 1E type train separation. The separation will be achieved through the use of safety class structures, independent seismic category I supports and raceways, barriers and physical distance between the primary and backup equipment and channel cabling in accordance with the design criteria described in UFSAR sections 8.3.1.4, "Independence of Redundant Systems," UFSAR Appendix 8A, "Attachment C to AEC Letter Dated December 14, 1973, Physical Independence of Electric Systems," and UFSAR Table 8.3-10, "Electrical Cable and Raceway Separation Criteria." All SFPIS equipment, conduit and trays for the routing of the cabling for the SFPIS will be seismically qualified and installed to maintain the separation criteria currently assumed in the plant design basis.

The primary instrument channel sensor will be located in the northwest comer of the SFP. From the sensor, the primary signal cable will be routed in rigid steel conduit away from the SFP (west) to the adjacent west wall of the Spent Fuel Building. The backup instrument channel sensor will be located in the southwest comer of the SFP (adjacent comer). From the sensor, the backup signal cable will be routed away from the SFP in rigid steel conduit to the adjacent west wall of the Spent Fuel Building. The comers of the SFP will provide inherent missile protection for the level sensor probes in the pool.

The level transmitters, one per channel, will be mounted in separate locations within the Containment Enclosure Ventilation Area (CEVA) within the CEB using independent seismically Page 6 of 15

qualified supports. The vendor supplied cables that connect the sensors in the SFP to the level transmitters will be routed independently to the appropriate level transmitter using Class 1E type train separation. Each conduit will be installed on its own separate independent series of seismically qualified supports (i.e. "A" train and "B" train supports) configured to maintain the train separation criteria currently assumed in the plant design basis.

The primary and backup channel UPS/ Remote Indication Enclosures, which include the remote displays, will be located in the Control Building Essential Switchgear Rooms, one channel in each room. The Essential Switchgear Rooms are separated by physical barriers that preserve the independence of redundant Class lE plant electrical systems. From the transmitter locations in CEVA, new plant cables will be installed in existing seismically qualified raceways to the remote indication enclosures. These cables will be routed using Class 1E type train separation with the primary channel cabling routed in existing separation group B raceways and the backup channel cable routed in existing separation group A raceways. The raceways that will be used were designed and installed in accordance with the Class 1E train separation criteria currently assumed in the plant design basis.

RAI-5: For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs and the methodology used to qualify the structural integrity of the affected structures/equipment.

NextEra Response RAI-5 The Fuel Storage, Containment Enclosure Building and the Control Buildings are seismic Category I reinforced concrete structures designed and constructed to meet the requirements of Seabrook UFSAR 3.8.4, Other Seismic CategoryI Structures. Reinforced concrete is designed and constructed per the American Concrete Institute code ACI 318-71.

Steel framing within the structures is designed and constructed to the requirements of the American Institute of Steel Construction code, AISC Specification for the Design, Fabrication and Erection of Structural Steel for Building 1969 Edition. Concrete walls have a minimum compressive strength of 3000 psi. No block or concrete masonry partitions are utilized in any Category I structure.

Structural integrity qualification of the Category I buildings for actual and postulated loads imposed by equipment mounted to the structure is addressed by local analysis of the attachment Page 7 of 15

mechanism. Attachment to the structures will use concrete anchors. Embedded concrete anchor allowable loads are based on the anchor failing before the concrete. Thus a properly designed embedded anchor assures that the concrete structure maintains its local structural integrity.

The effect of the actual and postulated loads on the global building structural integrity is a matter of comparison of the additional load to the generic design loads for the structure. Generic design loads, as described in the structural design criteria, are used to account for undefined loads.

Additional loads that exceed the generic design loads warrant an evaluation of the affected structural elements. Loads that exceed the generic design loads are not expected for this activity.

The design inputs for the attachment connection are the weight of the component, the method of attachment, the local seismic response of the building, any other pertinent loads per UFSAR 3.8.4.3 Loads andLoading Combinations.The allowable loads for the attachment mechanism are also design input.

Simple static analyses will be used to evaluate the support attachment design. This conservative analysis methodology uses peak acceleration in each of three orthogonal directions (UFSAR 3.7(B).2.6) obtained from the building amplified response spectra. Those accelerations are increased by 50% to account for multi-modal response (multiplied by 1.5). Attachment loads are calculated in each of the three directions; loads are combined by square root sum of the squares (SRSS), and then combined with dead weight loads and compared with allowable loads.

Alternatively, the stiffness of the component and support may be computed and the frequency of the first mode of vibration estimated. Should the frequency fall in the rigid range of the response spectra then the zero period accelerations of the three orthogonal directions may be used for the static analysis described above.

RAI-13: Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection 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.

NextEra Response RAI-13 The modification review process will be used to ensure all necessary procedures are developed for maintaining and operating the spent fuel level instruments after installation. These Page 8 of 15

procedures will be developed in accordance with NextEra Energy Seabrook procedural controls.

The objectives of each procedural area are described below:

Inspection, Calibration and Testing - Guidance on the performance of periodic visual inspections, as well intrusive testing, to ensure that each SFP channel is operating and indicating level within its design accuracy.

Preventative Maintenance - Guidance on scheduling of, and performing, appropriate preventative maintenance activities necessary to maintain the instruments in a reliable condition.

Maintenance - To specify troubleshooting and repair activities necessary to address system malfunctions.

Programmatic Controls - Guidance on actions to be taken if one or more channels is out of service.

System Operations - To provide instructions for operation and use of the system by plant staff.

Response to inadequate levels - Action to be taken on observations of levels below normal level will be addressed in Site off normal procedures and /or FLEX Support Guidelines.

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. Please include a description of plans to ensure 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 compensatory actions that will be taken in the event that one or both channels are non-functioning, as described in the guidance in NEI 12-02, Section 4.3.

c) A description of the compensatory actions that are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.

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NextEra Response RAI-14.a SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness will be established in accordance with NextEra Energy Seabrook's processes and procedures. The design modification process will take into consideration the vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit).

Once the maintenance and testing program requirements for the SFP are determined, the requirements will be documented in Maintenance program documents.

Performance checks, described in the Vendor Operator's Manual, and the applicable information will be contained in plant procedures. Operator performance tests will be performed periodically as recommended by the vendor.

Channel functional tests with limits established in consideration of vendor equipment specifications will be performed at appropriate frequencies.

Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications are planned to be performed at frequencies established in consideration of vendor recommendations.

NextEra Response RAI-14.b Both primary and backup SFPI channels incorporate permanent installations (with no reliance on portable, post-event installation) of relatively simple and robust augmented quality equipment.

Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) will be out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:

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  1. Channel(s) Required Restoration Action Compensatory action Out-of-service 1 Initiate actions to restore channel Implement actions in to functional status within 90 accordance with Note 2.

days. (Note 1) 2 Initiate action to restore at least Implement actions in one channel to functional status accordance with Note 2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Note 1: If channel restoration is not expected to be completed within 90 days initiate compensatory action.

Note 2: Initiate an evaluation in accordance with the corrective action program. The evaluation shall initiate compensatory actions to implement an alternate method of monitoring and schedule required actions for restoring the instrumentation channel(s) to functional status.

NextEra Response RAI-14c See RAI-14.b response above.

Page 11 of 15

References I. NRC Electronic Mail to NextEra Energy Seabrook, LLC, "Draft Requests for Additional Information Regarding the Seabrook Overall Integrated Plan for Reliable SFP Instrumentation, dated July 18, 2013 (ADAMS Accession No. ML13217A166).

2. NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 1), dated February 26, 2013 (ADAMS Accession No. ML13063A439)
3. NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049), dated February 22, 2013 (ADAMS Accession No. ML13063A438)
4. NRC JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29, 2012.
5. NEI 12-02, Industry Guidance for Compliance with NRC Order EA- 12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, August 2012.
6. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012.
7. Seabrook Calculation C-S-1-24606, "Spent Fuel Pool Level for Reliable Pump Suction,"

Revision 00.

8. NRC Order EA- 12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No ML12056A044).
9. NextEra Energy Seabrook, LLC, First Six Month Status Report for the Implementation of Order EA- 12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation ," dated August 28, 2013 9ADAMS Accession No. ML13247A177).
10. Seabrook Station, Unit 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA 051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0837), Dated December 4, 2013 (ADAMS Accession No. ML13267A388).

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11. Seabrook Drawings Drawing No. Title Revision 310733 Fuel Storage Building EL. 25'-0" 001 310724 Fuel Storage Building Exposed Conduit 017 Plan Elevation 25'-0" 102200 F.S.B. Stainless STL.- Spent Fuel Pool 012 Liner SH. 1 Area 040 FB 1-NHY-805059 Fuel Storage Building Plan Elevation 21"- 012 6" & 25"-0" General Arrangement 1-NHY-310431 Control Building Elev. 21 '-6" Electrical 030 General arrangement 1-NHY-805062 Primary auxiliary Building Plans At Elev. 020 25"-0" General Arrangement 101619 Containment Enclosure Ventilation Area 011 Concrete Plans At EL. 21 '-6" & 53'-0" Page 13 of 15

ATTACHMENT ENCLOSURE 1 NEXTERA ENERGY SEABROOK, LLC SEABROOK NUCLEAR PLANT SECOND SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION SPENT FUEL POOL LEVELS ELEVATION VIEW Page 14 of 15

4 ENCLOSURE 1 SEABROOK SPENT FUEL POOL LEVELS ELEVATION VIEW

-- TO LEVEL TRANSMITTER OPERATING FLOOR EL. 25'-D"

-- "INSTRUMENT NORMAL WATER LEVEL EL. 23'-4" TO 23'-9" SE NSITLVIT Y BAND 12" RELIABLE SUCTION LEVEL EL. 23'-4" ------------- -LEVEL 1 LOSS OF NPSH Z 212°F EL. 22'-4" TOP OF STRAINER -EL. 21'-B" SCTION TECHNICAL SPECIFICATION LIMIT EL. 21'-172",

STRAINER LEVEL FOR SUBSTANTIAL RADIATION SHIELDING EL. 1O'-9Y2 " - ------- -- LEVEL 2

_O.FPU.M_?,EL 9.-2"'.I~

0212° F NPSH- 11.2Ft LEVEL WHERE FUEL REMAINS COVERED EL. C-) 0'-6" --- LEVEL 3

--- l INSTRUMENT TOP OF FUEL RACK EL. (-) i-5Y4" ( I....- SENSITIVITY BAND 4"

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% '-BOTTOM OF SFP EL. (-) 15-11 /2" 0 - -

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  • 0 NOTES:
1. ALL ELEVATIONS ARE NOMINAL
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