View source for RC-14-0031, Second 6-Month Status Report of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

{{Adams
| number = ML14063A201
| issue date = 02/27/2014
| title = Second 6-Month Status Report of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation
| author name = Gatlin T
| author affiliation = SCANA Corp, South Carolina Electric &amp; Gas Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000395
| license number = NPF-012
| contact person = 
| case reference number = EA-12-051, RC-14-0031
| document type = Letter type:RC, Status Report
| page count = 10
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Thomas D. Gatlin Vice President,Nuclear Operations (803) 345-4342 A/ CANA C'OMPANY                                                                                        February 27, 2014 A scANA COMPANY                                                                                               RC-14-0031 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

==Dear Sir / Madam:==

==Subject:==
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY (SCE&G) SECOND 6-MONTH STATUS REPORT OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION

==References:==
: 1. NRC Order Number EA-1 2-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012
[ML12054A682]
: 2. SCE&G's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 RC-13-0031 [ML13063A099]
On March 12, 2012, the Nuclear Regulatory Commission issued an order (Reference 1) to South Carolina Electric & Gas Company (SCE&G). Reference 1 was immediately effective and directs SCE&G to have a reliable indication of the water level in associated spent fuel storage pools.
Reference 1 requires submission of a 6-month status report following the submittal of the Overall Integrated Plan (Reference 2). The purpose of this letter is to provide the second 6-month status report pursuant to Section IV, Condition C.2, of Reference 1. SCE&G developed an Overall Integrated Plan (Reference 2), documenting the-requirements to install reliable spent fuel pool level instrumentation, in response to Reference 1. Attachment I provides the second 6-month status report of milestone accomplishments since the submittal of the Overall Integrated Plan. This update includes any changes to the compliance method, schedule, or need for relief/relaxation and the basis.
This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Bruce L. Thompson at (803) 931-5042.
Virgil C.Summer Station - Post Office Box 88 . Jenkinsville, SC.29065 *F(803) 941-9776                      ei,

Document Control Desk CR-12-01070 RC-14-0031 Page 2 of 2 I certify under penalty of perjury that the foregoing is true and correct.
Executed on                          Thomas D. Gatlin BD/TDG/ts

==Attachment:==

I. South Carolina Electric & Gas (SCE&G)'s Second Six Month Status Report of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation c:    K. B. Marsh S. A. Byrne J. B. Archie N. S. Carns J. H. Hamilton J. W. Williams W. M. Cherry E. J. Leeds V. M. McCree (w/attachment)
S. A. Williams (w/attachment)
NRC Resident Inspector K. M. Sutton NSRC RTS (CR-12-01070)
File    (815.07)
PRSF (RC-14-0031)

Document Control Desk CR-12-01070 RC-14-0031 Attachment I Page 1 of 8 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT I ATTACHMENT I SOUTH CAROLINA ELECTRIC & GAS COMPANY (SCE&G) SECOND 6-MONTH STATUS REPORT OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION
: 1. Introduction SCE&G developed an Overall Integrated Plan (Reference 2) and first six-month status report (Reference 4), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPLI), in response to Reference 1. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
: 2. Milestone Accomplishments The following milestone(s) in section 3 have been completed since the development of the Overall Integrated Plan (Reference 2), and are current as of February 28, 2014.
Submitted the Virgil C. Summer Nuclear Station, Unit 1 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC NO. MF1173) Dated August 28, 2013 (RC-13-0119).
: 3. Milestone Schedule Status The following provides an update to milestone schedule to support the Overall Integrated Plan.
This section provides the activity status of each item, and the expected completion date. The dates are planning dates subject to change as design and implementation details are developed.
The revised milestone target completion dates do not impact the order implementation date.
Target                             Revised Completion          Activity          Target Milestone Date             Status        Completion Date Submit 60 Day Status Report                     Oct 2012          Complete Submit Overall Integrated Plan                  Feb 2013          Complete Submit Response to RAIs on Overall              Aug 2013          Complete Integrated Plan Submit Response to RAls on Overall              Oct 2014        In Progress

Document Control Desk CR-1 2-01097 RC-14-0031 Attachment I Page 2 of 8 Target           ARevised Completion           Activity          Target Milestone Date             Status         Completion Date Integrated Plan Submit 6 Month Updates:
Update 1                                 Aug 2013          Complete Update 2                                 Feb 2014          Complete Update 3                                 Aug 2014         Not Started Update 4                                 Feb 2015         Not Started Update 5                                 Aug 2015         Not Started Update 6                                 Feb 2016         Not Started Modifications:
Modification Development                 Jan 2014         In Progress Complete Procurement of                  Jun 2013         In Progress       March 2014 Instrumentation Package Complete Engineering and Design           Jul 2014        In Progress      January 2015 Commence Implementation                  Oct 2014         Not Started       March 2015 Unit 1 Implementation Outage             Oct 2015         Not Started Procedures:
Complete Procedures Development          Feb 2015         Not Started Training:
Develop Training Plan                    Feb 2015         Not Started Training Complete                        Aug 2015          Not Started
: 4. Changes to Compliance Method There is one change to the compliance method as documented in the Overall Integrated Plan (OIP) (Reference 2). The backup channel of the spent fuel pool level monitoring system will be

Document Control Desk CR-12-01070 RC-14-0031 Attachment I Page 3 of 8 a permanently installed channel instead of the portable channel described in the OIP. The details of this change were provided in the station response to the Request for Additional Information (References 3 and 5)
: 5. Need for Relief/Relaxation and Basis for the Relief/Relaxation SCE&G expects to comply with the order implementation date and no relief/relaxation is required at this time.
: 6. Open Items from Overall Integrated Plan and Draft Safety Evaluation Public meetings were held on November 26, 2013 and February 6, 2014 to discuss reliable spent fuel pool level instrumentation RAIs based on binning (References 7, 8, and 9). The two bins are: generic RAIs to be answered by the vendor and plant specific. VCSNS will provide a response to all RAIs by October 31, 2014. Below is an update on plant specific RAIs listed in reference 6.
RAI #1 Please provide additional information describing how the design of shielding for the SFP level instrumentation meets the requirement of the Order to arrange the instruments 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. Also, describe plans for protecting any equipment mounted outside the buildings from the effects of tornado driven missiles, freezing, elevated temperature, humidity, flooding, and other BDB conditions.
SCE&G Update This RAI is part of the detailed seismic design, and has not been started.
RAI #2 Please provide the following:
a) The design criteria to be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology to be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the sensing waveguide assembly. Indicate in a schematic the portions of the level sensor waveguide that will serve as points of attachment for mechanical/mounting or electrical connections.

Document Control Desk CR-12-01070 RC-14-0031 Attachment I Page 4 of 8 c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP wall or floor structures so as to support the waveguide level sensor assembly.
SCE&G Update This RAI is part of the detailed seismic design, and has not been started.
RAI#4 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/equipment.
SCE&G Update The SFP level indication equipment is being purchased Quality related per VCSNS Specification SP-1000. VCSNS Specification SP-1 000 requires the SFPL indication equipment to operate at a temperature of 212 degrees Fahrenheit, operate in a boiling water or steam environment at 100% humidity, operate at an elevation of at least 150 meters above sea level, and in radiological conditions for a normal refueling quantity of freshly discarded (100 hours) fuel with the SFP water level 3, as described in NEI 12-02. The instrument channel reliability under seismic conditions will be established using the methodology in NEI 12-02 Revision 1 Section 3 and will meet the intent of interim staff guidance for reliable spent fuel pool instrumentation in NRC JLD-ISG-2012-03, Revision 0. The instrument channel design basis seismic conditions will correspond to the VCSNS Safe Shutdown Earthquake in structure response spectra from SP-702 at the locations of the components of the instrument channel. The adequacy of the seismic design and installation will comply with the applicable guidance in IEEE Standard 344-2004 Sections 7, 8, 9, and 10. The instrumentation will also meet the shock qualifications of NEI 12-02 and MIL-S-901D.
RAI #5 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the equipment located within the FH building exterior wall and the auxiliary building stairwell will be exposed. Also, provide documentation indicating how it was determined the electronics for this equipment is capable of 3
withstanding a total integrated dose of lX1O Rads. Discuss the time period over which the analyzed total integrated dose was applied.
SCE&G Update The first part of this RAI will be provided in generic vendor meetings.
The second part of this RAI response is in progress, no new update.

Document Control Desk CR-1 2-01070 RC-1 4-0031 Attachment I Page 5 of 8 RAI #7 Please provide information indicating the maximum expected relative humidity in the rooms in which the system electronics will be located under BDB conditions, with no AC power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition.
SCE&G Update RAI response is in progress. The maximum humidity postulated for the spent fuel pool area is 100 percent relative humidity, saturated steam. The radar sensor electronics will be located outside of the spent fuel pool room in an area away from the steam atmosphere. The waveguide pipe can tolerate condensation formation on the inner wall surface, provided condensate pooling does not occur within the waveguide pipe. Condensate pooling is prevented by installing a weep hole(s) at the low point(s) in the wave guide pipe. VCSNS is still determining BDB conditions for the Fuel Handling Building exterior wall and the auxiliary building stairwell. Additional test information for the equipment will be provided once the purchase order is in place. This documentation is to be provided by the vendor per VCSNS Specification SP-1000.
RAI #11 Please provide an evaluation of the seismic testing results to show that the instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Virgil C. Summer Nuclear Station has been adequately demonstrated. Include information describing the design inputs and methodology used in any analyses of the mounting of electronic equipment onto plant structures, as requested in RAI #4 above.
SCE&G Update The first part of this RAI will be provided in generic vendor meetings.
VCSNS Specification SP-1 000 requires the design inputs for equipment related to instrument channel reliability under seismic conditions be established using the methodology in NEI 12-02 Revision 1 Section 3. These design inputs will meet the intent of interim staff guidance for reliable spent fuel pool instrumentation in NRC JLD-ISG-2012-03, Revision 0. The instrument channel design basis seismic conditions will correspond to the VCSNS Safe Shutdown Earthquake in structure response spectra from SP-702 at the locations of the components of the instrument channel.
RAI #12 Please provide the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.

Document Control Desk CR- 2-01070 RC-14-0031 Attachment I Page 6 of 8 SCE&G Update RAI response is in progress. VCSNS is waiting on the vendor to provide the final configuration of the primary and backup power sources for each channel. These channels will be independently fed with their own DC power sources.
RAI# 15 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.
SCE&G Update RAI response is in progress, no new update.
RAI #16 Please describe the evaluation used to validate the display locations can be accessed without unreasonable delay following a BDB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.
Additionally, include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BDB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.
SCE&G Update RAI response is in progress, no new update.
RAI #17 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. Include a brief description of the specific technical objectives to be achieved within each procedure.
SCE&G Update Appropriate quality assurance measures will be selected for the SFP instrumentation as required by Order EA-1 2-051, consistent with Appendix A-1 of NEI 12-02 and similar to those imposed by Regulatory Guide 1.155. Site procedures will be developed for system inspection, calibration and test, maintenance, repair, operation, and normal and abnormal responses, in accordance with VCSNS procedure controls. The development of these procedures has not started.

Document Control Desk CR-12-01070 RC-14-0031 Attachment I Page 7 of 8 Procedure                                          Obiectives to be achieved
: 1) System Inspection         To verify that system components are in place, complete, and in the correct configuration, and that the sensor probe is free of significant deposits of crystallized boric acid.
: 2) Calibration and Test      To verify that the system is within the specified accuracy, is functioning as designed, and is appropriately indicating SEP water level.
: 3) Maintenance               To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.
: 4) Repair                    To specify troubleshooting steps and component repair and replacement activities in the event of system malfunction.
: 5) Operation                 To provide sufficient instructions for operation and use of the system by plant operation staff.
: 6) Response                  To define the actions to be taken upon observation of system level indications, including actions to be taken at the levels defined in NEI 12-02.
RAI #18 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 the 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) Information describing compensatory actions when both channels are out-of order, and the implementation procedures.
c) Additional information describing expedited and compensatory actions in the maintenance procedure to address when one of the instrument channels cannot be restored to functional status within 90 days.
SCE&G Update RAI response is in progress, no new update.

Document Control Desk CR-12-01070 RC-14-0031 Attachment I Page 8 of 8
: 7. Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
: 8. References The following references support the updates to the Overall Integrated Plan described in this attachment.
: 1. NRC Order Number EA-12-051, " Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, " dated March 12, 2012
: 2. SCE&G's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (RC-13-0031)
: 3. Robert E. Martin to Thomas D. Gatlin Letter: Virgil C. Summer Nuclear Station, Unit 1-Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC NO. MF1 173) dated July 29, 2013
: 4. SCE&G's 6-Month Status Report of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, dated August 28, 2013 (RC-13-0117)
: 5. Virgil C. Summer Nuclear Station, Unit 1 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC NO. MF1 173) dated August 28, 2013 (RC-13-0119)
: 6. Shawn Williams to Thomas D. Gatlin Letter: Virgil C. Summer Nuclear Station, Unit 1-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 (TAC NO. MF1173) dated December 5, 2013
: 7. NRC (Nuclear Regulatory Commission 2013) Public Meeting on Reliable Spent Fuel Pool Instrumentation-StaffEvaluations of Licensee Plans for Addressing Order EA- 12-051, November 26, 2013 Rockville, MD: NRC
: 8. NEI (Nuclear Energy Institute 2013) Spent Fuel Pool Instrumentation Order (EA-12-051)
RAls Binning Nov. 26, 2013 Washington, DC: NEI
: 9. NRC (Nuclear Regulatory Commission 2013) Public Meeting on Reliable Spent Fuel Pool Instrumentation-StaffEvaluations of Licensee Plans for Addressing Order EA-12-051, February 6, 2014 Rockville, MD: NRC
: 10. SCE&G's Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Specification for Fukushima (FLEX) SFP Level Instrumentation System SP-1 000, Revision 1 dated February 4, 2014}}