ML14245A401

Six-month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12051)

ML14245A401
Person / Time
Site:	North Anna
Issue date:	08/26/2014
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-391, EA-12-051
Download: ML14245A401 (13)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 10 CFR 2.202 EA-1 2-051 August 26, 2014 Attention: Document Control Desk Serial No.: 14-391 U.S. Nuclear Regulatory Commission NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 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)

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

2. Virginia Electric and Power Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (Serial No. 12-166B)

3. Virginia Electric and Power Company'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-12-051), dated February 28, 2014 (Serial No.

12-166E)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 was immediately effective and directed Dominion to install reliable Spent Fuel Pool (SFP) Level Instrumentation.

Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2) pursuant to Section IV, Condition C. Reference 1 also required submission of a status report at six-month intervals following submittal of the OIP.

The attachment to this letter provides the third six-month status report and an update of milestone accomplishments since the submittal of the second six-month status report (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis.

DVL

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Page 2 of 3 If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. Sartain Vice President Nuclear Engineering Virginia Electric and Power Company Attachment (1)

Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me thisla 3.ay of ,2014.

My Commission Expires: /A. - /VA32,I 11 .

(SEAL)A" R 140542Notary My Public (SEAL) M Commissft ImMy 31, 2014

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region II Regional Administrator Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. K. R. Cotton NRC Project Manager Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center, Suite 300 4201 Dominion Blvd.

Glen Allen, Virginia 23060

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation August 2014 North Anna Power Station Units 1 and 2 Virginia Electric and Power Company (Dominion)

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 1 of 9 Six Month Status Report for the Implementation of Order EA-1 2-051 1 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting the requirements to install reliable Spent Fuel Pool (SFP) Level Instrumentation in response to Order EA-12-051 (the Order) (Reference 2). This attachment provides an update of milestone accomplishments since submittal of the last status report for North Anna Power Station (Reference 3) including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the North Anna Power Station OIP for Order EA-12-051 and are current as of July 31, 2014.

S Submit OIP S Commence Engineering and Design S Complete Engineering and Design S Commence Installation of SFP Instruments 3 Milestone Schedule Status The following table provides an update to the milestone schedule supporting the North Anna Power Station Overall Integrated Plan. This table provides the activity status of each item and the expected completion date, noting any change. The target completion dates are subject to change as design and implementation details are developed.

Milestone Target Activity Revised Target Completion Date Status Completion Date Submit OIP February 2013 Complete Commence Engineering and March 2013 Complete Design Complete Engineering and Design May 2014 Complete Complete Procurement of SFP May 2014 In-Progress August 2014*

Instruments

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 2 of 9 Milestone Target Activity Revised Target Completion Date Status Completion Date Commence Installation of SFP June 2014 Complete Instruments Level Measurement System September 2014 Started Functional

• The components of the SFP Level Instrumentation system required for installation have been procured and delivered. However, as of the effective date of this status report (July 31, 2014),

the calibration kit has not been delivered to the site, but will be available by the revised target completion date.

4 Changes to Compliance Method There are no changes to Dominion's compliance method with NEI 12-02 (Reference 4).

5 Need for RelieflRelaxation and Basis for the Relief/Relaxation Dominion 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 Interim Staff Evaluation No open items were identified in the North Anna Power Station Overall Integrated Plan.

However, the Requests for Additional Information (RAIs) identified in the Interim Staff Evaluation (Reference 5) are considered as Open Items. The following table provides a summary of these RAI Open Items from the North Anna Power Station Interim Staff Evaluation and the status of each item.

Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please specify which of the two identified values is the The response to this RAI was correct elevation for Level 1. provided in Attachment 2 to the February 28, 2014 Six-Month Status Report letter (Reference 3).

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 3 of 9 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide a clearly labeled sketch or marked-up The response to this RAI was plant drawing of the plan view of the SFP area, depicting provided in Attachment 2 to the the SFP inside dimensions, the planned February 28, 2014 Six-Month 2 locations/placement of the primary and back-up SFP Status Report letter (Reference 3).

level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out display device.

Provide the following: The response to this RAI was provided in Attachment 2 to the a) The design criteria that will be used to estimate the February 28, 2014 Six-Month total loading on the mounting device(s), including static Status Report letter (Reference 3) weight loads and dynamic loads. Describe the methodology that will 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.

3 b) A description of the manner in which the level sensor will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

For RAI 3(a) above, please provide the analyses used to The response to this RAI was verify the design criteria and methodology for seismic provided in Attachment 2 to the testing of the SFP instrumentation and the electronics February 28, 2014 Six-Month 4 units, including, design basis maximum seismic loads Status Report letter (Reference 3) and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 4 of 9 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status For each of the mounting attachments required to The response to this RAI was attach SFP Level equipment to plant structures, please provided in Attachment 2 to the 5 describe the design inputs, and the methodology that February 28, 2014 Six-Month was used to qualify the structural integrity of the Status Report letter (Reference affected structures/equipment. 3)

Please provide analysis of the maximum expected The response to this RAI was radiological conditions (dose rate and total integrated provided in Attachment 2 to the dose) to which the equipment (including transmitters, February 28, 2014 Six-Month control boxes, and display panels) will be exposed. Also, Status Report letter (Reference 6 please provide documentation indicating how it was 3) determined that the electronics for the SFP level instrumentation is capable of withstanding a total integrated dose of 1X104 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

Please provide information indicating (a) what are the The response to this RAI was temperature ratings and whether the temperature ratings provided in Attachment 2 to the for the system electronics (including transmitters, control February 28, 2014 Six-Month boxes, and display panels) are continuous duty ratings; Status Report letter (Reference and, (b) what will be the maximum expected ambient 3) 7 temperature in the rooms in which the system electronics will be located under BDB conditions in which there are no AC power available to run Heating Ventilation and Air Conditioning (HVAC) systems?

Please provide information indicating the maximum The response to this RAI was expected relative humidity in the rooms in which the provided in Attachment 2 to the system electronics will be located under BDB conditions, February 28, 2014 Six-Month 8 in which there are no AC power available to run HVAC Status Report letter (Reference systems, and whether the sensor electronics are 3).

capable of continuously performing its required functions under this expected humidity condition.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 5 of 9 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide information describing the evaluation of The response to this RAI was the comparative sensor design, the shock test method, provided in Attachment 2 to the test results, and forces applied to the sensor applicable February 28, 2014 Six-Month 9 to its successful tests demonstrating that the referenced Status Report letter (Reference 3).

previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of severe shock.

Please provide information describing the evaluation of The response to this RAI was the comparative sensor design, the vibration test provided in Attachment 2 to the method, test results, and the forces and their frequency February 28, 2014 Six-Month ranges and directions applied to the sensor applicable to Status Report letter (Reference 10 its successful tests, demonstrating that the referenced 3) previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

Please provide information describing the evaluation of The response to this RAI was the comparative system electronics (including provided in Attachment 2 to the transmitters, control boxes, and display panels) ratings February 28, 2014 Six-Month against postulated plant conditions. Also provide results Status Report letter (Reference of the manufacturer's shock and vibration test methods, test results, and the forces and their frequency ranges and directions applied to the system electronics and display panel associated with its successful tests.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 6 of 9 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status The response to this RAI was Please provide the following: provided in Attachment 2 to the February 28, 2014 Six-Month a) A description of the testing and/or analyses that will Status Report letter (Reference be conducted to provide assurance that the equipment 3).

will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor 12 mounted in the SFP area, and (b) any control boxes, electronics, or read-out and retransmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

b) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment during and following seismic conditions to maintain its required accuracy.

For RAI #12 above, please provide the results for the The response to this RAI was selected methods, tests and analyses used to provided in Attachment 2 to the 13 demonstrate the qualification and reliability of the February 28, 2014 Six-Month installed equipment in accordance with the Order Status Report letter (Reference 3).

requirements.

Please provide the following: The response to this RAI was provided in Attachment 2 to the a) A description of the electrical AC power sources and February 28, 2014 Six-Month capabilities for the primary and backup channels. Status Report letter (Reference 3).

14 b) Please provide the NRC staff with the final configuration of the power supply source for each channel so that the staff may conclude that the two channels are independent from a power supply assignment perspective.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 7 of 9 Interim Staff Evaluation Open Items (RAls)

RAI # Description Status Please provide the results of the calculation depicting The response to this RAI was the battery backup duty cycle requirements provided in Attachment 2 to the 15 demonstrating that its capacity is sufficient to maintain February 28, 2014 Six-Month the level indication function until offsite resource Status Report letter (Reference 3).

availability is reasonably assured.

Provide the following: The response to this RAI was provided in Attachment 2 to the a) A description of the methodology that will be used for February 28, 2014 Six-Month determining the maximum allowed deviation from the Status Report letter (Reference instrument channel design accuracy that will be 3).

employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires 16 adjustment to within the normal condition design accuracy.

b) Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BDB values. Please demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

Please provide a list of the procedures addressing The response to this RAI was operation (both normal and abnormal response), provided in Attachment 2 to the calibration, test, maintenance, and inspection February 28, 2014 Six-Month 17 procedures that will be developed for use of the SFP Status Report letter (Reference instrumentation. The licensee is requested to include 3).

a brief description of the specific technical objectives to be achieved within each procedure.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 8 of 9 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide the following: The response to this RAI was provided in Attachment 2 to the a) Further information describing the maintenance February 28, 2014 Six-Month and testing program the licensee will establish and Status Report letter (Reference and 3).

implement to ensure that regular testing 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, 18 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 7 Potential Interim Staff Evaluation (ISE) Impacts In the second Six Month Status Report letter (Reference 3), Dominion reported a change in the SFP Level Instrumentation vendor and reported conclusions of a comparison between the Westinghouse SFP Level Instrumentation design and the details that were previously provided to the staff and included in the ISE (Reference 5).

8 References The following references support the update to the North Anna Power Station SFP Level Instrumentation Overall Integrated Plan described in this attachment:

1. "Virginia Electric and Power Company'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)," Serial No. 12-166B, dated February 28, 2013.

Serial No.14-391 Docket Nos. 50-338/339 Order EA-12-051 Attachment Page 9 of 9

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.

3. Virginia Electric and Power Company'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-12-051), dated February 28, 2014 (Serial No. 12-166E).

4. NEI 12-02 (Revision 1), Industry Guidance for Compliance with NRC Order EA 051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 2012.

5. "North Anna Power Station, Units 1 and 2: 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," dated November 1, 2013.