ML14245A402

Surry, Units 1 & 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)

ML14245A402
Person / Time
Site:	Surry
Issue date:	08/26/2014
From:	Sartain M D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-392, EA-12-051
Download: ML14245A402 (13)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 2326110 CFR 2.202EA-12-051 itAugust 26, 2014Attention:

Document Control DeskU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Serial No.: 14-392NL&OS/MAE:

R1Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS I AND 2SIX-MONTH STATUS REPORT IN RESPONSEORDER MODIFYING LICENSES WITH REGAREINSTRUMENTATION (ORDER NUMBER EA-12-05'

.wMARCH 12, 2012 COMMISSION RELIABLE SPENT FUEL POOL

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation,"

dated March 12, 20122. Virginia Electric and Power Company's Overall Integrated Plan in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Requirements forReliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated February28, 2013 (Serial No. 12-167B)3. Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool Instrumentation (Order Number EA-12-051),

dated February 28, 2014 (Serial No.12-167D)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) pursuantto 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 ofmilestone accomplishments since the submittal of the second six-month status report(Reference 3), including any changes to the compliance method, schedule, or need for reliefand the basis.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Page 2 of 3If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. SartainVice President Nuclear Engineering Virginia Electric and Power CompanyAttachment (1)Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIACOUNTY OF HENRICOThe 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.

Hehas affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of theCompany, and that the statements in the document are true to the best of his knowledge and belief..eAcknowledged before me this ,Z -'day of 12014.My Commission Expires:

14(SEAL) tNoe~R L. Mi Notary PublicReg. # 140542my cnwt w -pmMay 31, 2018 Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Page 3 of 3cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region IIRegional Administrator Marquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257 Ms. K. R. CottonNRC Project Manager SurryU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North AnnaU. S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Six Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements forReliable Spent Fuel Pool Instrumentation August 2014Surry Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 1 of 9Six Month Status Report for the Implementation of Order EA-1 2-0511 Introduction Dominion developed an Overall Integrated Plan (OIP) (Reference

1) documenting therequirements to install reliable Spent Fuel Pool (SFP) Level Instrumentation in responseto Order EA-12-051 (the Order) (Reference 2). This attachment provides an update ofmilestone accomplishments since submittal of the last status report (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 SurryPower Station OIP for Order EA-12-051 and are current as of July 31, 2014." Submit OIP* Commence Engineering and Design" Complete Engineering and Design3 Milestone Schedule StatusThe following table provides an update to the milestone schedule supporting the OIP.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 andimplementation details are developed.

Milestone Target Activity Revised TargetCompletion Date Status Completion DateSubmit OIP Feb 2013 CompleteCommence Engineering and March 2013March2013 CompleteDesignComplete Engineering and May 2014 CompleteDesignComplete Procurement of SFP June 2014 In-Progress August 2014*Instruments Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 2 of 9Milestone Target Activity Revised TargetCompletion Date Status Completion DateCommence Installation of SFPInstruments June 2014 Not Started November 2014**Level Measurement System September 2014 Started December 2014**Functional

• The components of the SFP Level Instrumentation system required for installation have beenprocured 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 targetcompletion date.** The revised milestone target completion dates for 'Commence Installation of SFPInstruments' and 'Level Measurement System Functional' do not impact the Orderimplementation date for Surry Power Station.4 Changes to Compliance MethodThere are no changes to Dominion's compliance method with NEI 12-02 (Reference 4).5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dominion expects to comply with the Order implementation date, and no requiredrelief/relaxation has been identified at this time.6 Open Items from Overall Integrated Plan and Interim Staff Evaluation No open items were identified in the Surry Power Station Overall Integrated Plan.However, the Requests for Additional Information (RAIs) identified in the Interim StaffEvaluation (Reference

5) are considered as Open Items. The following table provides asummary of these RAI Open Items from the Surry Power Station Interim StaffEvaluation and the status of each item. Several of the RAIs in the following table havebeen addressed as part of the on-going NRC audit process for the Order regarding FLEX Mitigating Strategies, EA-12-049 (Reference 6). Per direction from the NRCProject Manager, this process has been applied to the Order regarding Spent FuelLevel Instrumentation, EA-12-051.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 3 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide a clearly labeled sketch or marked-up The response to this RAIplant drawing of the plan view of the SFP area, depicting has been addressed as partthe SFP inside dimensions, the planned locations/

of the on-going NRC auditplacement of the primary and back-up SFP level sensor, process for Order EA-1 2-and the proposed routing of the cables that will extend 051.from these sensors toward the location of the read-out/display device.Provide the following:

The response to this RAIhas been addressed as parta) The design criteria that will be used to estimate the of the on-going NRC audittotal loading on the mounting device(s),

including static process for Order EA-12-weight loads and dynamic loads. Describe the 051methodology that will be used to estimate the totalloading, inclusive of design basis maximum seismicloads and the hydrodynamic loads that could result frompool sloshing or other effects that could accompany suchseismic forces.2 b) A description of the manner in which the level sensorwill be attached to the refueling floor and/or othersupport structures for each planned point of attachment of the probe assembly.

Indicate in a schematic theportions of the level sensor that will serve as points ofattachment 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 sensorassembly.

For RAI 2(a) above, please provide the analyses used to The response to this RAIverify the design criteria and methodology for seismic was provided in Attachment testing of the SFP instrumentation and the electronics 2 to the February 28, 20143 units, including, design basis maximum seismic loads Six-Month Status Reportand the hydrodynamic loads that could result from pool letter (Reference 3).sloshing or other effects that could accompany suchseismic forces.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-1 2-051Attachment Page 4 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusFor each of the mounting attachments required to attach The response to this RAISFP Level equipment to plant structures, please has been addressed as part4 describe the design inputs, and the methodology that of the on-going NRC auditwas used to qualify the structural integrity of the affected process for Order EA-1 2-structures/equipment.

051.Please provide analysis of the maximum expected The response to this RAIradiological conditions (dose rate and total integrated has been addressed as partdose) to which the equipment (including transmitters, of the on-going NRC auditcontrol boxes, and display panels) will be exposed.

Also, process for Order EA-12-5 please provide documentation indicating how it was 051.determined that the electronics for the SFP levelinstrumentation is capable of withstanding a totalintegrated dose of lX104 Rads. Please discuss the timeperiod over which the analyzed total integrated dose wasapplied.Please provide information indicating (a) what are the The response to this RAItemperature ratings and whether the temperature ratings has been addressed as partfor the system electronics (including transmitters, control of the on-going NRC auditboxes, and display panels) are continuous duty ratings, process for Order EA-12-6 and (b) what will be the maximum expected ambient 051.temperature in the rooms in which the systemelectronics will be located under BDB conditions in whichthere are no AC power available to run HeatingVentilation and Air Conditioning (HVAC) systems?Please provide information indicating the maximum The response to this RAIexpected relative humidity in the rooms in which the has been addressed as part7 system electronics will be located under BDB conditions, of the on-going NRC auditin which there are no AC power available to run process for Order EA-12-performing its required functions under this expected 051.humidity condition.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 5 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide information describing the evaluation of The response to this RAIthe comparative sensor design, the shock test method, was provided in Attachment test results, and forces applied to the sensor applicable 2 to the February 28, 20148 to its successful tests demonstrating that the referenced Six-Month Status Reportprevious testing provides an appropriate means to letter (Reference 3).demonstrate reliability of the sensor under the effects ofsevere shock.Please provide information describing the evaluation of The response to this RAIthe comparative sensor design, the vibration test was provided in Attachment method, test results, and the forces and their frequency 2 to the February 28, 2014ranges and directions applied to the sensor applicable to Six-Month Status Reportits successful tests, demonstrating that the referenced letter (Reference 3).previous testing provides an appropriate means todemonstrate reliability of the sensor under the effects ofhigh vibration.

Please provide information describing the evaluation of The response to this RAIthe comparative system electronics (including was provided in Attachment transmitters, control boxes, and display panels) ratings 2 to the February 28, 201410 against postulated plant conditions.

Also provide results Six-Month Status Reportof the manufacturer's shock and vibration test methods, letter (Reference 3).test results, and the forces and their frequency rangesand directions applied to the system electronics anddisplay panel associated with its successful tests.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 6 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide the following:

The response to this RAIwas provided in Attachment a) A description of the testing and/or analyses that will 2 to the February 28, 2014be conducted to provide assurance that the equipment Six-Month Status Reportwill perform reliably under the worst-case credible design letter (Reference 3).basis loading at the location where the equipment will bemounted.

Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensormounted in the SFP area, and (b) any control boxes,electronics, or read-out and retransmitting devices thatwill be employed to convey the level information from thelevel sensor to the plant operators or emergency responders.

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

For RAI #11 above, please provide the results for the The response to this RAIselected

methods, tests and analyses used to was provided in Attachment 12 demonstrate the qualification and reliability of the 2 to the February 28, 2014installed equipment in accordance with the Order Six-Month Status Reportrequirements.

letter (Reference 3).Please provide the following:

The response to this RAIhas been addressed as parta) A description of the electrical AC power sources and of the on-going NRC auditcapabilities for the primary and backup channels.

process for Order EA-12-13 051.13 b) Please provide the NRC staff with the finalconfiguration of the power supply source for eachchannel so that the staff may conclude that the twochannels are independent from a power supplyassignment perspective.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 7 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide the results of the calculation depicting The response to this RAIthe battery backup duty cycle requirements was provided in Attachment 14 demonstrating that its capacity is sufficient to maintain 2 to the February 28, 2014the level indication function until offsite resource Six-Month Status Reportavailability is reasonably assured.

letter (Reference 3).Please provide the following:

The response to this RAIwas provided in Attachment a) A description of the methodology that will be used for 2 to the February 28, 2014determining the maximum allowed deviation from the Six-Month Status Reportinstrument channel design accuracy that will be letter (Reference 3).employed under normal operating conditions as anacceptance criterion for a calibration procedure to flag tooperators and to technicians that the channel requires15 adjustment to within the normal condition designaccuracy.

b) Please provide analysis verifying that the proposedinstrument performance is consistent with theseestimated accuracy normal and BDB values. Pleasedemonstrate that the channels will retain these accuracyperformance values following a loss of power andsubsequent restoration of power.Please provide the following:

The response to this RAIhas been addressed as parta) For both SFP level instrumentation read-out/displays of the on-going NRC auditlocated outside the main control room, please describe process for Order EA-12-the evaluation used to validate that the display location 051.can be accessed without unreasonable delay following aBDB event. Include the time available for personnel toaccess the display as credited in the evaluation, as well16 as the actual time (e.g., based on walk-throughs) that itwill take for personnel to access the display.

Additionally, please include a description of the radiological andenvironmental conditions on the paths personnel mighttake. Describe whether the display location remainshabitable for radiological, heat and humidity, and otherenvironmental conditions following a BDB event.Describe whether personnel are continuously stationed at the display or monitor the display periodically.

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 8 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide a list of the procedures addressing The response to this RAIoperation (both normal and abnormal response),

has been addressed as partcalibration, test, maintenance, and inspection of the on-going NRC audit17 procedures that will be developed for use of the spent process for Order EA-1 2-SFP instrumentation.

The licensee is requested to 051.include a brief description of the specific technical objectives to be achieved within each procedure.

Please provide the following:

The response to this RAIhas been addressed as parta) Further information describing the maintenance and of the on-going NRC audittesting program the licensee will establish and process for Order EA-12-implement to ensure that regular testing and calibration 051.is performed and verified by inspection and audit todemonstrate conformance with design and systemreadiness requirements.

Please include a description ofthe plans for ensuring that necessary channel checks,functional tests, periodic calibration, and maintenance 18 will be conducted for the level measurement system andits supporting equipment.

b) Information describing compensatory actions whenboth channels are out-of order, and the implementation procedures.

c) Additional information describing expedited andcompensatory actions in the maintenance procedure toaddress when one of the instrument channels cannot berestored to functional status within 90 days.7 Potential Interim Staff Evaluation (ISE) ImpactsIn the second Six Month Status Report letter (Reference 3), Dominion reported achange in the SFP Level Instrumentation vendor and reported conclusions of acomparison between the Westinghouse SFP Level Instrumentation design and thedetails that were previously provided to the staff and included in the ISE (Reference 5).

Serial No. 14-392Docket Nos. 50-280/281 Order EA-12-051 Attachment Page 9 of 98 References The following references support the update to the SFP Level Instrumentation OverallIntegrated Plan described in this attachment.

1. "Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051),"

Serial No. 12-167B,dated February 28, 2013.2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation,"

dated March 12, 2012.3. "Virginia Electric and Power Company's Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051),"

dated February 28,2014 (Serial No. 12-167D).

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

dated August 2012.5. Surry Power Station, Units 1 and 2: Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Implementation ofOrder EA-12-051, Reliable Spent Fuel Pool Instrumentation,"

dated November 1,2013.6. NRC Letter, "Nuclear Regulatory Commission Audits of Licensee Responses toMitigation Strategies Order EA-12-049,"

dated August 28, 2013.