ML19141A374

ABWR DC Renewal SER Section 22 Fukushima Design Related Changes Revision 5

ML19141A374
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Site:	05200045
Issue date:	06/19/2019
From:	James Shea NRC/NRO/DLSE
To:
Shea J
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ML19141A315	List: ML19141A371 ML19141A374
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Download: ML19141A374 (8)

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22.0 REQUIREMENTS RESULTING FROM FUKUSHIMA NEAR-TERM TASK FORCE RECOMMENDATIONS This chapter of the U.S. Nuclear Regulatory Commissions (NRCs) safety evaluation report (SER) provides the NRC staff evaluation of the Fukushima Near-Term Task Force (NTTF) recommendations that the staff requested General Electric Hitachi (GEH), the applicant, to address for the Advanced Boiling-Water Reactor (ABWR) Design Certification (DC) Renewal.

The staff determined that the applicable NTTF recommendations include the following three topics: mitigation strategies for beyond-design-basis external events (related to Recommendation 4.2), spent fuel pool (SFP) instrumentation (related to Recommendation 7.1),

and emergency preparedness (EP) staffing and communications (related to Recommendation 9.3).

Background:

In response to the events at Fukushima resulting from the March 11, 2011, Great Tohoku earthquake and tsunami in Japan, NRC established the NTTF to conduct a systematic and methodical review of NRC processes and regulations (1) to determine whether the agency should make additional improvements to its regulatory system, and (2) to make recommendations to the Commission for policy directions. In July 2011, the NTTF issued a 90-day report, SECY-11-0093, Near Term Report and Recommendations for Agency Actions Following the Events in Japan, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11186A950) identifying 12 recommendations. On September 9, 2011, in SECY-11-0124, Recommended Actions to Be Taken Without Delay From The NTTF Report, (ADAMS Accession No. ML11245A127), the staff submitted to the Commission for its consideration NTTF recommendations that can and, in the staffs judgment, should be partially or entirely initiated without delay. In SECY-11-0124, the staff identified and concluded that specific actions to address a subset of the NTTF recommendations would provide the greatest potential for improving safety in the near term. The staff also proposed to the Commission in SECY-11-0137, Prioritization of Recommended Actions to Be Taken in Response to Fukushima Lessons Learned, (ADAMS Accession No. ML11269A204), three tiers of prioritization for the NTTF recommendations. The first tier consists of those NTTF recommendations that the staff determined should be started without unnecessary delay and for which sufficient resource flexibility, including availability of critical skill sets, exists. The second tier consists of those NTTF recommendations that could not be initiated in the near term due to factors that include the need for further technical assessment and alignment, dependence on Tier 1 issues, or availability of critical skill sets.

In SECY-12-0025, Proposed Orders And Requests For Information In Response To Lessons Learned From Japans March 11, 2011, Great Tohoku Earthquake And Tsunami, (ADAMS Accession No. ML12039A111), the staff stated that all combined operating license (COL) applicants would be asked to provide the requisite Tier 1 information addressed in the orders and the requests for information through the review process. The staff had determined that the following three Tier 1 NTTF Fukushima recommendations should be addressed by the COL applicants at the time and the staff determined that the ABWR DC Renewal applicant should address design change proposals to address the following Tier 1 NTTF recommendation topics for potential future ABWR DC COL applicants; 22-1

1. Recommendation 4.2: Equipment covered under Title 10 Code of Federal Regulations (10 CFR) 50.54(hh)(2) - Order licensees to provide reasonable protection for equipment currently provided pursuant to 10 CFR 50.54(hh)(2) from the effects of design-basis external events, and to add equipment as needed to address multiunit events while other requirements are being revised and implemented.

2. Recommendation 7.1: Spent fuel pool instrumentation - Order licensees to provide sufficient safety-related instrumentation, able to withstand design-basis natural phenomena, and to monitor SFP parameters (i.e., water level, temperature, and area radiation levels) from the control room.

3. Recommendation 9.3: Emergency preparedness regulatory actions (staffing and communications.

In a letter dated July 20, 2012 (ADAMS Accession No. ML12125A385), the NRC staff identified 28 items for GEHs consideration as part of their application to renew the ABWR DC. The applicant was requested by the staff in Items No. 26, 27 and 28 of the July 20, 2012 letter to identify design changes that would allow a COL applicant to address the NTTF Fukushima Recommendations of 4.2, 7.1, and 9.3. These requested changes were identified in the staff letter as Issues 26, 27, and 28, respectively, and are addressed separately below.

22.1 Mitigation Strategies for Beyond-Design-Basis External Events (Recommendation 4.2) 22.1.1 Introduction During the initial review of the ABWR DC Renewal, the staff requested that GEH provide proposed changes to the ABWR design to address NTTF Recommendation 4.2 regarding mitigation strategies for beyond design-basis external events. SECY-12-0025 states that the staff will request all COL applicants to provide the information addressed in the orders (EA 049, EA-12-050, and EA-12-051) through the review process. For mitigation strategies for beyond-design-basis external events, SECY-12-0025 outlines a three-phase approach. The initial phase involves the use of installed equipment and resources to maintain or restore core cooling, containment, and SFP cooling without alternating current (AC) power. The transition phase involves providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from offsite. The final phase involves obtaining sufficient offsite resources to sustain those functions indefinitely.

In the staffs July 20, 2012 letter with 28 items for GEH consideration, the staff requested that GEH address a compilation of design changes that the agency considers to be regulatory improvements or changes that could meet the 10 CFR 52.59(b) criteria. In this letter the staff requested that GEH identify the design changes that would be incorporated into the DC Renewal design control document (DCD) related to aspects of the Fukushima Recommendation 4.2 regarding mitigation strategies for beyond-design-basis external events, Item number 26 of the staff letter. GEH responded to the staff in the following letters to address its design changes proposed to allow a potential COL applicant to meet requirements related to mitigation strategies. On September 17, 2012 (ADAMS Accession No. ML12261A311), GEH responded to staff design suggestions by agreeing to address the staff issues and to submit Revision 6 of the ABWR DCD addressing the staff suggested items including Item 26 on mitigating strategies. In a letter dated September 9, 2015 (ADAMS Accession No. ML15254A042), GEH provided a detailed specific response with DCD markups to address 22-2

Item 26 on mitigation strategies which was a follow-up from a public meeting on the issue on May 7, 2015 (ADAMS Accession No. ML15162A613). The applicant provided details to address of the March 12, 2012 Mitigating Strategies Order (ADAMS Accession No. ML12054A735) as requested by the staff in the July 20, 2012 letter and after the May 7, 2015 public/non-public meeting. In a public teleconference with the NRC on March 17, 2016 (ADAMS Accession No. ML16124A049), the NRC staff requested that GEH clarify the ABWR response to a Beyond Design Basis Event (BDBE) with specific information items to be provided by the COL applicant that would also address the pending draft Mitigation of Beyond Design Basis Events (MBDBE) rule (10 CFR 50.155). Therefore, in a letter dated April 29, 2016 (ADAMS Accession No. ML16120A032), GEH submitted its proposed resolution and supplemental information as requested by the staff during the March 17, 2016 public teleconference, including the DCD Revision 6 markups and a proposed new Appendix 1D to the ABWR DCD that addresses the ABWR response to a BDBE. In a supplemental letter on August 24, 2016 (ADAMS Accession No. ML16237A121), GEH provided additional updates to the previously submitted Appendix 1D and Enclosure 2 to the letter including the DCD markups associated with its supplemental response. GEH describes how a licensee of an ABWR plant would use certain design features that are onsite, and what features are available when the plant transitions to using the equipment that could be brought in from offsite to maintain the plant in a safe condition.

As the proposed draft MBDBE rule was being finalized it became clear that the staff would not require existing DCs including the ABWR to include operational matters, such as the elements of the proposed MBDBE rule. Therefore, the proposed draft rule is consistent with the issue finality provision in 10 CFR 52.63 for the ABWR. This clarification for DCs is described in more detail in the proposed rule regulatory analysis (ADAMS Accession No. ML15266A133).

Therefore, in a letter dated December 6, 2016 (ADAMS Accession No. ML16341A812),

regarding the latest public information related to the pending final rule and considering that no requirements would be applicable to applicants for a standard DC (or a DC renewal, as in the case of the ABWR application), GEH stated in its letter that it planned to submit a revised response for addressing Item 26 by the end of January 2017. The revised response would provide a complete description of the changes to the ABWR DCD that would remove references to Recommendation 4.2 mitigating strategies (e.g., Appendix 1D). In its follow up response to its December 6, 2016 letter, GEH on January 23, 2017 (ADAMS Accession No. ML17025A386) submitted its final proposal to remove references to Recommendation 4.2 mitigating strategies (e.g., proposed Appendix 1D of the ABWR DCD). In addition, to the extent that certain design features have been proposed in response to Item 26, GEH identified in its revised response which of those will be retained for NRC review as design changes in the renewal application (e.g., external connections for power and water; and enhanced systems capability for residual heat removal and reactor core isolation cooling). Therefore, the staff reviewed these design enhancements in separate staff SERs as follows:

• Tier 1 & 2 Chapter 5, Reactor Coolant System and Connected Systems.

Supplemental SER Section 5.4.7.1.1.10, ACIWA, provides the staff evaluation of the DCD design amendment proposed by GEH for the addition of a redundant alternating current independent water addition (ACIWA) capability to the residual heat removal system (RHR) Loop B and to provide clarity on the wetwell spray and SFP makeup capabilities of the ACIWA system. This GEH DCD proposed amendment could provide a potential COL applicant the means for meeting the proposed MBDBE rule.

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• Tier 2 Chapter 5, Reactor Coolant System and Connected Systems.

Supplemental SER Section 5.4.7, Residual Heat Removal System, provides the staff evaluation of the DCD design amendment proposed by GEH for a redundant ACIWA mode to the residual heat removal system (RHR) Loop B. This GEH DCD proposed amendment could provide a potential COL applicant the means for meeting the proposed MBDBE rule.

• Tier 2 Chapter 7, Instrumentation and Control Systems.

Supplemental SER Section 7.4.1.4.4, Shutdown Panel, provides the staff evaluation of the DCD design amendment proposed by GEH for additional controls and indications on the ABWR Remote Shutdown Panel. These additional controls and indications improve the diversity and defense in depth during beyond design basis events and could provide a potential COL applicant the means for meeting the proposed MBDBE rule.

• Tier 2 Chapter 8, Electric Power.

Supplemental SER Section 8.3.4.4, Isolation Between Class 1E Buses and Loads Designated as Non-Class 1E, provides the staff evaluation of the DCD design amendment proposed by GEH for a capability to provide electrical power to safety-related loads from an external non-safety power source. This GEH DCD proposed amendment could provide a potential COL applicant the means for meeting the proposed MBDBE rule.

• Tier 2 Chapter 16, Technical Specifications.

Supplemental SER Section 16, Technical Specifications, provides the staff evaluation of the DCD design amendment proposed by GEH for addition of ACIWA mode to Residual RHR Loop B (currently available for RHR Loop C), affecting TS 3.5.1, ECCS-Operating, and TS 3.6.2.4, RHR Containment Spray; and, additional controls and indications on the ABWR Remote Shutdown Panel. These additional controls and indications improve the diversity and defense in depth during beyond design basis events and could provide a potential COL applicant the means for meeting the proposed MBDBE rule.

22.2 Reliable Spent Fuel Pool Instrumentation (Recommendation 7.1) 22.2.1 Introduction In this section, the staff evaluates the design change proposed by GEH to the ABWR NTTF Recommendation 7.1 regarding SFP reliable level instrumentation. These proposed design changes affect the following ABWR design control document (DCD)

Chapters. SER Sections as outlined below are established separately as pointers to the reader to review this supplemental SER Section for the staffs technical evaluation of the GEH proposed ABWR design change for safety-related SFP instrumentation that addresses the NTTF Recommendation 7.1 on reliable level instrumentation.

• Tier 2 Chapter 3, Design of Structures, Components, Equipment and Systems.

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Supplemental SER Section 3.2.3, Safety Classifications, provides a pointer to this SER Section for the staff evaluation of the design changes proposed by GEH for the SFP level instrumentation to address the NTTF recommendation for reliable SFP instrumentation.

• Tier 2 Chapter 7, Instrumentation and Control Systems.

Supplemental SER Section 7.5.2.1, Post Accident Monitoring System, provides a pointer to this SER Section for the staff evaluation of the design changes proposed by GEH for the SFP level instrumentation to address the NTTF recommendation for reliable SFP instrumentation.

• Tier 2 Chapter 9, Auxiliary Systems.

Supplemental SER Section 9.1.3, Fuel Pool Cooling and Cleanup System, provides a pointer to this SER Section for the staff evaluation of the design changes proposed by GEH for the SFP level instrumentation to address the NTTF recommendation for reliable SFP instrumentation.

On March 11, 2011, a magnitude 9.0 earthquake struck off the coast of the Japanese island of Honshu. The earthquake resulted in a large tsunami that is estimated to have exceeded 14 meters (45 feet) in height, which inundated the Fukushima Dai-ichi Nuclear Power Plant site.

The tsunami caused extensive damage to site facilities and resulted in a complete loss of all AC electrical power at 5 of the 6 units on the site. In responding to and managing this damage, the plant operators lacked, among other things, reliable instrumentation to determine the water level in the SFPs on the site. This lack, combined with the operators inability to visually observe the SFPs because of the conditions in the plant, raised concerns that at least one pool may have boiled dryresulting in fuel damageand highlighted the need for reliable SFP instrumentation.

Although the likelihood of a catastrophic event affecting nuclear power plants and the associated SFPs in the United States remains very low, beyond-design-basis external events could challenge the ability of existing SFP instrumentation to provide emergency responders with reliable information on the condition of SFPs. A reliable and available indicator is essential to ensure that plant personnel can effectively prioritize emergency actions.

A NRC paper, SECY-12-0025 (ADAMS Accession No. ML12039A111), Proposed Orders and Requests for Information in Response to Lessons Learned from Japans March 11, 2011, Great Tohoku Earthquake and Tsunami, states that for design certifications and combined license applications submitted under 10 CFR Part 52 that are currently under active staff review, the staff plans to ensure that the Fukushima actions approved by the Commission are addressed before certification or licensing.

The Japan Lesson-Learned Project Directorate-Interim Staff Guidance (JLD-ISG)-2012-03 Revision 0 (ADAMS Accession No. ML12221A339), Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, endorses with exceptions and clarifications the methodologies described in the Nuclear Energy Institute (NEI) industry guidance document NEI 12-02 (ADAMS Accession No. ML122400399) Revision 1, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, and provides an acceptable approach for satisfying the applicable requirements.

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22.2.2 Regulatory Criteria The applicant proposed safety-related SFP level instrument design changes to the GEH ABWR DCD to provide reliable SFP level indication from the normal range to a level down to one meter below the top of active fuel. In addition, the instrument can be powered from an independent power source and power interruption will not impact the design accuracy. Therefore, in accordance with 10 CFR 52.59(c), this design change is an amendment, as this term is defined in Chapter 1 of this SER supplement and will correspondingly be evaluated using the regulations in effect at renewal.

The applicant included a COL Information Item under DCD Section 7.5.3, describing the maintenance, implementation and training for these safety-related SFP level instruments. The applicant in addition added a DCD Section 7.5.4, listing the pertinent references used to implement the Commission Order regarding reliable SFP instrumentation.

The relevant requirements for reliable SFP instrumentation are established or described in the following:

• SRM-SECY-12-0025, Staff Requirements - SECY-12-0025 - Proposed Orders and Requests for Information in Response to Lessons Learned from Japans March 11, 2011, Great Tohoku Earthquake and Tsunami, dated March 9, 2012, approves the issuance of orders for reliable SFP instrumentation under an administrative exemption to the Backfit Rule and the issue finality requirements in 10 CFR 52.63 and 10 CFR Part 52 Appendix A, Paragraph VIII (ADAMS Accession No. ML120690347).

• Atomic Energy Act of 1954 as amended (the Act), Section 161, authorizes the Commission to regulate the utilization of special nuclear material in a manner that is protective of public health and in accordance with common defense and security.

The relevant guidance for reliable SFP instrumentation is set forth in as follows:

• The Japan Lesson-Learned Project Directorate-Interim Staff Guidance (JLD-ISG)-2012-03, Revision 0 (ADAMS Accession No. ML12221A339), Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, which endorsed, with exceptions and clarifications, the methodologies described in the Nuclear Energy Institute (NEI) industry guidance document NEI 12-02 (ADAMS Accession No. ML122400399) Revision 1, Industry Guidance for Compliance with NRC Order EA-12-051, to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation.

22.2.3 Summary of Technical Information By letter dated September 25, 2014 (ADAMS Accession No. ML14267A352), the NRC staff in a Request for Additional Information (RAI) Question 01.05-1 requested that GEH address the design-related aspects of Fukushima Recommendation 7.1 regarding enhanced spent fuel instrumentation as outlined in Attachment 2 of the Commission Order EA-12-051.

The applicant responded to the staffs RAI in letters dated November 6, 2014 (ADAMS Accession No. ML14310A567), June 18, 2014 (ADAMS Accession No. ML15170A044), and August 25, 2015 (ADAMS Accession No. ML15237A192). As part of the RAI response, the 22-6

applicant proposed to add SFP level instruments that comply with applicable guidance. This change resulted in DCD changes to the following Sections:

• Tier 1, Subsection 2.6.2, Figure 2.6.2 and Table 2.6.2

• Tier 2, Chapter 1, Tables 1.8-21 and 1.8-22

• Tier 2, Chapter 3, Table 3.2-1

• Tier 2, Chapter 7, Subsections 7.5.2.1, 7.5.3 and 7.5.4

• Tier 2, Chapter 9, Subsections 9.1.3.2 and 9.1.7

• Tier 2, Chapter 21, Figure 9.1-1 22.2.4 Technical Evaluation Commission Order EA-12-051 requires a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel (NEI 12-02 refers to these monitoring levels as Level 1, Level 2 and Level 3, respectively):

1. level that is adequate to support operation of the normal fuel pool cooling system,

2. level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck, and

3. level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.

In its response to RAI 01.05-1 the applicant stated that the GEH ABWR design departs from the guidance of NEI 12-02 in the choice of water level nomenclature. In accordance with Human Factors Engineering principles, the ABWR SFP and RPV water level nomenclature have been made as consistent as possible. Thus, the ABWR DCD designates SFP Level 3 as slightly below normal water level (EA-12-051 item (1) or NEI 12-02 Level 1), and Level 1 as above the top of active fuel (EA-12-051 item (3) or NEI 12-02 Level 3 above).

The staff evaluated the applicants response and found that the proposed departure from the guidance was acceptable. Changing the nomenclature of the levels has no adverse impact in safety, as long as all three levels are monitored and alarmed. During an August 13, 2015 public meeting (ADAMS Accession No. ML15230A204) with the applicant, the staff identified that the applicant had introduced an additional departure from the guidance, without providing adequate justification for how the alternative meets the SFP instrumentation requirements. In Tier 2, Section 9.1.3.2, the DCD markups (that were part of the RAI response) showed that the alarm setpoint for GEH Level 1 (lowest level) would be at the top of the active fuel. This setpoint is not consistent with NEI 12-02, Level 3 (lowest level) which corresponds to the highest point of any fuel rack seated in the SFP.

On August 20, 2015, the applicant submitted a revised response to RAI 01.05-1 based on feedback provided during the August 13, 2015 public meeting. In the revised response, GEH updated the lowest level alarm to be the top of the fuel assembly bail handle in ABWR DCD Tier 2, Subsection 9.1.3.2. The response included ABWR DCD Revision 6 Markups.

The staff finds the proposed DCD changes meet the guidance in NEI 12-02 and therefore are acceptable. The staff has confirmed that DCD Revision 6 included the markups provided in 22-7

RAI 01.05-1. Commission Order EA-12-051 also requires the SFP instrumentation to include several design features. Design features are identified (the key words are in italics) and discussed below. As discussed below, all other aspects of RAI 01.05-1 have also been resolved.

Instrument:

Commission Order EA-12-051, Attachment 2, Section 1.1 states that the SFP level instrumentation shall consist of a permanent, fixed primary instrument channel and a backup instrument channel. The backup instrument channel may be fixed or portable. Portable instruments shall have capabilities that enhance the ability of trained personnel to monitor the SFP water level under conditions that restrict direct personnel access to the pool, such as partial structural damage, high radiation levels, or high heat and humidity from a boiling pool.

The applicants response to RAI 01.05-1 states that the instrumentation will consist of two safety related, permanent and fixed instrument channels. DCD Revision 6, Tier 2, Section 7.5.2.1 states that the instruments are designed to remain reliable considering normal operational, event and post-event conditions.

The staff evaluated the applicants proposed changes to the DCD description and determined that crediting two safety-related permanently installed instruments as primary and backup channels conforms with the design features identified in staff guidance (i.e., JLD-ISG-2012-03).

Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the markups provided in the response to RAI 01.05-1.

Arrangement:

Commission Order EA-12-051, Attachment 2, Section 1.2, states that the SFP level instrument channels shall be arranged 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.

This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the SFP area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the SFP structure.

The response to RAI 01.05-1 proposed markups to DCD Tier 2, Section 9.1.3.2 and states that the SFP level instrument channels will be arranged in a manner that provides reasonable protection of the level indication function against external missiles. This protection will be provided by maintaining instrument channel separation within the SFP area and will utilize inherent shielding from missiles provided by the existing SFP structure. The channel separation guidance in NEI 12-02, Revision 1, Section 3.2, will be considered in determining sensor locations.

The staff evaluated the applicants proposed instrument location description provided in the DCD and determined that the applicants proposal conforms to staff guidance (i.e.,

JLD-ISG-2012-03). Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 22-8

is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in response to RAI 01.05-1.

Mounting:

Commission Order EA-12-051, Attachment 2, Section 1.3 states that the installed instrument channel equipment within the SFP shall be mounted to retain its design configuration during and following the maximum seismic ground motion considered in the design of the SFP structure.

DCD Tier 2, Table 3.2-1, Classification Summary, identifies that the SFP wide range level instrumentation is classified as Seismic Category I components. The staff evaluated the applicants proposed DCD description and the equipment description included in the response to RAI 01.05-1 and determined that the applicants proposal conforms to staff guidance (i.e.,

JLD-ISG-2012-03). Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-1 is resolved.

Qualification:

Commission Order EA-12-051, Attachment 2, Section 1.4 states, in part, that the primary and backup instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the SFP water at saturation conditions for an extended period.

The applicants response to RAI 01.05-1 states that the instrument channels departs from the guidance of NEI 12-02 (Revision 1) in that the instrument reliability does not need to consider post-accident conditions of borated water. Boiling-water reactor (BWR) SFPs do not use borated water. DCD Tier 2, Section 7.5.2.1 states that the augmented quality assurance process will ensure that the level instrumentation will be operational at conditions (temperature, humidity and radiation levels) in the vicinity of the SFP and the area of use considering normal operational, event and post-event conditions for no fewer than seven days post-event or until off-site resources can be deployed by the mitigating strategies.

The staff evaluated the applicants departure from the approved guidance and found it acceptable, since borated water is not used in the BWR SFP, therefore, the instruments are not expected to be exposed to post-accident borated water conditions. The staff reviewed the applicants response and the information in the DCD and determined that the instruments will be designed to remain operational during all other post-accident anticipated conditions of temperature, humidity and radiation levels and these capabilities will be demonstrated in accordance with the guidance in JLD-ISG-2012-03. Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in the response to RAI 01.05-1.

Independence:

Commission Order EA-12-051, Attachment 2, Section 1.5 states that the primary instrument channel shall be independent of the backup instrument channel.

DCD Tier 2, Section 7.5.2.1 states that the instrument channels are powered from two independent Class 1E batteries. DCD Tier 2, Section 9.1.3.2 identifies the level transmitters as safety-related independent instruments.

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The staff reviewed the applicants response to RAI 01.05-01 along with the proposed DCD changes. The staff verified that the physical separation of the channels will be sufficient to establish physical and electrical independence. Accordingly, the staff finds that this feature conforms to the guidance in JLD-ISG-2012-03. Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in the response to RAI 01.05-1.

Power Sources:

Commission Order EA-12-051, Attachment 2, Section 1.6 states, in part, that permanently installed instrumentation channels shall each be powered by a separate power supply.

Permanently installed and portable instrumentation channels shall provide for power connections from sources independent of the plant alternating current (ac) and direct current (dc) power distribution systems, such as portable generators or replaceable batteries.

In response to RAI 01.05-01, the applicant proposed changes to DCD Tier 2, Section 7.5.2.1 to indicate that the level instrument channels will be powered by Class 1E batteries. In addition, the instruments will have the capability of being powered from an independent power source.

The staff identified that the level instrument channels are powered by separate Class 1E DC batteries capable of powering the instruments. The applicant designed the system with the capability of using an alternate power source to power the level instrumentation. Based on the evaluation of the system description provided in the DCD, the staff concludes that these design features conform to the guidance in JLD-ISG-2012-03. Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in the response to RAI 01.05-1.

Accuracy:

Commission Order EA-12-051, Attachment 3, Section 1.4 states that the instrument shall maintain its designed accuracy following a power interruption or change in power source without recalibration.

In response to RAI 01.05-01 the applicant proposed changes to DCD Tier 2, Section 7.5.2.1 to clarify that an interruption of power to the instruments will not impact the design accuracy of the instruments or require recalibration of the equipment.

The staff evaluated the applicants response to RAI 01.05-01 and its proposed changes to the DCD instrument description and determined that the applicant conforms to staff guidance (i.e.,

JLD-ISG-2012-03). Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051. Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in the response to RAI 01.05-1.

Testing:

Commission Order EA-12-051, Attachment 2, Section 1.8 states that the instrument channel design shall provide for routine testing and calibration.

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The DCD described the level channels as permanently installed safety-related instrumentation.

The DCD in its COL information item, DCD Section 7.5.3.1, states that the COL applicant will provide information to ensure that SFP instrumentation shall be maintained to be available in accordance with the requirements of Commission Order EA-12-051, Attachment 2 and that the permanently installed instrument channels are normally used to monitor the SFP level and will be subject to routine testing and calibration in accordance with plant procedures. Therefore, this part of the RAI 01.05-1 is resolved.

Display:

Commission Order EA-12-051, Attachment 2, Section 1.9 states that trained personnel shall be able to monitor the SFP water level from the control room, the alternate shutdown panel, or another appropriate and accessible location. The display shall provide on-demand or continuous indication of SFP water level.

In response to RAI 01.05-01 the applicant proposed changes to DCD Tier 2, Section 9.1.3.2 to indicate that SFP water level can be monitored from the control room, the Remote Shutdown Panels, or other appropriate location accessible post-accident. Tier 1, Section 2.6.2, was revised to include ITAAC 2.6.2 Item 7 which requires the verification that the safety-related level instruments provide level indication in the main control room and an alternate location.

The staff reviewed the applicants proposed changes to the system description in DCD Tier 1 and 2. The location of the level indication display, as installed, will be verified through testing, which will be confirmed through ITAAC 2.6.2-7, as discussed above. The staff finds that the applicant conforms to staff guidance (i.e., JLD-ISG-2012-03). Because the applicant conforms to staff guidance, the staff finds the applicant complies with Commission Order EA-12-051.

Therefore, this part of the RAI 01.05-01 is resolved. The staff has confirmed that Revision 6 of the DCD includes the DCD markups provided in RAI 01.05-1.

Programs:

Commission Order EA-12-051, Attachment 2, Section 2 states that the SFP instrumentation shall be maintained available and reliable through appropriate development and implementation of a training program, procedures, and a testing and calibration program. Personnel shall be trained in the use of the primary and backup instrument channels, provision of alternate power to each channel and testing and calibration of each channel. Procedures shall be established and maintained for the testing, calibration, and use of the primary and backup spent SFP instrument channels. Processes shall be established and maintained for scheduling and implementing testing and calibration of the primary and backup SFP level instrument channels sufficient to maintain them at the design accuracy.

In DCD Tier 2, Section 7.5.3, COL License Information, the applicant proposed COL Item 7.5.3.1, Spent Fuel Pool Level Instruments, which states:

In Commission Order EA-12-051, Attachment 2, Section 2 (Reference 7.5-3) states that the SFP instrumentation shall be maintained to be available and reliable through the appropriate development and implementation of a training program. Personnel shall be trained in the use and maintenance (including test 22-11

and calibration), and in the procedures for providing alternate power to the level instrument channels.

The staff finds that the COL Information Item 7.5.3.1, conforms to the guidance in JLD-ISG-2012-03, which requires the development of procedures for testing and calibration of the primary and backup SFP level instrument channel, and therefore complies with Commission Order EA-12-051. The staff has also determined that the existing commitments in Final Safety Analysis Report Section 13.5, Plant Procedures, already cover the procedures for the use of the safety-related permanently installed SFP level instrumentation. Therefore, no new commitment is needed for the development of these procedures. Accordingly, this part of the RAI 01.05-01 is resolved.

Based on the discussion presented above, the staff finds that all parts of the staffs concerns identified in the response to RAI 0.05-01 have been addressed and found acceptable, therefore RAI 01.05-01 is considered resolved and closed in its entirety.

ITAAC:

DCD Revision 6, Tier 1, Section 2.6.2 discusses a new ITAAC in Table 2.6.2 (as shown below),

to ensure that the SFP level instrumentation will be designed and installed as described in Tier 1, Section 2.6.2.

Tier 1 Table 2.6.2 Fuel Pool Cooling and Cleanup System Design Commitment Inspections, Tests, Analyses Acceptance Criteria

7. The safety-related 7. Inspections will be performed 7. Displays exist or can be displays provided for the of the safety-related FPC retrieved in both the main FPC System spent fuel system displays in both the main control room and an alternate pool wide range water control room and at an alternate location.

level are as described in location.

Section 2.6.2.

As discussed above (in Display Section), the staff finds that the proposed acceptance criteria will confirm that the installed level instrumentation meets the design functions specified in Tier 1, Section 2.6.2. Therefore, the staff finds that the proposed ITAAC is acceptable because it meets the requirements of 10 CFR 52.47(b)(1) with respect to the fuel pool cooling and cleanup system.

COL Information Item:

DCD Revision 6 includes a COL Information Item in DCD Section 7.5.3.1, which instructs the COL applicants to develop and implement a training program for the use and maintenance of the SFP level instrumentation. As discussed above (in the Testing and Programs Section of this SER), the staff finds that the proposed COL Information Item conforms to the guidance in JLD-ISG-2012-03.

22.2.5 Conclusion Order EA-12-051 requires a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the pool water level conditions by trained personnel.

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In addition, the Order requires that SFP level instrumentation include several design features (e.g., redundant instruments, separation and environment qualification). Based on the evaluation discussed above, the staff concludes that the applicants design conforms with the guidance in JLD-ISG-2012-03, where appropriate, and therefore, is acceptable. As a result, the staff finds these instruments to be reliable, able to withstand design-basis natural phenomena, and capable of monitoring key SFP level conditions that address NTTF Recommendation 7.1 and meet the relevant requirements of the March 12, 2012, Order EA-12-051.

22.3 Recommendation 9.3, Emergency Preparedness 22.3.1 Introduction The objective of EP is to ensure that the capability exists for a licensee (or will exist for a COL applicant) to implement measures that mitigate the consequences of a radiological emergency and to provide for protective actions of the public. The accident at Fukushima highlighted the need to determine the staffing needed to respond to a multi-unit event. Additionally, there is a need to ensure that the communication equipment relied on has adequate power to coordinate the response to an event during an extended loss of AC power.

In Revision 6 of the ABWR DCD, as supplemented by DCD markups included in responses to RAIs, GEH proposed changes to the design to address various aspects of emergency planning, in support of its renewal application for the ABWR standard design. The staff reviewed these separate design enhancements in a separate staff supplemental SER Section as follows:

• Tier 2 Chapter 13, Conduct of Operations.

Supplemental SER Section 13.3, Emergency Planning, provides the staff evaluation of the DCD design modifications proposed by GEH to (1) ensure that site-specific radiological protection for the technical support center (TSC) will be verified at the combined license (COL) application stage, consistent with the applicable TSC habitability guidance; and (2) provide for an assessment of staffing and communications capabilities to respond to a beyond design basis event, pursuant to certain NRC actions arising out of the U. S. Nuclear Regulatory Commissions (NRC) Fukushima Dai-ichi Near-Term Task Force (NTTF) Recommendation 9.3.

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