RNP-RA/15-0040, Completion of Required Actions for NRC Order EA-12-051 with Regard to Reliable Spent Fuel Pool Level Instrumentation

Completion of Required Actions for NRC Order EA-12-051 with Regard to Reliable Spent Fuel Pool Level Instrumentation

ML15187A229
Person / Time
Site:	Robinson
Issue date:	06/27/2015
From:	Glover R Duke Energy Corp, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RNP-RA/15-0040
Download: ML15187A229 (32)

Text

U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 2 of7 GENERIC DESIGN INFORMATION TEMPLATE FOR RNP I

Topic I

Parameter Summary I

Vendor Design Reference I Document#

EC 89580, Attachment D -

1 1 Design I Customer technical requirements I NCP-Z-0006, Rev. 0- SFP Wide 1

Specification specification for SFPLI Range Level Instrumentation Remote Level Sensors.pdf Qualification is based on a I

Qualification analyses Doc.

combination of tests and analyses 51-9202556-005 or similarity as described below.

2 Test Strategy I Qualification tests and analyses 32-9221237-are summarized in qualification 003_Calc_Qualification for a analyses report 51-9202556-005.

Waveguide Support and Horn End Assembly Environmental qualification for Qualification Analyses Doc.

3 electronics Temperature, humidity and dose 51-9202556-005 Section 2.3 enclosure with display Measurement capability through saturated steam and smoke.

Testing performed to demonstrate the radar horn cover was effective Environmental at preventing moisture intrusion Qualification Analyses Doc.

testing for level within the horn and wave guide 51-9202556-005, Section 2.3, sensor pipe.

2.4, 2.5, 2.7, Appendix Band components in supporting references SFP area-Radar horn cover (fused silica 66-9200846-002 4

Saturated glass), metal waveguide pipe and 51-9220845-001 steam &

horn are not susceptible to 51-9221032-000 radiation radiation degradation.

66-9225632-000 Manufacturer test data supports acceptable radiation degradation resistance for the radar horn cover adhesive.

Qualification Analyses Doc.

51-9202556-005, Sections Environmental 2.3, 2.5, Appendix A and testing for level Temperature and humidity testing supporting references sensor and analysis of sensor and 38-9218218-000, electronics indication 38-9218214-000, housing-USNRC Bulletin 79-01 B Table 5

outside SFP C-1, Reg. Guide 1.209 Additional Comments EA-12-051, NEI-12-02 EA-12-051, 1.4 NEI-12-02, 3.4 NEI 12-02, 3.4 EA-12-051, 1.4 NEI 12-02, 3.4 NEI 12-02, 3.4 Test or Analysis Results N/A Test and analyses results meet requirements of EA 21-051, JLD-ISG-2012-03, and NEI12-02 Rev. 1-Temperature rating of Power Control Panel 149°F allowing for 9°F rise above ambient.

NEMA 4X enclosure prevents moisture intrusion.

Radiation withstand analyzed to 1 x1 03 Rads Initial testing (without horn cover) demonstrated successful measurement capability through steam and smoke. Subsequent testing of the radar horn and cover demonstrated adequate operation during sustained simulated SFP boiling conditions, and that the horn cover was effective in preventing moisture intrusion within the horn and wave guide pipe.

The horn cover adhesive is a silicone elastomer manufactured by Down Corning (Sylgard 170).

The adhesive manufacturer radiation test data adequately demonstrates the adhesive would not experience unacceptable degradation for exposures up to 1.64 x1 08 Rads.

Sensor and indication are demonstrated to withstand the manufacturer ratings 80°C (sensor) and 70°C (indication), 100% RH. Radiation withstand analyzed to 1 x1 03 Rads.

Licensee Evaluation The vendor instrumentation design was reviewed and determined to adequately meet the specification requirements.

The vendor qualification documentation was reviewed and concluded to adequately demonstrate the instrumentation could reliably function in its installed environment(s) during a postulated Beyond Design Bases External Event (BDBEE).

The primary channel instrumentation electronics are located outside the SFP area. The vendor instrumentation design temperature, humidity, and dose limits bound the expected environmental conditions during a postulated BDBEE.

The radar horn cover qualification testing adequately demonstrated acceptable operation during exposure to simulated SFP boiling conditions.

The horn cover adhesive manufacturer radiation test data adequately demonstrated the adhesive would not experience unacceptable degradation for radiation exposure in excess of that expected for the postulated beyond design bases event over the required mission time.

The level sensor electronic housing are located outside the SFP area. The vendor instrumentation design temperature, humidity, and dose limits bound the expected environmental conditions during a postulated BDBEE.

U. S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 3 of7 Topic Parameter Summary Radar horn cover (fused silica glass), metal waveguide pipe and Thermal &

horn are not susceptible to Radiation Aging radiation degradation.

6

- organic components in Horn cover adhesive manufacturer SFP area radiation test data and temperature withstand specifications.

SFPLI remote transmitter and Basis for Dose power control panel qualified to Requirement 1 x1 03 Rads based on industry operating experience.

7 Based on engineering judgment, the expected total integrated dose for the radar horn cover adhesive would not exceed 1 x1 06 Rads over the required mission time for the instrumentation.

Seismic withstand capability of Seismic VEGAPULS 62 ER sensor,

8 Qualification indicators, power control panel, mounting brackets, waveguide pipe Sloshing NRC RAis indicated a SFP seismic induced sloshing analyses is required. If wave impact is predicted, then the hydrodynamic forces should be included in the mounting design loading 9

combinations.

Vendor Design Reference Document#

Qualification analyses Doc.

51-9202556-005, Section 2.5 51-9221032-000 66-9225632-000 AREVA Document No. 51 -

9202556-005, Qualification Analysis of VEGAPULS 62 ER Through Air Radar 51-9221032-000 66-9225632-000 Qualification analyses Doc.

51-9202556-005, Section 2.1, Appendix D and supporting references 11-9203036-000, 17 4-9213558-006 Allowable seismic combined with hydrodynamic loading that the horn mounting can withstand is analyzed in 32-9221237-003.

Predicted loading from impact and drag due to slosh is calculated in Attachment BH 9221237-003 Calc Qualification for a Waveguide Support and Horn End Assembly. verification and sensitivity study to predict slosh phenomena is evaluated in Attachment AW, NAI-1809-004 Hydraulic Response Calc.

Additional Licensee Evaluation Test or Analysis Results Comments Thermal and radiation aging not applicable to metal waveguide in SFP area. The horn cover The glass and metallic instrumentation components located within the SFP area adhesive is a silicone elastomer manufactured are not susceptible to aging due to thermal and/or radiation effects.

by Down Corning (Sylgard 170). The adhesive manufacturer radiation test data adequately The horn cover adhesive manufacturer radiation test data adequately EA-12-051, 1.4 demonstrates the adhesive would not experience demonstrated the adhesive would not experience unacceptable degradation for NEI12-02, 3.4 unacceptable degradation for exposures up to radiation exposure in excess of that expected for the postulated bey?nd design 1.64 x106 Rads. The silicone adhesive is rated bases event over the required mission time. The horn cover adhes1ve to withstand temperatures extremes of -45 to temperature ratings are acceptable and readily bound the expected conditions for 200°C, which adequately bound the postulated the postulated beyond design bases event.

temperatures for sustained SFP boiling conditions.

Analyses based on operating experience A location specific dose calculation was performed for the remot~ electr?nics, concludes the electronics are not susceptible to which demonstrated the sensor total integrated dose (TID) over 1ts requ1red degraded performance up to this dose threshold.

mission time is enveloped by the vendor instrumentation design limit of 1 x1 03 The adhesive manufacturer radiation test data Rads.

NEI12-02, 3.4 adequately demonstrates the adhesive would not The horn cover adhesive manufacturer radiation test data adequately experience unacceptable degradation for demonstrated the adhesive would not experience unacceptable degradation for exposures up to 1.64 x1 06 Rads.

radiation exposure in excess of that expected for the postulated beyond design bases event over the required mission time.

VEGAPULS 62 ER sensor, indicators, power The vendor instrumentation seismic testing adequately demonstrates the NEI 1-02, 3.4 control panel, mounting brackets, waveguide equipment is capable of reliably operating during a seismic event.

pipe are seismically qualified toRRS levels from EPRI TR-1 07330 Seismic induced sloshing analyses concluded that wave impact on the horn end assembly is The vendor horn end mounting can withstand the expected seismic and N/A predicted and the expected combined hydrodynamic loading caused by sloshing during a postulated BDBEE.

hydrodynamic and seismic forces are less than the allowable hydrodynamic and seismic forces.

U. S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 4 of7 Spent Fuel Pool instrumentation Functionality testing was 10 system performed during the factory functionality test acceptance test. See #16 procedure 11 Boron Build-Up Not applicable to Robinson Test and analyses were performed for the horn cover and Pool-side adhesive to demonstrate adequate 12 Bracket Seismic seismic withstand capability.

Analysis Perform seismic induced sloshing analyses to assess hydrodynamic wave force on the radar horn.

Additional Brackets (Sensor Seismic withstand of sensor 13 Electronics and brackets and electronic enclosure Electronic mounting Enclosure)

AREVA Doc. 51-9228351-000, "Through Air Radar Spent Fuel Pool Level Instrument (SFPLI) Factory Acceptance Test (FAT)

Report for H.B. Robinson" N/A Qualification analyses Doc.

51-9202556-005 and supporting reference 17 4-9213558-006, Calculations 32-9208751-002, 32-9221237-003 51-9221 032-000 66-9225632-000 66-9225469-000 Sloshing analyses was performed by an alternate vendor than the vendor whom supplied the radar level instrumentation Predicted loading from impact and drag due to slosh is calculated in Attachment AW-NAI-1809-004 Hydraulic Response Calc Qualification analyses Doc.

51-9202556-005, Section 2.1, Appendix D and supporting references 11-9203036-002, EPRI TR-107330, 17 4-9213558-006 Calculations 32-9208751-002, 32-9221237-003 32-9221971-000 CPL-HBR2-S-001, Rev. 10, "Specifications for standard supports" The vendor factory acceptance test demonstrated reliable operation of the SFP N/A Testing demonstrated that the SFPLI met the level instrumentation under normal conditions and under various simulated test specification functional requirements.

conditions (e.g. steam exposure). The testing demonstrated the instrumentation met design accuracy and repeatability specifications.

N/A N/A N/A I

Waveguide horns including the mounting are seismically qualified to EPRI TR-107330 or site-specific RRS.

The test and analyses of the horn cover and adhesive demonstrate adequate Testing and analyses horn cover and adhesive seismic withstand capability.

support the components can tolerate horizontal and vertical accelerations up to 1 OOg and SFP The vendor horn end assembly including the mounting can withstand the NEI12-02, 3.4 sloshing loads up to 3.37 psi.

expected seismic and hydrodynamic loading caused by sloshing during a postulated BDBEE.

Seismic induced sloshing analyses concluded that wave impact on the horn end assembly is predicted and the expected combined hydrodynamic and seismic forces are less than the allowable hydrodynamic and seismic forces.

Sensor brackets and electronic enclosure Sensor brackets and electronic enclosure are qualified analytically and by seismic NEI 12-02, 3.4 mounting are seismically qualified to EPRI TR-testing to adequately demonstrates the equipment is capable of reliably operating 1 07330 or site-specific RRS.

after a seismic event.

U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 5 of7 Shock and vibration withstand testing and analyses for sensor, displays, power control panel Shock &

Test and analyses were 14 Vibration performed for the horn cover and adhesive to demonstrate adequate shock withstand. Additional testing was performed for the power control panel assembly.

Qualification Analysis Doc. 51-9202556-005, Sections 2.2 and supporting references MIL-S-901 D, MIL-STD-167-1 38-9193058-000, EN 60068-2-27, 38-9218022-000, NEI 12-02, 3.4 EN 60068-2-6, 38-9218023-000, 51-9221032-000 66-9225632-000 32-9221237-003 66-9225469-000 38-922804 7-000 Sensor, displays, and power control panel have been tested and/or analyzed for shock and vibration.

The test parameter values provided in IEC Standards, IEC 60068-2-6 (vibration) and IEC 60068-2-27 (shock), tables are recommendations and not mandatory testmg levels. The test parameter values were selected to be consistent with previous shock and vibration testing performed on the VEGA supplied equipment. The test parameter values specified envelope the expected levels for the equipment installed location, du~ to_ the fact that The shock and vibration testing performed for the SFP level ins~rument~tion.

the equipment is mounted to se1_sm1c st.ructure~

within the plant. This approach 1s cons1s~ent_w1th adequately demonstrates the sensor and power control panel Will be reliable m the similar technology used in the same application installed design location.

at other installations.

Seismic Qualification of the VEGAPULS 62 ER syst~m, i~cluding ~he _Power The vibration testing deviated from the IEC Control Panels and VEGADIS 62 display is summanzed m the Se1sm1c Test 60068-2-6 recommended frequency range and Report. The system was qualified to an Areva supplied OBE and SSE_ eart~quake displacement magnitude for large power plant which bounds site SSE. A seismic technical review of the vendor qualification equipment (TABLE C.2). In-lieu of the 10-55 Hz report per AD-EG-ALL-1126 Attachment 3 ~as p_erformed. The re~ort al~~

and minimum displacement of 0.15 mm contains a discussion of environmental qualification of the system m add1t1?n to recommended in TABLE C.2, the power and seismic loading. Control Room Indicators are lnternationallnstrum~nt~ wh1ch control panel vibration testing utilized a narrower have been used in Control Rooms for years in Safety-Related appllcat1on..

frequency band (5-25 Hz) and a more limiting displacement magnitude (1.6 mm). These The post modification testing will demonstrate reliable op~ratio~ of_ the values were deemed to be acceptable and instrumentation, which confirms no damage occurred dunng sh1ppm~, handling enveloping for equipment rigidly mounted to a and installation. Similarly, the performance of monthly channel funct1o~al Seismic Category I structure, based on comparisons will serve to confirm proper operation of the instrume~tat1on, or engineering judgment.

provide a means of early detection of potential instrument degradation.

The shock testing deviated from the IEC 60068-The test and analyses of the horn cover and adhesive demonstrate adequate 2-27 recommended peak acceleration and capability to withstand shock and vibration.

duration for land-based permanently installed equipment. In-lieu of the 15 g's peak acceleration and duration of 11 m-sec recommended in TABLE A.1, the power and control panel vibration testing utilized an~

acceleration of 1 Og with a 6 m-sec durat1on.

These values were deemed to be acceptable and enveloping for equipment rigidly mounted to a seismic Category I structure, based on engineering judgment.

Testing and analyses horn cover and adhesive support the components can tolerate horizontal and vertical accelerations up to 1 OOg and SFP sloshino loads up to 3.37 psi.

U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 6 of7 Requirements Not required by order 15 Traceability Inspection of waveguide, test of Factory functionality of power transfer to 16 Acceptance battery, sensor measurement Test accuracy and effects of steam and water in waveguide Normal and accident conditions 17 Channel Accuracy SFP level measurement accuracy Power Lifetime of battery backup at full 18 Consumption load Technical Application-specific information on 19 the installation, operation, and Manual maintenance of the SFPLI Periodic indication checks, 20 Calibration calibration checks, calibration N/A AREVA Doc. 51-9228351-000, "Through Air Radar Spent Fuel Pool Level Instrument (SFPLI) Factory Acceptance Test (FAT)

Report for H.B. Robinson" EC 89580 Attachment AA -

01-9228622-002_Robinson Instruction Manual Qualification Analysis Doc. 51-9202556-005, Section 2.9, EC 89580 Attachment AA 9228622-002_Robinson Instruction Manual Section 12 Attachment AA- 01-9228622-002_Robinson Instruction Manual Attachment AA- 01-9228622-002_Robinson Instruction Manual Sections 7.0 and 9.1 N/A N/A N/A The vendor factory acceptance test demonstrated reliable operation of the SFP Test demonstrates that specification level instrumentation under normal conditions and under various simulated test N/A requirements were met.

conditions (e.g. steam exposure). The testing demonstrated the instrumentation met design accuracy and repeatability specifications.

Normal conditions accuracy +/-1 inch, error due to The vendor factory acceptance test demonstrated reliable operation of the SFP EA-12-051, 1.7 all effects including 212°F saturated steam +/-3 level instrumentation under normal conditions and under various simulated test NEI12-02, 3.7 inches.

conditions (e.g. steam exposure). The testing demonstrated the instrumentation Accuracy verified during factory acceptance met design accuracy and repeatability specifications.

testing.

Based on vendor analyses the battery capacity is deemed sufficient to support EA-12-051, 1.6, Battery capacity at full load is expected to easily reliable instrument channel operation until off-site resources can be deployed by NEI 12-02, 3.6 the mitigating strategies in response to Order EA-12-049.

exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

N/A The vendor technical manual has been reviewed, accepted and incorporated in N/A the engineering change package.

EA-12-051, 1.8 NEI 12-02, 3.8 Based on negligible drift rate of VEGA electronics experienced over large user base, The vendor technical manual has been reviewed, accepted and incorporated in periodic calibration N/A the engineering change package.

is not needed.

Functional verification can be achieved using cross channel checks and functional checks

• per vendor manual.

U.S. Nuclear Regulatory Commission to Serial: RNP-RA/15-0040 Page 7 of7 Failure Modes and Effects 21 Analysis (FMEA)

N/A 22 EM! Testing Emissions and susceptibility testing for VEGAPULS 62 ER N/A Qualification Analysis Doc. 51-9202556-005, Section 2.6 and supporting references 58-9214362-000, 38-9218963-000, 38-9218965-000, 38-9218966-000, 38-9218962-000, 38-9218967-000, 38-9218968-000, 38-9218969-000, 38-9218970-000, 38-9218964-000 The instrumentation is required to function to provide SFP level indication for a beyond design bases event. Performance of a FMEA is not warranted for this N/A N/A type of an application. Reasonable assurance that both channels are not susceptible to a common mode failure is provided by satisfying the NEI 12-02 guidance.

The EMI/RFI susceptibility and emissions testing performed for the waveguide radar transmitter provides adequate assurance the instrumentation will be compatible in the design location. The testing was conservatively performed with unshielded interconnecting wiring.

VEGAPULS 62 ER has been tested for N/A emissions to both MIL and IEC standards and for Post-modification testing will further demonstrate acceptable operation in the susceptibility to IEC standards installed location.

During a postulated BDBEE, it is possible that intermittent UHF radio operation could occur in the vicinity of the radar transmitter. Successful long-term SFP monitoring capability during a postulated BDBEE would not be inhibited by potential intermittent radio transmission interference.