ML14245A401
| ML14245A401 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/26/2014 |
| From: | Sartain M D Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 14-391, EA-12-051 | |
| Download: ML14245A401 (13) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261 10 CFR 2.202EA-1 2-051August 26, 2014Attention: Document Control Desk Serial No.: 14-391U.S. Nuclear Regulatory Commission NL&OS/MAE: R1Washington, D.C. 20555-0001 Docket Nos.: 50-338/339License Nos.: NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS 1 AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSIONORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOLINSTRUMENTATION (ORDER NUMBER EA-12-051)
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. 12-166B)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.12-166E)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 effectiveand 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.DVL Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051Page 2 of 3If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely,Mark D. SartainVice President Nuclear EngineeringVirginia Electric and Power CompanyAttachment (1)Commitments made by this letter: No new Regulatory CommitmentsCOMMONWEALTH 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.Acknowledged before me thisla 3.ay of ,2014.My Commission Expires: /A VA32, 11 ..-/ I(SEAL)A" My R 140542Notary Public(SEAL) M Commissft ImMy 31, 2014 Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051Page 3 of 3cc: Director of Office of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory Commission, Region IIRegional AdministratorMarquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257Dr. V. SreenivasNRC Project Manager North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738Ms. K. R. CottonNRC Project Manager SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorNorth Anna Power StationMr. J. E. Reasor, Jr.Old Dominion Electric CooperativeInnsbrook Corporate Center, Suite 3004201 Dominion Blvd.Glen Allen, Virginia 23060 Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentSix Month Status Report for the Implementation of Order EA-12-051,Order Modifying Licenses with Regard to Requirements forReliable Spent Fuel Pool InstrumentationAugust 2014North Anna Power Station Units 1 and 2Virginia Electric and Power Company (Dominion)
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 1 of 9Six Month Status Report for the Implementation of Order EA-1 2-0511 IntroductionDominion 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 for North AnnaPower Station (Reference 3) including any changes to the compliance method,schedule, or need for relief/relaxation and the basis, if any.2 Milestone AccomplishmentsThe following milestones have been completed since the development of the NorthAnna Power Station OIP for Order EA-12-051 and are current as of July 31, 2014.SSSSSubmit OIPCommence Engineering and DesignComplete Engineering and DesignCommence Installation of SFP Instruments3 Milestone Schedule StatusThe following table provides an update to the milestone schedule supporting the NorthAnna Power Station Overall Integrated Plan. This table provides the activity status ofeach item and the expected completion date, noting any change. The target completiondates are subject to change as design and implementation details are developed.Milestone Target Activity Revised TargetCompletion Date Status Completion DateSubmit OIP February 2013 CompleteCommence Engineering and March 2013 CompleteDesignComplete Engineering and Design May 2014 CompleteComplete Procurement of SFP May 2014 In-Progress August 2014*Instruments Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 2 of 9Milestone Target Activity Revised TargetCompletion Date Status Completion DateCommence Installation of SFP June 2014 CompleteInstrumentsLevel Measurement System September 2014 StartedFunctional* 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.4 Changes to Compliance MethodThere are no changes to Dominion's compliance method with NEI 12-02 (Reference 4).5 Need for RelieflRelaxation and Basis for the Relief/RelaxationDominion expects to comply with the Order implementation date and no relief/relaxationis required at this time.6 Open Items from Overall Integrated Plan and Interim Staff EvaluationNo open items were identified in the North Anna 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 North Anna Power Station Interim StaffEvaluation and the status of each item.Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease specify which of the two identified values is the The response to this RAI wascorrect elevation for Level 1. provided in Attachment 2 to theFebruary 28, 2014 Six-MonthStatus Report letter (Reference3).
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 3 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide a clearly labeled sketch or marked-up The response to this RAI wasplant drawing of the plan view of the SFP area, depicting provided in Attachment 2 to thethe SFP inside dimensions, the planned February 28, 2014 Six-Month2 locations/placement of the primary and back-up SFP Status Report letter (Referencelevel sensor, and the proposed routing of the cables that 3).will extend from these sensors toward the location of theread-out display device.Provide the following: The response to this RAI wasprovided in Attachment 2 to thea) The design criteria that will be used to estimate the February 28, 2014 Six-Monthtotal loading on the mounting device(s), including static Status Report letter (Referenceweight loads and dynamic loads. Describe the 3)methodology 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.3 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 attachmentof the probe assembly. Indicate in a schematic theportions of the level sensor that will serve as points ofattachment for mechanical/mounting or electricalconnections.c) A description of the manner by which the mechanicalconnections will attach the level instrument to permanentSFP structures so as to support the level sensorassembly.For RAI 3(a) above, please provide the analyses used to The response to this RAI wasverify the design criteria and methodology for seismic provided in Attachment 2 to thetesting of the SFP instrumentation and the electronics February 28, 2014 Six-Month4 units, including, design basis maximum seismic loads Status Report letter (Referenceand the hydrodynamic loads that could result from pool 3)sloshing or other effects that could accompany suchseismic forces.
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 4 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusFor each of the mounting attachments required to The response to this RAI wasattach SFP Level equipment to plant structures, please provided in Attachment 2 to the5 describe the design inputs, and the methodology that February 28, 2014 Six-Monthwas used to qualify the structural integrity of the Status Report letter (Referenceaffected structures/equipment. 3)Please provide analysis of the maximum expected The response to this RAI wasradiological conditions (dose rate and total integrated provided in Attachment 2 to thedose) to which the equipment (including transmitters, February 28, 2014 Six-Monthcontrol boxes, and display panels) will be exposed. Also, Status Report letter (Reference6 please provide documentation indicating how it was 3)determined that the electronics for the SFP levelinstrumentation is capable of withstanding a totalintegrated dose of 1X104 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 RAI wastemperature ratings and whether the temperature ratings provided in Attachment 2 to thefor the system electronics (including transmitters, control February 28, 2014 Six-Monthboxes, and display panels) are continuous duty ratings; Status Report letter (Reference7 and, (b) what will be the maximum expected ambient 3)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 RAI wasexpected relative humidity in the rooms in which the provided in Attachment 2 to thesystem electronics will be located under BDB conditions, February 28, 2014 Six-Month8 in which there are no AC power available to run HVAC Status Report letter (Referencesystems, and whether the sensor electronics are 3).capable of continuously performing its required functionsunder this expected humidity condition.
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 5 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide information describing the evaluation of The response to this RAI wasthe comparative sensor design, the shock test method, provided in Attachment 2 to thetest results, and forces applied to the sensor applicable February 28, 2014 Six-Month9 to its successful tests demonstrating that the referenced Status Report letter (Referenceprevious testing provides an appropriate means to 3).demonstrate reliability of the sensor under the effects ofsevere shock.Please provide information describing the evaluation of The response to this RAI wasthe comparative sensor design, the vibration test provided in Attachment 2 to themethod, test results, and the forces and their frequency February 28, 2014 Six-Monthranges and directions applied to the sensor applicable to Status Report letter (Reference10 its successful tests, demonstrating that the referenced 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 RAI wasthe comparative system electronics (including provided in Attachment 2 to thetransmitters, control boxes, and display panels) ratings February 28, 2014 Six-Monthagainst postulated plant conditions. Also provide results Status Report letter (Referenceof the manufacturer's shock and vibration test methods,test results, and the forces and their frequency rangesand directions applied to the system electronics anddisplay panel associated with its successful tests.
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 6 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusThe response to this RAI wasPlease provide the following: provided in Attachment 2 to theFebruary 28, 2014 Six-Montha) A description of the testing and/or analyses that will Status Report letter (Referencebe conducted to provide assurance that the equipment 3).will perform reliably under the worst-case credible designbasis loading at the location where the equipment will bemounted. Include a discussion of this seismic reliabilitydemonstration as it applies to (a) the level sensor12 mounted 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 emergencyresponders.b) A description of the specific method or combination ofmethods that will be used to confirm the reliability of thepermanently installed equipment during and followingseismic conditions to maintain its required accuracy.For RAI #12 above, please provide the results for the The response to this RAI wasselected methods, tests and analyses used to provided in Attachment 2 to the13 demonstrate the qualification and reliability of the February 28, 2014 Six-Monthinstalled equipment in accordance with the Order Status Report letter (Referencerequirements. 3).Please provide the following: The response to this RAI wasprovided in Attachment 2 to thea) A description of the electrical AC power sources and February 28, 2014 Six-Monthcapabilities for the primary and backup channels. Status Report letter (Reference3).14 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. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 7 of 9Interim Staff Evaluation Open Items (RAls)RAI # Description StatusPlease provide the results of the calculation depicting The response to this RAI wasthe battery backup duty cycle requirements provided in Attachment 2 to the15 demonstrating that its capacity is sufficient to maintain February 28, 2014 Six-Monththe level indication function until offsite resource Status Report letter (Referenceavailability is reasonably assured. 3).Provide the following: The response to this RAI wasprovided in Attachment 2 to thea) A description of the methodology that will be used for February 28, 2014 Six-Monthdetermining the maximum allowed deviation from the Status Report letter (Referenceinstrument channel design accuracy that will be 3).employed under normal operating conditions as anacceptance criterion for a calibration procedure to flag tooperators and to technicians that the channel requires16 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 a list of the procedures addressing The response to this RAI wasoperation (both normal and abnormal response), provided in Attachment 2 to thecalibration, test, maintenance, and inspection February 28, 2014 Six-Month17 procedures that will be developed for use of the SFP Status Report letter (Referenceinstrumentation. The licensee is requested to include 3).a brief description of the specific technical objectives tobe achieved within each procedure.
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 8 of 9Interim Staff Evaluation Open Items (RAIs)RAI # Description StatusPlease provide the following: The response to this RAI wasprovided in Attachment 2 to thea) Further information describing the maintenance February 28, 2014 Six-Monthand testing program the licensee will establish and Status Report letter (Reference3).implement to ensure that regular testing andcalibration is performed and verified by inspection andaudit to demonstrate conformance with design andsystem readiness requirements. Please include adescription of the plans for ensuring that necessarychannel checks, functional tests, periodic calibration,18 and maintenance will be conducted for the levelmeasurement system and its supporting equipment.b) Information describing compensatory actions whenboth channels are out-of-order, and theimplementation 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 days7 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).8 ReferencesThe following references support the update to the North Anna Power Station SFPLevel Instrumentation Overall Integrated 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. 12-166B,dated February 28, 2013.
Serial No. 14-391Docket Nos. 50-338/339Order EA-12-051AttachmentPage 9 of 92. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to ReliableSpent 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. 12-166E).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. "North Anna Power Station, Units 1 and 2: Interim Staff Evaluation and Request forAdditional Information Regarding the Overall Integrated Plan for Implementation ofOrder EA-12-051, Reliable Spent Fuel Pool Instrumentation," dated November 1,2013.