ML14063A201

Virgil C. Summer, Unit 1, Second 6-Month Status Report of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation

ML14063A201
Person / Time
Site:	Summer
Issue date:	02/27/2014
From:	Gatlin T D SCANA Corp, South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RC-14-0031
Download: ML14063A201 (10)

Text

Thomas D. GatlinVice President, Nuclear Operations (803) 345-4342A/ CANA C'OMPANY February 27, 2014A scANA COMPANY RC-14-0031 U. S. Nuclear Regulatory Commission Document Control DeskWashington, DC 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1DOCKET NO. 50-395OPERATING LICENSE NO. NPF-12SOUTH CAROLINA ELECTRIC

& GAS COMPANY (SCE&G) SECOND6-MONTH STATUS REPORT OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR RELIABLE SPENTFUEL POOL INSTRUMENTATION

References:

1. NRC Order Number EA-1 2-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation,"

dated March 12, 2012[ML12054A682]

2. SCE&G's Overall Integrated Plan in Response to March 12, 2012Commission Order Modifying Licenses with Regard to Reliable Spent FuelPool Instrumentation (Order Number EA-12-051),"

dated February 28, 2013RC-13-0031

[ML13063A099]

On March 12, 2012, the Nuclear Regulatory Commission issued an order (Reference

1) toSouth Carolina Electric

& Gas Company (SCE&G).

Reference 1 was immediately effective anddirects SCE&G to have a reliable indication of the water level in associated spent fuel storagepools.Reference 1 requires submission of a 6-month status report following the submittal of theOverall Integrated Plan (Reference 2). The purpose of this letter is to provide the second6-month status report pursuant to Section IV, Condition C.2, of Reference

1. SCE&Gdeveloped an Overall Integrated Plan (Reference 2), documenting the-requirements to installreliable spent fuel pool level instrumentation, in response to Reference

1. Attachment I providesthe second 6-month status report of milestone accomplishments since the submittal of theOverall Integrated Plan. This update includes any changes to the compliance method, schedule, or need for relief/relaxation and the basis.This letter contains no new regulatory commitments.

If you have any questions regarding thisreport, please contact Mr. Bruce L. Thompson at (803) 931-5042.

Virgil C. Summer Station -Post Office Box 88 .Jenkinsville, SC. 29065

• F (803) 941-9776 ei, Document Control DeskCR-12-01070 RC-14-0031 Page 2 of 2I certify under penalty of perjury that the foregoing is true and correct.Executed on Thomas D. GatlinBD/TDG/ts

Attachment:

I. South Carolina Electric

& Gas (SCE&G)'s Second Six Month Status Report of OrderEA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable SpentFuel Pool Instrumentation c: K. B. MarshS. A. ByrneJ. B. ArchieN. S. CarnsJ. H. HamiltonJ. W. WilliamsW. M. CherryE. J. LeedsV. M. McCree (w/attachment)

S. A. Williams (w/attachment)

NRC Resident Inspector K. M. SuttonNSRCRTS (CR-12-01070)

File (815.07)PRSF (RC-14-0031)

Document Control DeskCR-12-01070 RC-14-0031 Attachment IPage 1 of 8VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT IATTACHMENT ISOUTH CAROLINA ELECTRIC

& GAS COMPANY (SCE&G) SECOND 6-MONTH STATUSREPORT OF ORDER EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TOREQUIREMENTS FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION

1. Introduction SCE&G developed an Overall Integrated Plan (Reference

2) and first six-month status report(Reference 4), documenting the requirements to install reliable spent fuel pool levelinstrumentation (SFPLI),

in response to Reference

1. This attachment provides an update ofmilestone accomplishments since submittal of the Overall Integrated Plan, including anychanges to the compliance method, schedule, or need for relief/relaxation and the basis, if any.2. Milestone Accomplishments The following milestone(s) in section 3 have been completed since the development of theOverall Integrated Plan (Reference 2), and are current as of February 28, 2014.Submitted the Virgil C. Summer Nuclear Station, Unit 1 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

(TAC NO. MF1173) Dated August 28, 2013 (RC-13-0119).

3. Milestone Schedule StatusThe following provides an update to milestone schedule to support the Overall Integrated Plan.This section provides the activity status of each item, and the expected completion date. Thedates are planning dates subject to change as design and implementation details aredeveloped.

The revised milestone target completion dates do not impact the order implementation date.Target RevisedMilestone Completion Activity TargetDate Status Completion DateSubmit 60 Day Status Report Oct 2012 CompleteSubmit Overall Integrated Plan Feb 2013 CompleteSubmit Response to RAIs on Overall Aug 2013 CompleteIntegrated PlanSubmit Response to RAls on Overall Oct 2014 In Progress Document Control DeskCR-1 2-01097RC-14-0031 Attachment IPage 2 of 8Target ARevisedMilestone Completion Activity TargetDate Status Completion DateIntegrated PlanSubmit 6 Month Updates:Update 1 Aug 2013 CompleteUpdate 2 Feb 2014 CompleteUpdate 3 Aug 2014 Not StartedUpdate 4 Feb 2015 Not StartedUpdate 5 Aug 2015 Not StartedUpdate 6 Feb 2016 Not StartedModifications:

Modification Development Jan 2014 In ProgressComplete Procurement of Jun 2013 In Progress March 2014Instrumentation PackageComplete Engineering and Design Jul 2014 In Progress January 2015Commence Implementation Oct 2014 Not Started March 2015Unit 1 Implementation Outage Oct 2015 Not StartedProcedures:

Complete Procedures Development Feb 2015 Not StartedTraining:

Develop Training Plan Feb 2015 Not StartedTraining Complete Aug 2015 Not Started4. Changes to Compliance MethodThere is one change to the compliance method as documented in the Overall Integrated Plan(OIP) (Reference 2). The backup channel of the spent fuel pool level monitoring system will be Document Control DeskCR-12-01070 RC-14-0031 Attachment IPage 3 of 8a permanently installed channel instead of the portable channel described in the OIP. Thedetails of this change were provided in the station response to the Request for Additional Information (References 3 and 5)5. Need for Relief/Relaxation and Basis for the Relief/Relaxation SCE&G expects to comply with the order implementation date and no relief/relaxation isrequired at this time.6. Open Items from Overall Integrated Plan and Draft Safety Evaluation Public meetings were held on November 26, 2013 and February 6, 2014 to discuss reliablespent fuel pool level instrumentation RAIs based on binning (References 7, 8, and 9). The twobins are: generic RAIs to be answered by the vendor and plant specific.

VCSNS will provide aresponse to all RAIs by October 31, 2014. Below is an update on plant specific RAIs listed inreference 6.RAI #1Please provide additional information describing how the design of shielding for the SFPlevel instrumentation meets the requirement of the Order to arrange the instruments in amanner that provides reasonable protection of the level indication function againstmissiles that may result from damage to the structure over the SFP. Also, describe plansfor protecting any equipment mounted outside the buildings from the effects of tornadodriven missiles,

freezing, elevated temperature,

humidity, flooding, and other BDBconditions.

SCE&G UpdateThis RAI is part of the detailed seismic design, and has not been started.RAI #2Please provide the following:

a) The design criteria to be used to estimate the total loading on the mountingdevice(s),

including static weight loads and dynamic loads. Describe themethodology to be used to estimate the total loading, inclusive of design basismaximum seismic loads and the hydrodynamic loads that could result from poolsloshing or other effects that could accompany such seismic forces.b) A description of the manner in which the level sensor (and stilling well, ifappropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the sensing waveguide assembly.

Indicatein a schematic the portions of the level sensor waveguide that will serve as pointsof attachment for mechanical/mounting or electrical connections.

Document Control DeskCR-12-01070 RC-14-0031 Attachment IPage 4 of 8c) A description of the manner by which the mechanical connections will attach thelevel instrument to permanent SFP wall or floor structures so as to support thewaveguide level sensor assembly.

SCE&G UpdateThis RAI is part of the detailed seismic design, and has not been started.RAI#4For each of the mounting attachments required to fasten SFP level equipment to plantstructures, please describe the design inputs, and the methodology that will be used toqualify the structural integrity of the affected structures/equipment.

SCE&G UpdateThe SFP level indication equipment is being purchased Quality related per VCSNS Specification SP-1000.

VCSNS Specification SP-1 000 requires the SFPL indication equipment to operate ata temperature of 212 degrees Fahrenheit, operate in a boiling water or steam environment at100% humidity, operate at an elevation of at least 150 meters above sea level, and inradiological conditions for a normal refueling quantity of freshly discarded (100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuel withthe SFP water level 3, as described in NEI 12-02. The instrument channel reliability underseismic conditions will be established using the methodology in NEI 12-02 Revision 1 Section 3and will meet the intent of interim staff guidance for reliable spent fuel pool instrumentation inNRC JLD-ISG-2012-03, Revision

0. The instrument channel design basis seismic conditions will correspond to the VCSNS Safe Shutdown Earthquake in structure response spectra fromSP-702 at the locations of the components of the instrument channel.

The adequacy of theseismic design and installation will comply with the applicable guidance in IEEE Standard 344-2004 Sections 7, 8, 9, and 10. The instrumentation will also meet the shock qualifications ofNEI 12-02 and MIL-S-901D.

RAI #5Please provide analysis of the maximum expected radiological conditions (dose rate andtotal integrated dose) to which the equipment located within the FH building exterior walland the auxiliary building stairwell will be exposed.

Also, provide documentation indicating how it was determined the electronics for this equipment is capable of3withstanding a total integrated dose of lX1O Rads. Discuss the time period over whichthe analyzed total integrated dose was applied.SCE&G UpdateThe first part of this RAI will be provided in generic vendor meetings.

The second part of this RAI response is in progress, no new update.

Document Control DeskCR-1 2-01070RC-1 4-0031Attachment IPage 5 of 8RAI #7Please provide information indicating the maximum expected relative humidity in therooms in which the system electronics will be located under BDB conditions, with no ACpower available to run HVAC systems, and whether the sensor electronics are capable ofcontinuously performing required functions under this expected humidity condition.

SCE&G UpdateRAI response is in progress.

The maximum humidity postulated for the spent fuel pool areais 100 percent relative

humidity, saturated steam. The radar sensor electronics will be locatedoutside of the spent fuel pool room in an area away from the steam atmosphere.

Thewaveguide pipe can tolerate condensation formation on the inner wall surface, providedcondensate pooling does not occur within the waveguide pipe. Condensate pooling isprevented by installing a weep hole(s) at the low point(s) in the wave guide pipe. VCSNS isstill determining BDB conditions for the Fuel Handling Building exterior wall and the auxiliary building stairwell.

Additional test information for the equipment will be provided once thepurchase order is in place. This documentation is to be provided by the vendor per VCSNSSpecification SP-1000.RAI #11Please provide an evaluation of the seismic testing results to show that the instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Virgil C. SummerNuclear Station has been adequately demonstrated.

Include information describing thedesign inputs and methodology used in any analyses of the mounting of electronic equipment onto plant structures, as requested in RAI #4 above.SCE&G UpdateThe first part of this RAI will be provided in generic vendor meetings.

VCSNS Specification SP-1 000 requires the design inputs for equipment related to instrument channel reliability under seismic conditions be established using the methodology in NEI 12-02Revision 1 Section 3. These design inputs will meet the intent of interim staff guidance forreliable spent fuel pool instrumentation in NRC JLD-ISG-2012-03, Revision

0. The instrument channel design basis seismic conditions will correspond to the VCSNS Safe ShutdownEarthquake in structure response spectra from SP-702 at the locations of the components of theinstrument channel.RAI #12Please provide the final configuration of the power supply source for each channel sothe staff may conclude the two channels are independent from a power supplyassignment perspective.

Document Control DeskCR- 2-01070RC-14-0031 Attachment IPage 6 of 8SCE&G UpdateRAI response is in progress.

VCSNS is waiting on the vendor to provide the final configuration of the primary and backup power sources for each channel.

These channels will beindependently fed with their own DC power sources.RAI# 15Please provide a description of the in-situ calibration process at the SFP location thatwill result in the channel calibration being maintained at its design accuracy.

SCE&G UpdateRAI response is in progress, no new update.RAI #16Please describe the evaluation used to validate the display locations can be accessedwithout unreasonable delay following a BDB event. Include the time available forpersonnel to access the display as credited in the evaluation, as well as the actual time(e.g., based on walk-throughs) that it will take for personnel to access the display.Additionally, include a description of the radiological and environmental conditions onthe paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BDBevent. Describe whether personnel are continuously stationed at the display or monitorthe display periodically.

SCE&G UpdateRAI response is in progress, no new update.RAI #17Please provide a list of the procedures addressing operation (both normal and abnormalresponse),

calibration, test, maintenance, and inspection that will be developed for use ofthe SFP instrumentation.

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

SCE&G UpdateAppropriate quality assurance measures will be selected for the SFP instrumentation asrequired by Order EA-1 2-051, consistent with Appendix A-1 of NEI 12-02 and similar to thoseimposed by Regulatory Guide 1.155. Site procedures will be developed for system inspection, calibration and test, maintenance, repair, operation, and normal and abnormal responses, inaccordance with VCSNS procedure controls.

The development of these procedures has notstarted.

Document Control DeskCR-12-01070 RC-14-0031 Attachment IPage 7 of 8Procedure

1) System Inspection

2) Calibration and Test3) Maintenance

4) Repair5) Operation

6) ResponseObiectives to be achievedTo verify that system components are in place, complete, and inthe correct configuration, and that the sensor probe is free ofsignificant deposits of crystallized boric acid.To verify that the system is within the specified

accuracy, isfunctioning as designed, and is appropriately indicating SEP waterlevel.To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.

To specify troubleshooting steps and component repair andreplacement activities in the event of system malfunction.

To provide sufficient instructions for operation and use of thesystem by plant operation staff.To define the actions to be taken upon observation of system levelindications, including actions to be taken at the levels defined inNEI 12-02.RAI #18Please provide the following:

a) Further information describing the maintenance and testing program the licenseewill establish and implement to ensure that regular testing and calibration isperformed and verified by inspection and audit to demonstrate conformance withdesign and system readiness requirements.

Please include a description of theplans for ensuring that necessary channel checks, functional tests, periodiccalibration, and maintenance will be conducted for the level measurement systemand its supporting equipment.

b) Information describing compensatory actions when both channels are out-oforder, and the implementation procedures.

c) Additional information describing expedited and compensatory actions in themaintenance procedure to address when one of the instrument channels cannot berestored to functional status within 90 days.SCE&G UpdateRAI response is in progress, no new update.

Document Control DeskCR-12-01070 RC-14-0031 Attachment IPage 8 of 87. Potential Draft Safety Evaluation ImpactsThere are no potential impacts to the Draft Safety Evaluation identified at this time.8. References The following references support the updates to the Overall Integrated Plan described in thisattachment.

1. NRC Order Number EA-12-051,

" Order Modifying Licenses with Regard to Reliable SpentFuel Pool Instrumentation,

" dated March 12, 20122. SCE&G's Overall Integrated Plan in Response to March 12, 2012 Commission OrderModifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051),"

dated February 28, 2013 (RC-13-0031)

3. Robert E. Martin to Thomas D. Gatlin Letter: Virgil C. Summer Nuclear Station, Unit 1-Request for Additional Information Regarding Overall Integrated Plan for Reliable SpentFuel Pool Instrumentation (Order Number EA-12-051)

(TAC NO. MF1 173) dated July 29,20134. SCE&G's 6-Month Status Report of Order EA-12-051, Order Modifying Licenses withRegard to Requirements for Reliable Spent Fuel Pool Instrumentation, dated August 28,2013 (RC-13-0117)

5. Virgil C. Summer Nuclear Station, Unit 1 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (OrderNumber EA-12-051)

(TAC NO. MF1 173) dated August 28, 2013 (RC-13-0119)

6. Shawn Williams to Thomas D. Gatlin Letter: Virgil C. Summer Nuclear Station, Unit 1-Interim Staff Evaluation and Request for Additional Information Regarding the OverallIntegrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel PoolInstrumentation (TAC NO. MF1173) dated December 5, 20137. NRC (Nuclear Regulatory Commission 2013) Public Meeting on Reliable Spent Fuel PoolInstrumentation-Staff Evaluations of Licensee Plans for Addressing Order EA- 12-051,November 26, 2013 Rockville, MD: NRC8. NEI (Nuclear Energy Institute 2013) Spent Fuel Pool Instrumentation Order (EA-12-051)

RAls Binning Nov. 26, 2013 Washington, DC: NEI9. NRC (Nuclear Regulatory Commission 2013) Public Meeting on Reliable Spent Fuel PoolInstrumentation-Staff Evaluations of Licensee Plans for Addressing Order EA-12-051, February 6, 2014 Rockville, MD: NRC10. SCE&G's Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Specification for Fukushima (FLEX) SFP Level Instrumentation System SP-1 000, Revision 1 dated February 4, 2014