ML14342B005
| ML14342B005 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/03/2014 |
| From: | Sartain M D Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 14-391A, EA-12-051 | |
| Download: ML14342B005 (10) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261December 3, 2014U. S. Nuclear Regulatory Commission Attention:
Document Control DeskWashington, DC 20555-0001 Serial No.:NLOS/ETS:
Docket Nos.:License Nos.:14-391ARO50-338/339 NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS 1 AND 2STATUS OF REQUIRED ACTIONS FOR EA-1 2-051ORDER MODIFYING LICENSES WITH REGARD TORELIABLE SPENT FUEL POOL INSTRUMENTATION On March 28, 2012 the NRC issued EA-12-051, "Order Modifying Licenses With Regard ToReliable Spent Fuel Pool Instrumentation,"
which required the installation of a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of thefollowing pool water level conditions by trained personnel:
(1) level that is adequate to supportoperation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) levelwhere fuel remains covered and actions to implement make-up water addition should no longerbe deferred.
Condition C.3 of the Order required all Licensees to report to the Commission whenfull compliance with the requirements of the order is achieved.
This letter provides notification that Dominion has completed the requirements of EA-12-051 andis in full compliance with the Order for North Anna Units 1 and 2. The attachments to this letterprovide:
- 1) a summary of how the compliance requirements were met and 2) the response toSFPI RAIs and the Safety Evaluation Review Item 9 for Order EA-12-051.
Should you have any questions orMargaret Earle at (804) 273-2768.
require additional information, please contactRespectfully, ak&dL24D47 Mark SartainVice President
-Nuclear Engineering Commitment contained in this letter: NoneIVidkIL.t4V1I NOTARY PUBLICCommonwealth of VirginiaReg. # 140542IqyC"mmisslon Expires May 31, 2018I1COMMONWEALTH OF VIRGINIACOUNTY OF HENRICO)))The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mr. Mark D. Sartain,who is Vice President
-Nuclear Engineering, of Virginia Electric and Power Company.
He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of hisknowledge and belief. ,Acknowledged before me this % day of Z)eeember
, 2014.My Commission Expires:
5- 3 (-- I00I Serial No. 14-391ADocket Nos. 50-338/339 Compliance with EA-12-051 Page 2 of 2Attachments:
- 1. Order EA-1 2-051 Compliance Requirements Summary2. Response to SPFI RAIS and Safety Evaluation Review Item 9Commitment contained in this letter: Nonecc: U.S. Nuclear Regulatory Commission
-Region IIMarquis One Tower245 Peachtree Center Avenue, NE Suite 1200Atlanta, GA 30303-1257 Dr. V. Sreenivas NRC Project Manager North AnnaU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Mrs. Lisa M. RegnerU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 011 F111555 Rockville PikeRockville, MD 20852-2738 Mr. Blake A. PurnellU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 012 D2011555 Rockville PikeRockville, MD 20852-2738 Mr. Steven R. JonesU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 010 Al11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Serial No. 14-391ADocket Nos. 50-338/339 Attachment 1Order EA-12-051 Compliance Requirements SummaryVirginia Electric and Power CompanyNorth Anna Power Station Units 1 And 2 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 1North Anna Power Station, Units I and 2Order EA-12-051 Compliance Requirements SummaryBACKGROUND North Anna Power Station (NAPS) developed an Overall Integrated Plan (OIP) (Reference 1),documenting how the requirements for reliable spent fuel pool level instrumentation (SFPLI)would be achieved, in response to Order EA-12-051, "Order Modifying Licenses with Regardto Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"(Reference 2); The North Anna Power Station Units 1 and 2 OIP was submitted to the NRCon February 28, 2013 and was supplemented by Six-Month Status Reports (References 3, 4,and 5), in accordance with Order EA-12-051 (the Order). By letter dated November 1, 2013,the NRC provided its Interim Staff Evaluation and Request for Additional Information Regarding Order EA-12-051 (Reference 6).NAPS shares a common Spent Fuel Pool (SFP) between Units 1 and 2. Two independent SFP level measurement
- channels, supplied and qualified by Westinghouse, were installed inresponse to Reference 2.On October 8, 2014 NAPS achieved full compliance with Order EA-12-051, prior to the end ofthe second refueling outage. Completion of the elements identified below for NAPS, as wellas References 1, 3, 4, and 5, document full compliance with Order EA-12-051 for NAPS Units1 and 2.The design features identified in Attachment 2 of Reference 2 are summarized in Section 6.4of ETE-CPR-2012-0012, Revision
- 5. This document has previously been provided to theNRC and is available for their review.COMPLIANCE SUMMARYNRC RAI, ISE AND AUDIT ITEMS -STATUS: COMPLETEDuring the ongoing audit process (Reference 7), Dominion provided responses for thefollowing items for NAPS:" Request for Additional Information (RAI)" Interim Staff Evaluation (ISE) Open Items* ISE Confirmatory Items" Licensee Identified Open Items" Audit Questions
" Safety Evaluation Review ItemsPage 1 of 4 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 1"The North Anna Power Station, Units 1 and 2 -Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051,"
(Reference
- 8) delineated the items reviewedduring the North Anna onsite audit. Reference 8 identified one additional audit item related toSFPI, specified as Safety Evaluation Review Item 9. This item was added following the auditand required supplemental information.
As requested by the NRC, Dominion's responses, or references to the source document forthe responses, to the SFPLI RAIs and Safety Evaluation Review Item 9 (SE 9) are providedin Attachment 2 of this letter. It is Dominion's position that no further actions related to theSFPLI RAls or SE 9 are required.
MILESTONE SCHEDULE ITEMS -STATUS: COMPLETENorth Anna Power Station Milestone Completion DateSubmit OIP February 2013Commence Engineering and Design March 2013Complete Engineering and Design May 2014Complete Procurement of SFP Instruments August 2014Commence Installation of SFP Instruments June 2014Level Measurement System Functional October 2014IDENTIFICATION OF LEVELS OF REQUIRED MONITORING
-COMPLETENorth Anna Power Station has identified the three required levels for monitoring spent fuelpool (SFP) level in compliance with Order EA-12-051.
These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFPinventory.
INSTRUMENT DESIGNED FEATURES
-STATUS: COMPLETEThe design of the SFP level measurement instrumentation system installed at NAPScomplies with the requirements specified in Order EA-12-051 and described in NEI 12-02"Industry Guidance for Compliance with NRC Order EA-12-051."
The instrumentation systemhas been installed in accordance with the station design control process.The instruments have been arranged to provide reasonable protection against missiles.
Theinstruments have been mounted to retain design configuration during and following themaximum expected ground motion. The instruments will be reliable during expectedenvironmental and radiological conditions when the SFP is at saturation for extended periods.The instruments are independent of each other and have separate and diverse powerPage 2 of 4 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 1supplies.
The instruments will maintain their designed accuracy following a powerinterruption and are designed to allow for routine testing and calibration.
The instrument display is readily accessible during postulated events and allows for SFPlevel information to be promptly available to decision makers.PROGRAM FEATURES
-STATUS: COMPLETETraining of personnel performing maintenance functions including calibration and surveillance associated with the SFP level instrument channels at NAPS has been completed inaccordance with an accepted training process as recommended in NEI 12-02, Section 4.1.Operating and maintenance procedures, for the NAPS SFP level instrument channels havebeen developed, and integrated with existing procedures.
These procedures have beenverified and are available for use in accordance with the site procedure control program.Site processes have been established to ensure the instruments are maintained at theirdesign accuracy.
Page 3 of 4 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 1REFERENCES The following references support the North Anna Power Station, Units 1 and 2 SFPLICompliance Summary:1. North Anna Power Station, Units 1 and 2 Overall Integrated Plan with regard to ReliableSpent Fuel Pool Implementation,"
February 28, 2013 (ML13063A017).
- 2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard toReliable Spent Fuel Pool Instrumentation,"
March 12, 2012.3. Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),
dated August 23, 2013 (Serial No. 12-166D).
(ML13242A015).
- 4. Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),
dated February 27, 2014 (Serial No. 12-166E). (ML14069A009).
- 5. Virginia Electric and Power Company's Six-Month Status Report in Response to March12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation (Order Number EA-12-051),
dated August 26, 2014 (Serial No.14-391).(ML14245A401).
- 6. North Anna Power Station, Units 1 and 2: NRC Interim Staff Evaluation and Request forAdditional Information Regarding to Overall Integrated Plan for Implementation of OrderEA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 1, 2013(ML13281A648).
- 7. NRC letter to All Operating Reactor Licensees and Holders of Construction Permits,"Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049,"
dated August 28, 2013 (ML13234A503).
- 8. The North Anna Power Station, Units 1 and 2 -Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Relatedto Orders EA-12-049 and EA-12-051 (ML14259A458).
Page 4 of 4 Attachment 2Order EA-12-051 Response to SFPI RAIsand Safety Evaluation Review Item 9Virginia Electric and Power CompanyNorth Anna Power Station Units I And 2 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 2Order EA-12-051 Response to SFPI RAIsand Safety Evaluation Review Item 9Spent Fuel Pool Indication (SPFI) RAIs I through 18Dominion ResponseOn November 1, 2013, Dominion received an Interim Staff Evaluation (ISE) regarding theNorth Anna SFP Level Instrumentation system OIP in a letter from Dr. V. Sreenivas to Mr.David Heacock (Reference 1). Responses to the RAIs contained in the ISE were provided tothe NRC in Attachment 2 to the second Six-Month Status Report in response to March 12,2012 Commission Order Modifying Licenses with Regard to Reliable spent Fuel PoolInstrumentation, dated February 27, 2014 (ML14069A009).
Safety Evaluation Review Item 9EMC compliance for SFP level instruments Dominion
Response
The base configuration necessary to meet Criterion B (instrument will function before andafter an Electro-Magnetic Compatibility (EMC) event) was confirmed during EMC qualification testing performed by Westinghouse.
NRC representatives audited the Westinghouse testdocuments.
As a result Westinghouse specified materials, installation, and grounding requirements necessary to ensure the installed SFP level measurement system meets thetested EMI/RFI qualifications.
These requirements and characteristic are detailed inWestinghouse proprietary letter LTR-EQ-14-32, Rev. 2 dated August 1, 2014 (Reference 2),which is available for review upon request.Attachment 5 in the NAPS Onsite Audit Report (Reference 3), requested Dominion to: "1)Provide confirmation that there are no major electrical noise sources near the probes in theSFP, and 2) provide actions taken by the licensee to address the possibility ofelectromagnetic interference."
The response to this request is as follows:1) The probe is located just above the pool surface in two locations at the North AnnaSFP. Dominion has confirmed that there are no major electrical noise sources nearthe probes in the Spent Fuel Pool.2) Placards have been installed in the Auxiliary Building and the Fuel Building.
Theplacards read, "Be aware that use of hand-held radios within 3 ft. may causeinterference with the SFP level channels.
The reading returns to normal when radiousage is stopped."
Page 1 of 2 Serial No. 14-391ADocket Nos. 50-338/339 Compliance letter for EA 12-051Attachment 2
References:
- 1. North Anna Power Station, Units 1 and 2: NRC Interim Staff Evaluation and Request forAdditional Information Regarding to Overall Integrated Plan for Implementation of OrderEA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 1, 2013(ML13281A648).
- 2. Westinghouse letter LTR-EQ-14-32, Rev. 2, "Spent Fuel Instrumentation System -Hardware Configuration for EMC testing to satisfy Performance Criteria B," dated August1,2014.3. The North Anna Power Station, Units 1 and 2 -Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Relatedto Orders EA-12-049 and EA-12-051 (ML14259A458).
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