LR-N13-0156, Response to RAI for Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Response to RAI for Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML13225A363
Person / Time
Site: Salem  PSEG icon.png
Issue date: 08/12/2013
From: Neely C
Public Service Enterprise Group
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, LR-N13-0156
Download: ML13225A363 (20)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG NuclearLLC AUG 122013 Order EA-12-051 LR-N13-0156 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

PSEG Nuclear LLC's Response to Request for Additional Information for the Salem Generating Station's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. PSEG Letter LR-N13-0020, "PSEG Nuclear LLC's Overall Integrated Plan (OIP) for the Salem Generating Station in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 )," dated February 28, 2013
2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation," dated March 12, 2012
3. NRC Letter to PSEG, "Salem Nuclear Generating Station, Unit Nos. 1 and 2 -

Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) TAC Nos. MF0913 and MF0914," dated July 11, 2013 By letter dated February 28, 2013 (Reference 1), PSEG Nuclear LLC (PSEG) provided the Salem Generating Station (SGS) Units 1 and 2, Overall Integrated Plan (OIP) in response to the Nuclear Regulatory Commission (NRC) Order modifying licenses with regard to reliable Spent Fuel Pool (SFP) instrumentation (Reference 2).

This letter is provided in response to the NRC's Request for Additional Information (RAI)

(Reference 3) regarding the Reference 1 OIP. Attachment 1 contains the SGS Units 1 and 2 response to the RAI. Consistent with Reference 3, the attached

LR-N13-0156 Order EA-12-051 Page 2 response includes schedules for providing final information that is not currently available.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please do not hesitate to contact Mrs. Emily Bauer at 856-339-1023 ..

I declare under penalty of perjury that the foregoing is true and correct.

Executed on AV~\Jst \/)., ~ O\~

(Date)

Sincerely, Christine T. Neely Director - Regulatory Affairs : Response to Request for Additional Information - Overall Integrated Plan in Response to Order EA-12-051 "Reliable Spent Fuel Pool Instrumentation" cc: Mr. E. Leeds, Director of Office of Nuclear Reactor Regulation Mr. W. Dean, Administrator, Region I, NRC Mr. J. Hughey, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Manager IV, NJBNE Salem Commitment Tracking Coordinator PSEG Corporate Commitment Coordinator

AUll 1 ~ 2013 ATTACHMENT 1 LR-N13-0156 Response to Request for Additional Information Overall Integrated Plan in Response to Order EA*12*051 "Reliable Spent Fuel Pool Instrumentation" Salem Nuclear Generating Station Units 1 & 2 PSEG Nuclear LLC

ATTACHMENT 1 LR-N13-0156 Page 1 of 16 Salem Generating Station, Units 1 and 2 Response to Request for Additional Information Reliable Spent Fuel Pool Instrumentation NRC RAI No.1, Levels of Required Monitoring The [Overall Integrated Plan] OIP states, in part, Level 1 - This is the water level required to support operation of the normal fuel pool cooling system. Indicated SFP level on either the Primary or Back-up instrument channel of greater than an elevation of approximately 124' - 8". The cooling water return lines include anti- Siphoning design features to prevent inadvertent drainage below a water elevation of 124' - 8."

Level 2 - This is the water level required to provide substantial radiation shielding for personnel standing on the SFP operating deck. Indicated SFP level on either the Primary or Back-up instrument channels of greater than elevation of approximately 114' - 11 %" (+/- l' - 0"). This elevation is approximately 10' above the top of the fuel racks and ensures a minimum of 10' above the top of the fuel.

This water level ensures there is a sufficient depth for a minimum shielding depth over the top of the stored fuel of 10' of water to provide substantial radiation shielding for personnel to respond to Beyond-Oesign-Basis (BOB) external events and initiate any SFP makeup strategies.

Level 3 - This is the water level required such that the spent fuel remains covered. Indicated SFP level on either the Primary or Back-up instrument channels of greater than elevation of approximately 104' - 11 %" (+/- l' - 0").

This water level ensures that there is adequate water level above the stored fuel seated in the fuel racks.

Please provide the following:

a) For Level 1, specify how the identified location represents the HIGHER of the two points described in the NE112-02 guidance for this level.

b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3, as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.

ATTACHMENT 1 LR-N13-0156 Page 2 of 16 PSEG Response a) Level 1 has been established using the guidance provided in NEI 12-02 Revision 1 (Reference 1) as the water level required to support operation of the normal fuel pool cooling system. Level 1 represents the higher of the following two points:

  • The level at which reliable suction loss occurs due to uncovering of the coolant inlet pipe, weir, or vacuum breaker (depending on design), or
  • The level at which the water height, assuming saturated conditions, above the centerline of the cooling pump suction provides the required net positive suction head (NPSH R) specified by the pump manufacturer or engineering analysis.

For Salem Generating Station (SGS) Units 1 and 2, the level at which reliable suction loss occurs is due to uncovering of the coolant suction pipe. The centerline of the suction pipe is at elevation 124' - 8" of the SFP. This is the level at which reliable suction loss occurs.

The NPSH R specified by the pump manufacturer assuming saturated conditions is 16 ft. At the SFP suction elevation of 124' - 8" and saturated conditions, the lowest available NPSH (NPSH A) is greater than the NPSH R of 16 ft as specified by the pump manufacturer (Reference 8 for NPSH calculation details).

For Level 1, the centerline of the suction pipe (124' - 8") is greater than the level where the NPSH A equals NPSH R and therefore represents the higher of the two points described in the NEI 12-02 guidance for this level.

b) The sketch below provides an elevation view of the SFP for SGS Units 1 and 2, showing the Level 1, 2, and 3 values, elevations of the fuel racks, and other elevations related to the SFP and cooling system. It is anticipated that the final mounting arrangement (e.g., fixed level sensors and mounting brackets) will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

ATTACHMENT 1 LR-N13-0156 Page 3 of 16 Salem Units 1& 2 Spent Fuel Pool Level Sketch Elevation View Fuel Handling Building To Electronics To Electronics Enclosure Enclosure

. Jil t

EI133' - 0" Operating Floor level I::;, <1= EI129' - 2" (Hi Level Alarm)

~:::: P= EI 128' - 8" (Normal Level) t:;: [<:= EI128' - 2" (Low Level Alarm

~

I

[,;:' EI 124' - 8" (Level 1)

I~:

I~:

t Sensor (Note 1)

Spent Fuel Pool 9' - 8 %"

I~

[~~

~ r:== EI 114' - 11 Yo" (Level 2)

~:

10' - 0"  ::~:

I  :;:

j Top of Fuel Rack
~ ~ ~ EI 104' - 11 %" (Level 3)

EI 89' - 0" (Bottom of Pool)

(NOT TO SCALE)

(Note 1) - The sensor total span (Le., measurement range that is sensitive to measurement of the fuel pool level) is approximately 25' - 0." The sensor is capable of continuously monitoring level over the entire range from the existing Hi Level Alarm down to the proposed Level 3. The actual length of the sensor will be determined during detailed design.

ATTACHMENT 1 LR-N13-0156 Page 4 of 16 NRC RAI No.2, Arrangement The OIP states, in part, The primary and backup channel level sensor probes will be installed in different locations of the SFP for a maximum separation within the limits of the existing SFP design. The primary and backup channels will be physically separated in accordance with the guidelines provided in NEI 12-02 Revision 1. In the conceptual design [Reference 7], the SFP probes bolt to mounting plates for installation at the corner of the SFP, or along the side of the SFP. This mounting will allow the probe to be installed within a few inches of the SFP liner without penetrating the liner thereby minimizing the chances of interference with other structures, and occupying limited space of the SFP deck. Existing barriers will be used to provide a level of protection for the sensor and interconnecting cable located along the SFP wall or on the refueling floor. These physical barriers will protect the instrument sensors and cables from potential missile hazards generated by an event. The final sensor mounting design and cable routing will maintain a low profile to ensure that there is no interference with the existing fuel handling equipment. Specific details will be developed during the detailed design phase.

Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/ placement of the primary and back-up SFP level sensor and mounting brackets, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.

PSEG Response The attached Figure RAI-2, "Salem Unit 2 Spent Fuel Pool Level Sketch Plan View," depicts the approximate locations for both the primary and back-up level sensors (SGS Unit 1 is similar to Unit 2). As stated in the OIP for SGS Units 1 and 2, both the primary and backup channels will be physically separated in accordance with the guidelines provided in NEI 12-02 Revision 1.

Specifically, the sensors will be in different corners of the SFP and separated by a distance comparable to the shortest side of the pool. The interconnecting cables that extend from the sensors toward the location of the electronics enclosures will be installed using separate routes and separate conduit to transition from the SFP curb. Existing conduit embedded in the fuel handling floor concrete will be utilized to the extent practical, providing a physical barrier to protect from potential missile hazards until the cable leaves the Fuel Handling Building and transitions into the Auxiliary Building. In the Auxiliary Building, the cables will be routed using SGS Units 1 and 2 "Technical Standard for Physical Separation Requirements (Electrical)"

(Reference 10) over the entire length of the cable.

ATTACHMENT 1 LR-N13-0156 Page 5 of 16 NRC RAI No.3, Mounting The OIP states, in part, Installed equipment will be qualified to withstand the maximum seismic ground motion considered in the design of the plant area where the equipment will be installed. The basis for the seismically designed mountings will be the plant seismic design basis at the time of the submittal of this integrated plan. The instrument sensors mounted in the SFP will be designed to Seismic Category I.

Please provide the following:

a) The design criteria that will be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design-basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic, the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

PSEG Response a) The design criteria used to estimate total loading, including static and dynamic loads is in accordance with PSEG Technical Standard "Salem Structural Design Criteria" (Reference 12). The SGS Units 1 and 2 Structural Design Criteria provide both the design criteria and the methodology used for determining total loading. Final static and dynamic (seismic and hydrodynamic) loads will be provided by the manufacturer based on their final design and the testing and/or analysis results. The final static, dynamic and hydrodynamic loads will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

b) The SGS Units 1 and 2 SFP Level Instrumentation Guided Wave Radar (GWR) sensor design does not include a stilling well. The low sensor mass and the sensor's reaction to seismic loading permit the sensor assembly mount to be very simple, lightweight, and require a very small footprint. The sensor can be mounted on the curb's horizontal surface or curb face. The sensor is designed to mount in close proximity to the liner without penetrating it. Therefore, there are no points of attachment to the SFP liner.

The final mounting details will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

ATTACHMENT 1 LR-N13-0156 Page 6 of 16 c) The mounting details have not been finalized. The final mounting details will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

NRC RAt No.4, Qualification The OIP states, in part, Components of the instrument channels installed in the SFP area will be qualified for shock and vibration using one or more of the following methods: ...

For seismic effects on instrument channel components used after a potential seismic event for only installed components, the following measures will be used to verify that the design and installation is adequate. Applicable components of the instrument channels are rated by the manufacturer (or otherwise tested) for seismic effects at levels commensurate with those of postulated design basis event conditions in the area of instrument channel component use using one or more of the following methods: ...

Please provide the following:

a) A description of the specific method or combination of methods you intend to apply to demonstrate the reliability of the permanently installed equipment under Beyond-Oesign-Basis (BOB) ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (i) the level sensor mounted in the SFP area, and (ii) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

c) Please provide a description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment following seismic conditions to maintain its required accuracy.

PSEG Response a) . Reliability of the permanently installed equipment under BOB ambient temperature, humidity, shock, vibration, and radiation conditions will be demonstrated by the manufacturer through their equipment design, testing, or analysis as specified in the PSEG procurement specification. Section 7 of the procurement specification(Reference

9) provides performance requirements for temperature, humidity, pressure, radiation, chemistry, shock and vibration, EMI/RFI, and seismic based on the environmental and seismic design criteria from NEI 12-02 Revision 1.

All equipment located in the fuel handling building will be certified for use by the manufacturer for survivability under post-event conditions including temperatures of at least 100° Centigrade (212° Fahrenheit), 100 percent condensing atmosphere, submerged operation for components located in the SFP at elevated chemical

ATTACHMENT 1 LR-N13-0156 Page7of16 concentrations, and exposure to postulated radiation levels with the SFP water levels at the top of the fuel storage rack for an extended period of time. The new electronics enclosures will be installed in the Auxiliary Building Relay Room, which is considered a mild environment.

b) The new SFP electronic enclosures will be qualified by test in accordance with the seismic qualification requirements outlined in IEEE-344 2004 (Reference 6) using a bounding set of criteria that will envelope the SGS Units 1 and 2 Auxiliary Building Required Response Spectra (RRS). The electronicenclosure mounts will be seismically qualified to reflect the specific plant configuration determined by the final design.

Dynamic analysis, including the applicable seismic and hydrodynamic loads, will be used to determine the total loads on the sensor and its mounting. Site specific analysis will be performed to demonstrate the mount's structural adequacy at the selected location.

In addition to the above, the electronic enclosures will be qualified by the manufacturer for use at temperatures, humidity and integrated radiation doses consistent with other electronic devices containing digital components and located in mild environments. The inherent shielding of the structures between the fuel handling building and the transmitter will result in negligible doses to the transmitter located in the Auxiliary Building.

c) The new SFP level instrumentation system will be tested and/or analyzed using a bounding set of seismic response spectra that will meet the Seismic Design and Qualification requirements for SGS Units 1 and 2. Testing and analysis will confirm that the system maintains its required accuracy following a seismic event.

Further details of the qualification by test and/or analysis used to confirm the reliability of the permanently installed equipment during and following seismic event will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

NRC RAI No.5, Independence The OIP states, in part, Independence will be achieved through physical separation of the final installed devices. The two (2) permanently installed instrument sensors will be separated by a distance comparable to the shortest length of a side of the SFP, to the extent practical, based on the existing SFP geometry and construction. The interconnecting cabling associated with each channel will follow separate and independent routes back to the indicating transmitter (electronics) enclosure. The normal AC power source for each channel will be provided from independent and separate sources.

Please provide the following:

a) A description of how the two channels of the proposed level measurement system meet this requirement so that the potential for a common cause event to adversely affect both channels is minimized to the extent practical.

ATTACHMENT 1 LR-N13-0156 Page 8 of 16 b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

PSEG Response a) For SGS Units 1 and 2, the primary and back-up level sensors are located in different corners of the SFP, the electronics enclosures are located in the relay room within the Auxiliary Building, and SGS Units 1 and 2 "Technical Standard for Physical Separation Requirements (Electrical)" (Reference 10) for instrument cabling will be applied to the design (refer to the sketchattached in response tORAI-2). Additionally, for SGS Units 1 and 2, the Fuel Handling Building and Auxiliary Building areSeismic Class 1 structures designed to withstand seismic, flooding and wind events and therefore provide reasonable protection in accordance with assumptions used for the Diverse and Flexible Coping Strategies (FLEX) required by Order EA-12-049 (Reference 4) and outlined in NEI 12-06 (Reference 5).

b) The SGS Units 1 and 2 SFP level instrumentation system is designed to be a complete integrated solution that meets the requirements set forth in EA-12-051 (Reference 2), NEI 12-02 Revision 1 (Reference 1), and JLD-ISG-2012-03 (Reference 3). The system provides two completely independent channels of level instrumentation. Each channel is comprised of the GWR sensor assembly, the sensor mount, and an electronics enclosure (transmitter, signal conditioning, communications circuitry, display panel, and internal battery). Each channel's electronics is equipped with appropriate connections to provide a signal to the remote displays. The normal power supply for each channel will be provided via separate 120VAC, battery-backed, inverter vital power supplies, such that loss of one power source will not result in the loss of both channels. In addition to the normal AC power supply, each channel contains a back-up power source in the form of a back-up battery and will automatically transfer from the normal AC power source to the battery back-up source upon a loss of the AC supply.

NRC RAI No.6, Power Supplies The OIP states, in part, The normal power supply for each channel will be provided by independent AC or DC power sources such that loss of one power source will not result in the loss of both channels. In addition to the normal plant AC or DC power supply to each channel, a back-up power source will also be provided in the form of a back-up battery independent of the normal AC or DC power sources. The back-up power will have sufficient capacity to support reliable instrument channel operation through the use of replaceable batteries until appropriate off-site resource availability is reasonably assured.

Please provide the following:

ATTACHMENT 1 LR-N13-0156 Page 9 of 16 a) Please provide a description of the electrical AC power sources and capacities for the primary and backup channels.

b) If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BOB event for the minimum duration needed, consistent with the plant Diverse and Flexible Coping Strategies (FLEX) Program plans.

PSEG Response a) The normal power supply for each channel will be provided using separate station 120VAC power sources that are fed from battery-backed inverters (vital supplies) such that loss of one power source will not result in the loss of both channels. The station batteries providing power to the SFP instrument channels will remain operational through an initial coping period as defined by the SGS FLEX strategies.

b) As stated in the response to a), the level measurement channels use separate station 120VAC power sources that are fed from battery-backed inverters (vital supplies) as the normal supply. Back-up power is provided by means of batteries internal to the electronics enclosure. The design criteria applied to the instrument specification is for continuous system operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following loss of ac power. System power consumption is based on the specified values provided by the manufacturer which will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month alP update.

NRC RAI No.7, Accuracy The alP states, in part, The instrument channels will maintain their designed accuracy following a power interruption or change in power source without requiring recalibration. The instrumentation channels utilize [Commercial-off-the-shelf] (COTS) components and, therefore, the final design will ensure vendor published instrument design accuracies are acceptable in accordance with the guidelines of NEI 12-02 Revision 1. Accuracies will be sufficient to allow trained personnel to determine when the actual level exceeds the specified lower level of each indicating range (Levels 1, 2 and 3) without providing conflicting or ambiguous information.

Accuracy requirements will consider all SFP conditions (e.g., saturated water, steam environment, and concentrated borated water).

ATTACHMENT 1 LR-N13-0156 Page 10 of 16 Please provide the fol/owing:

a) An estimate of the expected instrument channel accuracy performance under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BOB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

PSEG Response:

a. The selected SFP level instrumentation system is expected to have a design reference accuracy better than +/- 1% of span and will maintain this accuracy over the entire range of operating conditions, including BDB conditions. It will maintain its design accuracy following a power interruption without the need for recalibration. The final design accuracy information will be provided by the manufacturer and will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month DIP update.
b. The maximum allowed deviation from the channel design accuracy forchannel check and calibration tolerances will be developed as part of the detailed design using the standard SGS Units 1 and 2 Setpoint Methodology Technical Standard (Reference 11).

The final tolerances will be developed from design accuracy information provided by the manufacturer and will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month DIP update.

NRC RAI No.8, Testing The DIP states, in part, Instrument channel design will provide for routine testing and calibration consistent with Order EA-12-051 and the guidancein NE112-02 Revision 1.

Details will be finalized upon receipt of final vendor information duringthe detailed design phase.

Please provide the fol/owing:

a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

ATTACHMENT 1 LR-N13-0156 Page 11 of 16 c) A description of how functional checks will be performed and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.

d) A description of what preventative maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

PSEG Response a) A description of the capability and provisions for the proposed level sensing equipment as well as specific periodic testing and calibration capabilities enabling the equipment to be tested in-situ will be provided by the manufacturer. This information is not yet available and will be available upon completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

b) The two independent channels of the SFP level instrumentation system will be cross-checked against each other. Since the two wide range level channels are independent, a channel check tolerance based on the design reference accuracy of each channel will be applied for cross comparison between the two channels. The overall channel tolerance will be determined using the SGS Units 1 and 2 Instrument Setpoint Technical Standard (Reference 11) and instrument reference accuracy information provided by the manufacturer.

c) Specific details of the functional and calibration test program, including frequencies, will be developed as part of the final instrument design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

d) Specific details of the preventative maintenance program, including maximum frequencies, will be developed as part of the final instrument design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

NRC RAI No.9, Display The OIP states, in part, Each instrument channel (Primary and Backup) will also have the capability to drive an external remote signal that can be used to provide level indication at a second display location or be used as an input to the plant computer. Failure of the external remote signal will not adversely impact the primary display located in the transmitter (electronics) enclosure.

The conceptual design locates the electronic enclosure and primary display in the Relay Room located within the Auxiliary Building. Specific details regarding

ATTACHMENT 1 LR-N13-0156 Page 12 of 16 the display and display location(s) will be finalized during the detailed design phase.

Please provide the following:

a) The specific location for the primary and backup instrument channel display.

b) If the primary or backup display location is other than the main control room, then provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.

c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.

PSEG Response a) The electronic units for both primary and back-up channels are located in the Auxiliary Building Relay Room which is a Seismic Category 1 structure designed to withstand flooding, wind and seismic events. The electronics enclosures provide both a local display and a retransmitted signal to a remote display located in the main control room, one elevation above the Relay Room. Refer to the sketch attached in response to RAI-2.

b) Final design details for the display units, including justification for prompt accessibility from the main control room, habitability, resource availability and communications with decision makers is scheduled to be completed as part of the BOB mitigating strategies assessments and included in applicable processes and procedures. Final details of the display location(s) will be developed as part of the final instrument design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

c) See response to b) above.

NRC RAI No.1 0, Procedures The OIP states, in part, Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation, and abnormal response issues associated with the new SFP instrumentation. These procedures will be completed following completion of the detailed design package ..

Procedures will address a strategy to ensure SFP water level addition is initiated at an appropriate time consistent with implementation of NEI12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

ATTACHMENT 1 LR-N13-0156 Page 13 of 16 Please provide the following:

a) A list of the operating (both normal and abnormal response) procedures, calibration/test procedures, maintenance procedures, and inspection procedures that will be developed for use of the SFP instrumentation in a manner that addresses the order requirements.

b) A brief description of the specific technical objectives to be achieved within each procedure. If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable components when needed.

PSEG Response a) Procedures for operation (both normal and abnormal response), calibration, testing, maintenance, inspection, and administrative controls associated with the SFP level instrumentation will be developed in accordance with existing controlled station administrative and technical procedures that govern procedure development. These procedures ensure standardization of format and terminology and ease of use along with assurance of a consistent level of quality. Specific details of the procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls will be developed as part of the final instrument design package, scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month DIP update.

b) The specific technical objectives associated with the procedures are yet to be developed. There are no portable instruments associated with the new SFP level instrumentation system that are required for normal operation. Consequently, specific procedures for storage and installation are not required. Specific technical objectives associated with the procedures will be developed as part of the final instrument design package, scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month DIP update.

NRC RAI No. 11, Testing and Calibration The DIP states, in part, Processes will be established and maintained for scheduling and implementing necessary testing and calibration of the primary and backup SFP level instrument channels to maintain the instrument channels as described in JLD-ISG-2012-03 and the guidance in NEI 12-02 Revision 1. Testing and calibration of the instrumentation will be consistent with vendor recommendations and any other documented basis.

Please provide the following:

a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system

ATTACHMENT 1 LR-N13-0156 Page 14 of 16 readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of how the guidance in NE112-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.

PSEG Response a) The maintenance and testing of the SFP level instrumentation system will be incorporated into the normal station preventative maintenance and work control processes based on manufacturer recommendations for maintenance and periodic testing. The calibration and maintenance program will include testing to validate the functionality of each instrument channel within 60 days of a planned refueling outage considering normal testing scheduling allowances as outlined in NEI 12-02 Revision 1.

The new system will receive unique identification numbers and will be entered into the PSEG preventative maintenance program. A recurring task for the required maintenance frequency will be established. Normal station administrative controls will be used to schedule regular testing and calibration to demonstrate conformance with design and system limits.

The preventative maintenance, test and calibration program will be developed consistent with manufacturer recommendations. This information will be available following completion of the final design that is scheduled for completion by the end of the first quarter 2014. Details will be provided to the NRC in the August 2014, six-month OIP update.

b) The guidance in NEI 12-02, Revision 1, states:

The primary or back-up instrument channel can be out of service for testing, maintenance and/or calibration for up to 90 days provided the other channel is functional. Additionally, compensatory actions must be taken if the instrumentation channel is not expected to be restored or is not restored within 90 days. If both channels become non-functioning then initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels of instrumentation and implement compensatory actions (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

In the event that either a primary or backup SFP level instrumentation channel must be taken out of service or is inoperable for any reason, a notification will be entered into PSEG corrective action program to restore the channel to service within 90 days. The determination of required compensatory actions is part of the overall effort to develop the FLEX program administrative controls and implementing procedures. The FLEX program will incorporate the guidance of NEI 12-02 Revision 1, including the requirements associated with out of service times and compensatory actions. The FLEX program is expected to be sufficiently developed to provide details to the NRC in the August 2014, six-month OIP update.

ATTACHMENT 1 LR-N13-0156 Page 15 of 16 c) In the event that a channel cannot b~ restored to service within the 90 day period, expedited actions to restore the channel would be initiated and tracked via PSEG's Corrective Action Program. If both channels are determined to be non-functional, PSEG will initiate appropriate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the instrument channels and implement compensatory actions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Since the sensor and interconnecting cables are passive devices, their simultaneous failure is not considered credible and therefore compensatory actions are not expected to be required for failure of both sensors. PSEG intends to purchase a portable version of the level instrument electronics to use for testing and for monitoring of a single channel whenever necessary for compensatory measures; however, the appropriate compensatory actions have yet to be defined and the determination of these actions is part of the overall effort to develop the FLEX program administrative controls and implementing procedures. The FLEX program will incorporate the guidance of NEI 12-02 Revision1, including the requirements associated with out of service time. The FLEX program is expected to be sufficiently developed to provide details to the NRC in the August 2014, six-month OIP update.

ATTACHMENT 1 LR-N13-0156 Page 16 of 16

References:

1) NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" Revision 1, August 2012 (ADAMS Accession ML12240A307)
2) US Nuclear Regulatory Commission Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," March 12, 2012 (ADAMS Accession ML12056A044)
3) NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, August 29,2012 (ADAMS Accession ML12221A339)
4) US Nuclear Regulatory Commission Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"

March 12, 2012 (ADAMS Accession ML12056A045)

5) NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, August 2012 (ADAMS Accession ML12221A205)
6) IEEE Standard 344-2004, "IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations"
7) S-C-SFP-CDI-0132 - "Reliable Wide Range Spent Fuel Pool Instrumentation" Conceptual Design, dated December 19,2012
8) S-C-SF-MDC-1040 - "NPSH for Spent Fuel Pool Pumps - SF System (Salem 1 and 2)"
9) A-5-SF-EC-CDS-0517 - "Spent Fuel Pool Level Instrumentation Detailed Specification"
10) SC.DE-TS.ZZ-2032(Q) - "Salem Technical Standard Physical Separation Requirements (Electrical)"
11) SC.DE-TS.ZZ-1 904(Q) - "Instrument Setpoint Calculations for Salem Generating Station Units 1 and 2"
12) SC.DE-TS.ZZ-4201(Q) - "Salem Structural Design Criteria"

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