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Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
	ML14058A665
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	02/27/2014
From:	Belcher S; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-051, L-14-024, TAC MF0799, TAC MF0800, TAC MF0802, TAC MF0960
	Download: ML14058A665 (53)
	v • d • e

{{#Wiki_filter:FENOC First Enetgt M)clor Op.'t-gCt--rl 76 South Main Street Akron. Ohio 44308 Samuel L. Belcher Senior Vice President and Chief Operating Officer February 27,2014 L-14-024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-001 10 cFR 2.202

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 FirstEneroy Nuclear Operatinq Company's (FENOC's) Second Six-Mo.nth Status Report in Response to March 12, 2012 Commission Order Modifyinq Licenses with Reoard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0799. MF0800. MF0960. and MF0802) On March 12,2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order (Reference

1) to FENOC. Reference 1 was immediately effective and directs FENOC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section lV, Condition C. Referen ce 2 endorses industry guidance document Nuclear Energy lnstitute (NEl) 12-02, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference

2. Reference 4 provided the FENOC initial status report regarding requirements for reliable spent fuel pool instrumentation.

Reference 5 provided the FENOC overall integrated plan for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), Davis-Besse Nuclear Power Station (DBNPS), and Perry Nuclear Power Plant (PNPP). Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the second

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuctear Power Station Perry Nuclear Power Plant L-14-024 Page 2 six-month status report pursuant to Section lV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The attached reports for BVPS, DBNPS, and PNPP (Attachments 1,2, and 3, respectively) provide an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.

The NRC staff also issued interim staff evaluations (References 6,7, and 8) that included requests for additional information (RAls). The FENOC response to the RAls for which information is currently available is attached for BVPS, DBNPS, and PNPP (Attachments 4,5, and 6, respectively). This letter contains no new regulatory commitments. lf you have any questions regarding this report, ptease cbntact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at 330-315-6810. I declare under penalty of perjury that the foregoing is true and correct. Executed on February 31,2014. Samuel L. Belcher Attachments:

1.

Beaver Valley Power Station Second Six-Month Status Report for the f mplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Davis-Besse Nuclear Power Station Second Six-Month Status Report for the f mpfementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Perry Nuctear Power Plant Second Six-Month Status Report for the lmplbmentation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Response

to Request for Additional Information for Beaver Valley Power Station

Response

to Request for Additional Information for Davis-Besse Nuclear Power Station

Response

to Request for Additional Information for Perry Nuclear Power Plant 2. 3. 4. 5. 6.

2. 3. 4. 5. 6. 7. 8. Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-14-024 Page 3

References:

1.

NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012 NRC f nterim Staff Guidance JLD-lSG-2O1 2-03, Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool f nstrumentation, Revision 0, dated August 29, 2012 NEf 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, dated August2012 FirstEnergy Nuclear Operating Company's (FENOC's) Initial Status Report in Responseio March 1i,2OlZ, Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated October 26,2012 FirstEnergy Nuclear Operating Company's (FENOC's) Overall Integrated Plan in ResponsJio March li,2Ot2 bommission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27, 2013 Beaver Valley power Station, Units 1 and 2 - Interim Staff Evaluation and Request for Additionai Information Regarding the Overall Integrated Plan for lmplementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated November 19, 2013 Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Informtion Regarding the Overall Integrated Plan for lmpiementation of Order EA-1 2-051, Reliable Spent Fuel Pool lnstrumentation, dated December 11,2013 Perry Nuclear Power Plant, Unit 1, - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for lmplementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated Decemb er 11, 2013

Director, Office of Nuclear Reactor Regulation (NRR)

NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS) NRC Resident Inspector (DBNPS) NRC Resident Inspector (PNPP) NRC Project Manager (BVPS) NRC Project Manager (DBNPS) NRC Project Manager (PNPP) Ms. Lisa M. Regner, NRR/JLD/PMB, NRC Mr. Blake A. Purnell, NRR/JLD/PMB, NRC Director BRP/DEP (without Attachments) Site BRP/DEP Representative (without Attachments) Utility Radiological Safety Board (without Attachments) cc:

Attachment 1 L-14-024 Beaver Valley Power Station Second Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 7 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall lntegrated Plan (OlP) for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2 (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any. 2 MilestoneAccomplishments The following milestone(s) have been completed since July 29,2013 and are current as of Janu ary 31, 201 4. o None 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. This section provides the activity status of each item and the expected completion date, noting any change. The dates are planning dates subject to change as design and implementation details are developed. The following milestones are being modified as part of this update to reflect the number assigned in the interim staff evaluation (lSE) (Reference 3) to each request for additional information (RAl) and to update the scheduled submittal time for the RAls. Submit Six-Month Status Updates Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a: February 2014 Update 3, including response to ISE RAI-4b schematic, RAI-S, RAI-7, RAI-8, RAI-10b, RAI-11, RAI-12, RAI-13, RAI-1 4, and RAI-15: August 2014 The revised milestone target completion dates do not impact the order implementation date.

Attachment 1 L-14-024 Page 2 of 7 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1). Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Gompletion Date Submit Six-Month Status Updates (Unit Nos. 1 and 2) Update 1 Auqust 2013 Complete Update 2, including response fo /SE RAI-1, RALZ, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-I0a February 2014 Started Update 3, including response fo /SE RAI-4b schematic, RAI-I, RAI-7, RAI-1, RAI-10b, RAI-11, RAI-I2, RAI-13, RAI-14, and RAI-15 Auqust 2014 Not Started Update 4 Februarv 2415 Not Started Update 5 Auqust 2015 Not Started BVPS Unit No. 1 Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 4Q13 Started 3Q14 SFP Instrumentation Delivery 2Q14 Not Started Begin SFP lnstrumentation Installation 3Q14 Not Started 4Q14 Commissioning of SFP Instrumentation 2Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Sprinq 2015 Not Started BVPS Unit No. 2 Commence SFP Instrumentaton Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 4Q13 Started 1Q15 SFP Instrumentation Delivery 3Q14 Not Started Begin SFP Instrumentation Installation 4Q14 Not Started 2Q15 Commissioning of SFP lnstrumentation 4Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Fall 201 5 Not Started L-14-024 Page 3 of 7 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time. 6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe ISE and the status of each item. Overall Integrated Plan Open ltem Status None Not Applicable Interim Staff Evaluation Open ltem Status RAI-1: Please specify for Level t how the identified location represents the higher of the two points described in the NEI 1 2-02 quidance for this level. RAI response provided in Attachment 4. RAI-2: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., 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. RAI response provided in Attachment 4. RAI-3: 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 backup SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-out/display device. RAI response provided in Attachment 4. RAI-4: 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. lndicate 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 RAI response provided in Attachment 4 (except 4b schematic). L-14-024 Page 4 of 7 Interim Staff Evaluation Open ltem Status support the level sensor assembly. RAI-5: For RAI 4(a) above, please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics

units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompanv such seismic forces.

Not started. RAI-6: For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural inteqrity of the affected structures/equipment. RAI response provided in Attachment 4. RAI-7: Please provide the following: (a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BDB 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. lnclude 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) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracv. Not started. RAI-8: For RAI 7 above, please provide the results from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements. Not started. RAI-9: 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 pacticable. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and backup channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the read-out devices, and the independence of the displays. RAI response provided in Attachment 4. RAI-10: Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels. (b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstratinq that its capacity is RAI-10a response provided in Attachment 4. (RAI-10b to be provided in Auqust 2014 update)

Attachment 1 L-14-024 Page 5 of 7 Interim Staff Evaluation Open ltem Status sufficient to maintain the level indication function until offsite resource availability is reasonably assured. RAI-1 1: Please provide the following: (a) An estimate of the expected instrument channel accuracy performance (e.9., in percent of span) under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BDB 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 desiqn accuracv. Not started. RAI-12: Please provide the following: (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 i nstru mentation. (c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted. Discuss how these surveillances will be incorporated into the plant surveillance program. (d) A description of what preventive 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. Not started. RAI-13: Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure. Not started. RAI-14: Please provide the following: (a) Further lnformation 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 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) Describe how the guidance in NEI 12-02, Section 4.3, regarding compensatorv actions for one or both non-functioninq channels will Not started.

Attachment 1 L-14-024 Page 6 of 7 7 Potential Interim Staff Evaluation lmpacts BVPS Unit No. 1: By FENOC letterdated July 18,2013, FENOC established Level 3 as the highest point of the SFP rack at Elevation (El.)742'0.5" for BVPS Unit No. 1. lt has since been determined that the probe will have a 3" dead zone at the rack end, and the probe is designed to end 1" above the SFP rack. Therefore, Level 3 for BVPS Unit No. t has been changed to 6" above the rack, or El. 742'6.5", which takes into account the probe's 4" non-readable zone plus the calculated equipment inaccuracy of less than 2". This position is conservative and is in compliance with NEI 12-02, Revision 1, Section 2.3.3, which states that Level 3 corresponds nominally (i.e., +l-1 foot) to the highest point of any fuel rack seated in the fuel pool. BVPS Unit No. 2: FENOC has revised Level 2 for BVPS Unit No. 2 as a result of a correction highest point of the SFP rack. The highest point of the SFP rack for BVPS was determined to be El.742' 6.4" ratherthan El.742'0". Therefore, Level changed from El.752'to El. 752' 6.4". in the Unit No. 2 2 has been By FENOC letterdated July 18,2013, FENOC established Level 3 as the highest point of the SFP rack at El. 742'0" for BVPS Unit No.2. lt has since been determined that the probe will have a 3" dead zone at the rack end, and the probe is designed to end 1" above the SFP rack. As a result of this determination and the correction made in the highest point of the SFP rack, Levef 3 for BVPS Unit No. 2 has been changed to 6" above the rack, or El.743' 0.4", which takes into account the probe's 4" non-readable zone plus the calculated equipment inaccuracy of less than 2". This position is conservative and is in compliance with NEI 1 2-02, Revision 1, Section 2.3.3, which states that Level 3 corresponds nominally (i.e., +l-1 foot) to the highest point of any fuel rack seated in the fuel pool. References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Company's (FENOC's) Overall Integrated Plan in Response to March 12, 2012 Commission Order lssuance of Order to Modify lnterim Staff Evaluation Open ltem Status be addressed.

(c) Describe what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 davs. RAI-15: Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration beinq maintained at its desiqn accuracv. Not started. L-14-024 Page 7 of 7 Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated February 27,2013. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Ref iable Spent Fuel Pool Instrumentation, dated March 12,2012. Beaver Valley Power Station, Units 1 and 2 - lnterim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for lmplementation of Order EA-12-051 , Reliable Spent Fuel Pool Instrumentation, dated November 19. 2013. 2. 3.

Attachm ent 2 L-14-024 Davis-Besse Nuclear Power Station Second Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Davis-Besse Nuclear Power Station (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any. 2 MilestoneAccomplishments The following milestone(s) have been completed since July 29,2A13 and are current as of Janu ary 31, 201 4. o None 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. This section provides the activity status of each item and the expected completion date, noting any change. The dates are planning dates subject to change as design and implementation details are developed. The following milestones are being modified as part of this update to reflect the number assigned in the interim staff evaluation (lSE) (Reference 3) to each request for additional information (RAl) and to update the scheduled submittal time forthe RAls. Submit Six-Month Status Updates o Update 2, including response to ISE RAI-1, RAI-2, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-9, and RAI-10a: February 2014 o Update 3, including response to ISE RAI-4b schematic, RAI-S, RAI-7, RAI-8, RAI-10b, RAI -11, RAI-1 2, RAI-1 3, RAI-1 4, and RAI-1 5: August 2014 The revised milestone target completion dates do not impact the order implementation date.

Attachment 2 L-14-024 Page 2 of 6 4 Changes to Gompliance Method There are no changes to the compliance method as documented in the OIP (Reference 1). 5 Need for RelieflRelaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relief/relaxation is not required at this time. 6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP orthe ISE and the status of each item. Overall Inteqrated Plan Open ltem Status None Not Applicable Milestone Target Completion Date Activity Status (as of 11311141 Revised Target Completion Date Submit Six-Month Status Updates Update 1 Auqust 2013 Complete Update 2, including response fo /SE RAI-1, RAI-Z, RAI-3, RAI-4 (except 4b schematic), RAI-6, RAI-?, and RAI-I0a Februarv 2014 Started Update 3, including response fo /SE RAI-4b schematic, RAI-I, RAI-7, RAI-I, RAI-I0b, RAI-I1, RAI-I2, RAI-13, RAI-I4, and RAI-15 Auqust 2014 Not Started Update 4 Februarv 2015 Not Started Update 5 Auqust 2015 Not Started Update 6 Februarv 2016 Not Started Commence SFP Instrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP Instrumentation Desiqn 4Q13 Started 2Q15 SFP Instrumentation Deliverv 4Q14 Not Started Beqin SFP lnstrumentation Installation 1Q15 Not Started 3Q15 Commissioninq of SFP Instrumentation 2Q16 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Sprinq 2016 Not Started Interim Staff Evaluation Open ltem Status RAI-1 : Please specify for Level t how the identified location represents the higher of the two points described in the NEI 1 2-02 quidance for this level. RAI response provided in Attachment 5.

Attachment 2 L-14-024 Page 3 of 6 Interim Staff Evaluation Open ltem Status RAI-2: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., 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. RAI response provided in Attachment 5. RAI-3: 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 the proposed routing of the cables that will extend from these sensors toward the location of the read-ouUdisplay device. RAI response provided in Attachment 5. RAI-4: 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. RAI response provided in Attachment 5 (except 4b schematic). RAI-S: For RAI 4(a) above, please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics

units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

Not started. RAI-6: For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment. RAI response provided in Attachment 5. RAl-7: Please provide the following: (a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BDB 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 desiqn basis loadinq at the Not started.

Attachment 2 L-14-024 Page 4 of 6 lnterim Staff Evaluation Open ltem Status location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) 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) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracv. RAI-8: For RAI 7 above, please provide the results from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements. Not started. RAI-9: Please provide the following: (a) A description of the manner the two channels of the proposed level measurement system meet the independence requirement to minimize, to the extent pacticable, the potential for a common cause event to adversely affect both channels. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displavs. RAI response provided in Attachment 5. RAI-10: Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels. (b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured. RAI-10a response provided in. (RAI-10b to be provided in August 2014 update) RAI-1 1: Please provide the following: (a) An estimate of the expected instrument channel accuracy performance (e.9., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB 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 desiqn accuracv. Not started. RAI-12: Please provide the following: (a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, includinq how this capability enables the equipment to be Not started.

Attachment 2 L-14-024 Page 5 of 6 Potential Interim Staff Evaluation lmpacts By FENOC letter dated August 12, 2013, FENOC established Level 3 as the highest point of the SFP rack at Elevation (El.) 577' 8" for DBNPS. lt has since been determined that the probe will have a 3" dead zone at the bottom of the probe and the probe is designed to end 1" above the SFP rack. lt has also been determined that DBNPS fuel bundles sit slightly higher than the fuel rack. Therefore, the top of the highest point of the rack (including fuel) has been changed to 577' 11 118". Level 3 for DBNPS has been changed to 6" above the updated rack elevation, or El. 578' 5 118", which takes into account the probe's 4" non-readable zone plus the calculated lnterim Staff Evaluation Open ltem Status tested in-situ. (b) A description of the testing and calibration necessary to enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation. (c) A description of the calibration tests and functional checks processes to be performed, and their frequency. Discuss the steps to be taken to ensure these surveillances will be incorporated into the plant surveillance program. (d) A description of the preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed. RAI-13: Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure. Not started. RAI-14: 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 readiness requirements. lnclude 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 the approach and process to be used by the licensee to follow guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels. (c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 davs. Not started. RAI-15: Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its desiqn accuracv. Not started. L-14-024 Page 6 of 6 equipment inaccuracy of less than 2". This position is conservative and is in compliance with NEI 12-02, Revision 1, Section 2.3.3, which states that Level 3 corresponds nominally (i.e., +/- 1 foot) to the highest point of any fuel rack seated in the fuel pool. 8 References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Company's (FENOC's) Overall lntegrated Plan Response to March 12,2012 Commission Order lssuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated February 27,2013.

2. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.

3. Davis-Besse Nuclear Power Plant Unit No. 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for lmplementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated December 11.2013.

Attachment 3 L-14-024 Perry Nuclear Power Plant Second Six-Month Status Report for the lmplementation of Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Page 1 of 6 Introduction FirstEnergy Nuclear Operating Company (FENOC) developed an Overall Integrated Plan (OlP) for Perry Nuclear Power Plant (Reference 1 in Section 8), documenting the requirements to install reliable spent fuel pool (SFP) level instrumentation (Ll), in response to Reference2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. 2 MilestoneAccomplishments The following milestone(s) have been completed since July 29,2013 and are current as of January 31,2014. o None Milestone Schedule Status The following provides an update to the milestone schedule to support the OlP. This section provides the activity status of each item and the expected completion date, noting any change. The dates are planning dates subject to change as design and implementation details are developed. The following milestones are being modified as part of this update to reflect the number assigned in the interim staff evaluation (lSE) (Reference 3) to each request for additional information (RAl) and to update the scheduled submittal time forthe RAls. Submit Six-Month Status Updates o Update 2, including response to ISE RAI-1, RAI-2, RAI-3 (except 3b schematic), RAI-5, RAI-8, and RAI-9a: February 2014 Update 3, including response to ISE RAI-3b schematic, RAI-4, RAI-6, RAI-7, RAI-9b, RAI-10, RAI-11, RAI-12, RAI-13, and RAI-14: August 2014 The revised milestone target completion dates do not impact the order implementation date.

Attachment 3 L-14-024 Page 2 of 6 4 Changes to Compliance Method There are no changes to the compliance method as documented in the OIP (Reference 1). 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation FENOC expects to comply with the order implementation date. Relieflrelaxation is not required at this time. 6 Open ltems from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the OIP or the ISE and the status of each item. Overall Inteqrated Plan Open ltem Status None Not Apolicable Milestone Target Gompletion Date Activity Status (as of 11311141 Revised Target Gompletion Date Submit Six-Month Status Updates Update 1 Auqust 2Arc Complete Update 2, including response fo /SE RAI-1, RAI-2, RAI-3 (except 3b schematic), RAI-1, RAI-9, and RAI-9a Februarv 2014 Started Update 3, including response fo /SE RAI-35 schematic, RAI-4, RAI-6, RAI-7, RAI-q,, RAI-I0, RAI-11, RAI-I2, RAI-I3, and RAI-14 Auqust 2014 Not Started Update 4 Februarv 2015 Not Started Commence SFP lnstrumentation Desiqn 4Q12 Complete Commence SFP Instrumentation Procurement 2Q13 Complete Complete SFP lnstrumentation Desiqn 4Q13 Started 2Q14 SFP Instrumentation Delivery 2Q14 Not Started Beqin SFP Instrumentation Installation 3Q14 Not Started Commissioninq of SFP Instrumentation 1Q15 Not Started NRC Order lmplementation Date (based on the scheduled end of the second refueling outage after implementation plan submittal) Sprinq 2015 Not Started Interim Staff Evaluation Open ltem Status RAI-1 : Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., fixed level sensors and/or stilling wells, and mounting brackets). lndicate on this sketch the RAI response provided in Attachment 6.

Attachment 3 L-14-024 Page 3 of 6 Interim Staff Evaluation Open ltem Status 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 fuef pool level, with respect to the Level 1, Level2, and Level 3, datum points. RAI-2: 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 the proposed routing of the cables that will extend from these sensors toward the location of the read-ouVdisplay device. RAI response provlded in Attachment 6. RAI-3: 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 con nections. (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. RAI response provided in Attachment 6 (except 3b schematic). RAI-4: For RAI 3(a) above, please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics

units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sfoshing or other effects that could accompanv such seismic forces.

Not started. RAI-S: For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/equipment. RAI response provided in Attachment 6. RAI-6: Please provide the following: (a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BDB 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. lnclude a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) 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 Not started.

Attachment 3 L-14-024 Page 4 of 6 Interim Staff Evaluation Open ltem Status plant operators or emergency responders. (c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracv. RAI-7: For RAI 6 above, please provide the results from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements. Not started. RAI-8: 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 pacticable. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displavs. RAI response provided in Attachment 6. RAI-9: Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels. (b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured. RAI-9a response provided in. (RAl-gb to be provided in August 2A14 update) RAI-10: Please provide the following: (a) An estimate of the expected instrument channel accuracy performance (e.9., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB 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 desiqn accuracv. Not started. RAI-11: Please provide the following. (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. Not started.

Attachment 3 L-14-024 Page 5 of 6 Potential Interim Staff Evaluation lmpacts There are no potential impacts to the interim staff evaluation identified at this time. Level 3 at PNPP is not affected by the determination that the probe will have a 3" dead zone at the bottom of the probe and that the probe is designed to end 1" above the SFP rack. Level 3 at PNPP was estabfished at 3' 2" above the SFP rack. I References The following references support the updates to the OIP described in this attachment.

1. FirstEnergy Nuclear Operating Company's (FENOC's) Overall Integrated Plan in Response to March 12, 2012 Commission Order lssuance of Order to Modify Interim Staff Evaluation Open ltem Status (c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.

Discuss how these surveillances will be incorporated into the plant surveillance program. (d) A description of the preventive maintenance tasks 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. RAI-12: Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the spent SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure. Not started. RAI-13: 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 readiness requirements. Include a description of plans to ensure 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 FENOC's procedure/process to implement the guidance in NEI 12-02 Section 4.3 on compensatory actions for one or both non-functioning channels. (c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days. Not started. RAI-14: Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its desiqn accuracv. Not started. L-14-024 Page 6 of 6 Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-1 2-051), dated February 27,2013.

2. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12,2012.

3. Perry Nuclear Power Plant, Unit 1, - Interim Staff Evaluation and Request for Additional lnformation Regarding the Overall Integrated Plan for lmplementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation, dated December 11.2013.

L-14-024 Response to Request for Additional Information for Beaver Valley Power Station Page 1 of 13

== Introduction:== By fetter dated February 27,2013, FirstEnergy Nuclear Operating Company (FENOC) provided to the Nuclear Regulatory Commission (NRC) the Beaver Valley Power Station (BVPS) reliable spent fuel pool (SFP) instrumentation overall integrated plan. By letter dated November 19, 2013, the NRC staff issued an interim staff evaluation (lSE) for BVPS that included requests for additional information (RAls). This report provides the FENOC response to the RAls for which information is currently available. The NRC request is presented in bold type, followed by the FENOC response. Requests for Additional Information : RAI.1 : Please specify for Level t how the identified location represents the higher of the two points described in the NEI 12-02 guidance for this level.

Response

Level 1, the level that is adequate to support operation of the normal fuel pool cooling system, is defined in NEI 12-02 as the higherof the following two points: (1) The level at which reliable suction loss occurs due to uncovering of the coolant inlet pipe, weir or vacuum breaker (depending on the design), or (2) 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) specified by the pump manufacturer or engineering analysis. The coolant inlet pipes for both Unit 1 and Unit 2 are located at elevation (El.)751'3". Analysis has shown that an elevation of 755' for both units is sufficient to prevent vortexing and loss of suction. Analysis has demonstrated that for Unit 1, an elevation of 758'is required to assure adequate NPSH. For Unit 2, analysis has shown that there is adequate NPSH at an elevation of 755'. For Unit 1, the higher of the above points is (2). Therefore, Level 1 is at El. 758' for Unit 1. For Unit2, the higher of the above points is (1). Therefore, Level 1 is at El. 755'for Unit 2. L-14-A24 Page 2 of 13 RAI.2: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., 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.

Response

The following two sketches are provided. The first sketch depicts the elevation view for Unit 1. The second sketch depicts the elevation view for Unit 2.

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RAI-3

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 backup SFP level sensor, and the proposed routing of the cables that will extend from these sensors toward the location of the read-ouUdisplay device.

Response

Below are excerpts from plant drawings, being used as sketches, that depict the preliminary design and locations of the two permanently mounted level probes within the SFP area and the cable routing to locate the electronics to a non-harsh environment outside the SFP area. These sketches are excerpts from the 30 percent design change package and include references to other sketches that are not included for this response. The level transmitter electronics for Unit 1 will be located in the auxiliary building El. 755' 6", which is separated from the SFP area by one floor. The level transmitters located in the auxiliary building have a local display, although the credited display units will be located in the main control room. The inner dimensions of the Unit 1 Euel Pool are 39' 0" x 29' 6".. il!-.: lJI.ul

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L-14-024 Page11of13 (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.

Response

(a) The mounting bracket forthe sensing probe will be designed according to the plant design basis, inclusive of loads from a Safe Shutdown Earthquake (SSE). Loads that will be considered in the evaluation of the bracket and its mounting arer 1) Static loads, inclusive of the dead weight of the mounting bracket in addition to the weight of the level sensing instruments, and cabling; and 2) Dynamic loads, including the seismic load due to excitation of the dead weight of the system in addition to the hydrodynamic effects resulting from the excitation of the SFP water. A response spectra analysis will be performed for the seismic evaluation of the mounting bracket using a Finite Element Analysis (FEA) software and using floor response spectrum at the operating deck elevation (that is, mounting floor elevation). Damping values will be according to SSE and consistent with the design basis of the station. The material properties that will be used for the bracket and its mounting will take into consideration the environmental conditions in the SFP area following an event. Hydrodynamic effects on the mounting bracket will be evaluated using TID-7024 (Nuclear Reactors and Earthquakes, dated 1963). Plant acceptance criteria and applicable codes will be used for the design of the bracket and its anchorage. (b) The bracket will be attached to the pool deck using installed anchors that will be designed according to the plant existing specification for design of concrete anchors. This is the only support for this instrument. The probe attaches to the bracket's support plate via a 1 112" NPT (National Pipe Thread Taper) threaded connection. Non-movable connections of parts will be welded. The specifics of the bracket design have yet to be finalized therefore, FENOC intends to provide a schematic in the August 2014 six-month update. (c) The attachment of the seismically qualified bracket to the pool deck will be through permanently installed anchors. With the permanently installed anchors, the bracket pedestal will be secured to the poolside deck with adequate washers and bolts. RAI.6: For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

Response

Westinghouse has conducted seismic testing of the level sensor electronics bracket and electronics enclosure, which includes the mounting details, according to lnstitute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 344 (20Aq, against the L-14-024 Page 12 of 13 seismic spectra defined in the product design specification. All steel plates will conform to American Society for Testing and Materials (ASTM) Standard A240 Type 304 steel. All bolts will conform to ASTM Standard F593C. All weld material will be the same as base metal or compatible. Loads applied consist of self-weight, dead load of the instrumentation (the probe assembly including the launch plate), seismic load, and hydrodynamic load due to the seismic effect. The seismic loads are obtained from plant response spectra curves. Convective pressure associated with hydrodynamic loads will be considered for sloshing analysis by conservatively using the longest span of the pool and the height of the water between the top of the fuel racks and the high water level since the bracket cantilevers over the SFP water. The calculation of the convective pressure is based on TID-7024. Load combinations will be used in accordance with plant seismic criteria. Seismic forces in all three directions are combined using GT STRUDL, Version 32, analysis. Dead weight, seismic and convective pressure results are combined in absolute values. The FENOC engineering change process will be used to address the effect of this added instrumentation to plant structures, and it will be analyzed per the plant design basis for equipment loads. RAI.9: 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 practicable. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and read-out devices. Please address how independence of these components of the primary and backup channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the read-out devices, and the independence of the displays.

Response

(a) Within the Unit 1 SFP area, the brackets will be mounted as close to the northeast (primary sensor) and southwest (back-up sensor) corners of the SFP, as permanent plant structures allow. Within the Unit 2 SFP area, the brackets will be mounted as close to the southwest (primary sensor) and northeast (back-up sensor) corners of the SFP, as permanent plant structures allow. Placing the brackets and probes in the corners allows for natural protection from a single event or missile from disabling both systems. The cabling within the SFP area will be routed in separate hard-pipe conduit. All conduit routing and location of system components will be selected such that there will not be any seismic 2-over-1 hazard Site safety related separation requirements will be followed. (b) Each system will be installed using completely independent cabling structures, including routing of the interconnecting cable within the SFP area in separate hard-pipe L-14-024 Page 13 of 13 conduits. Power sources will be routed to the electronics enclosures from electrically separated sources ensuring the loss of one train or bus will not disable both channels. The system displays will be installed in separate qualified National Electrical Manufacturers Association (NEMA) Type 4X or better enclosures in the Unit 1 Auxiliary Building El. 752' 6" and the Unit 2 Auxiliary Building El. 755' 6", with the primary and back-up display in the main control room. Primary and backup systems will be completely independent of each other, having no shared components.

RAI-10

Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

Response

Each instrument channel is normally powered by non-class 1 E 120 volts alternating current (VAC) distribution panels to support continuous monitoring of the SFP level. The 120VAC distribution panels for the primary and backup channels at each unit are powered by different 480V buses. Therefore the loss of any one 480V bus will not result in the failure of both instrument channels. On loss of normal 120VAC power, each channel's uninterruptible power supply (UPS) automatically transfers to a dedicated backup battery. lf normal power is restored, then the channel will automatically transfer back to the normal alternating current (AC) power. The 7?-hour backup batteries are maintained in a charged state by UPSs.

Attachment 5 L-14-024

Response

to Request for Additional Information for Davis-Besse Nuclear Power Station Page 1 of 8 Introduction By letter dated February 27,2013, FirstEnergy Nuclear Operating Company (FENOC) provided to the Nuclear Regulatory Commission (NRC) the Davis-Besse Nuclear Power Station (DBNPS) reliable spent fuel pool (SFP) instrumentation overall integrated plan. By letter dated December 11,2013, the NRC staff issued an interim staff evaluation (lSE) for DBNPS that included requests for additional information (RAls). This report provides the FENOC response to the RAls for which information is currently available. The NRC request is presented in bold type, followed by the FENOC response. Requests for Additional Information : RAI.I : Please specify for Level t how the identified location represents the higher of the two points described in the NEI 12-02 guidance for this level.

Response

Level 1, the level that is adequate to support operation of the normal fuel pool cooling system, is defined in NEI 12-02 as the higherof the following two points: (1) The level at which reliable suction loss occurs due to uncovering of the coolant inlet pipe, weir or vacuum breaker (depending on the design), or (2) 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) specified by the pump manufacturer or engineering analysis. Level 1 for DBNPS is designated to be elevation (El.) 597' (19' 2" above the top of the fuel racks). Once the water level drops below El. 597', water will no longer be extracted from the pool to be sent to the SFP cooling equipment to provide heat removal from the SFP. At this level, the coolant inlet pipe is uncovered. This level is also above the level required to provide NPSH to SFP pumps at El. 585'. L-14-024 Page 2 of 8 RAI.2: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., fixed level sensors and/or stilling wells, and mounting brackets). lndicate 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.

Response

The following sketch is provided. The sketch depicts the elevation view for DBNPS. The top of fuel assemblies was used instead of the fuel rack, as the top of fuel assemblies have a higher top elevation than the top of the fuel rack. t!!! lln tltl t llltl t l t ltl L__l L-14-024 Page 3 of 8 RAI.3: 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 the proposed routing of the cables that will extend from these sensors toward the location of the read-ouUdisplay device.

Response

Below are excerpts from plant drawings, being used as sketches, that depict the preliminary design and locations of the two permanently mounted level probes within the SFP area and the cable routing to locate the electronics to a non-harsh environment outside the SFP area. These sketches are excerpts from the 30 percent design change package and include references to other sketches that are not included for this response. The level transmitter electronics will be located in the auxiliary building El. 603', on the same level as the SFP but in the building adjacent to the fuel handling buifding. The level transmitters located in the auxiliary building have a local display, although the credited display units will be located in the main control room. The inner dimensions of the SFP are 52' 11.5" x 19' 11.5". L-14-024 Page 4 of 8 L-14-424 Page 5 of 8 L-14-024 Page 6 of 8 RAI.4: 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.

Response

(a) The mounting bracket for the sensing probe will be designed according to the plant design basis, inclusive of loads from a Safe Shutdown Earthquake (SSE) (referred to as a maximum possible earthquake in the DBNPS Updated Safety Analysis Report). Loads that will be considered in the evaluation of the bracket and its mounting are:

1) Static loads, inclusive of the dead weight of the mounting bracket in addition to the weight of the level sensing instruments, and cabling; 2) Dynamic loads including the seismic load due to excitation of the dead weight of the system in addition to the hydrodynamic effects resulting from the excitation of the SFP water. A response spectra analysis will be performed for the seismic evaluation of the mounting bracket using a Finite Element Analysis (FEA) software and using floor response spectrum at the operating deck elevation (that is, mounting floor elevation). Damping values will be according to SSE and consistent with the design basis of the station. The material properties that will be used for the bracket and its mounting will take into consideration the environmental conditions in the SFP area following an event. Hydrodynamic effects on the mounting bracket will be evaluated using TID-7024 (Nuclear Reactors and Earthquakes, dated 1963). Plant acceptance criteria and applicable codes will be used for the design of the bracket and its anchorage.

(b) The bracket will be attached to the pool deck using installed anchors that will be designed according to the plant existing specification for design of concrete anchors. This is the only support for this instrument. The pedestal will be adjusted to the height of the poolside curb to ensure the SFP bracket extends over the pool horizontally level. The probe attaches to the bracket's support plate via a 1 112" NPT (National Pipe Thread Taper) threaded connection. Non-movable connections of parts will be welded. L-14-024 Page 7 of 8 The specifics of the bracket design have yet to be finalized; therefore, FENOC intends to provide a schematic in the August 2014 six-month update. (c) The attachment of the seismically qualified bracket to the pool deck will be through permanently installed anchors. With the permanently installed anchors, the bracket pedestal will be secured to the poolside deck with adequate washers and bolts. RAI.6: For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

Response

Westinghouse has conducted seismic testing of the level sensor electronics bracket and electronics enclosure, which include the mounting details, according to Institute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 344 (2004), against the seismic spectra defined in the product design specification. All steel plates will conform to American Society for Testing and Materials (ASTM) Standard A240 Type 304 steel. All bolts will conform to ASTM Standard F593C. All weld material will be the same as base metal or compatible. Loads applied consist of self-weight, dead load of the instrumentation (the probe assembly including the launch plate), seismic load, and hydrodynamic load due to the seismic effect. The seismic loads are obtained from plant response spectra curves. Convective pressure associated with hydrodynamic loads will be considered for sloshing analysis by conservatively using the longest span of the pool and the height of the water between the top of the fuel racks and the high water level since the bracket cantilevers over the SFP water. The calculation of the convective pressure is based on TID-7024. Load combinations will be used in accordance with plant seismic criteria. Seismic forces in all three directions are combined using GT STRUDL, Version 32, analysis. Dead weight, seismic and convective pressure results are combined in absolute values. The FENOC engineering change process will be used to address the effect of this added instrumentation to plant structures, and it will be analyzed per the plant design basis for equipment loads. RAI.9: Please provide the following: (a) A description of the manner the two channels of the proposed level measurement system meet the independence requirement to minimize, to the extent practicable, the potential for a common cause event to adversely affect both channels. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout L-14-024 Page 8 of 8 devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays. Response. (a) Within the SFP area, the brackets will be mounted as close to the northeast (primary sensor) and southeast (back-up sensor) corners of the SFP, as permanent plant structures allow. Placing the brackets and probes in the corners allows for natural protection from a single event or missile from disabling both systems. The cabling within the SFP area will be routed in separate hard-pipe conduit. All conduit routing and location of system components will be selected such that there will not be any seismic 2-over-1 hazard Site safety related separation requirements will be followed. (b) Each system will be installed using completely independent cabling structures, including routing of the interconnecting cable within the SFP area in separate hard-pipe conduits. Power sources will be routed to the electronics enclosures from electrically separated sources ensuring the loss of one train or bus will not disable both channels. The system displays will be installed in separate qualified National Electrical Manufacturers Association (NEMA) Type 4X or better enclosures in the auxiliary building El. 623', with the primary and back-up display in the main control room. Primary and backup systems will be completely independent of each other, having no shared components. RAt-10: Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

Response

Each instrument channel is normally powered by non-class 1E 120 volts alternating current (VAC) distribution panels to support continuous monitoring of the SFP level. The 120VAC distribution panels for the primary and backup channels at each unit are powered by different 480V buses. Therefore, the loss of any one 480V bus will not result in the failure of both instrument channels. On loss of normal 120YAC power, each channel's uninterruptible power supply (UPS) automatically transfers to a dedicated backup battery. lf normal power is restored, then the channel will automatically transfer back to the normal alternating current (AC) power. The 72-hour backup batteries are maintained in a charged state by UPSs. L-14-024 Response to Request for Additional Information for Perry Nuclear Power Plant Page 1 of 10

== Introduction:== By letter dated February 27,2013, FirstEnergy Nuclear Operating Company (FENOC) provided to the Nuclear Regulatory Commission (NRC) the Perry Nuclear Power Plant (PNPP) reliable spent fuel pool (SFP) instrurnentation overall integrated plan. By letter dated December 11,2013, the NRC staff issued an interim staff evaluation (lSE) for PNPP that included requests for additional information (RAls). This report provides the FENOC response to the RAls for which information is currently available. The NRC request is presented in bold type, followed by the FENOC response. Requests for Additional Information : RAI.1 : Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.9., 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.

Response

The following sketch is provided. The sketch depicts the elevation view for PNPP.

Attachment 6 L-14-024 Page 2 of 10 T+p ot Measurrynent Range {Expected to bs ff1$i-1ffr" but lvillh,e datarrnined by fineJ *Bb"le design length} L-14-024 Page 3 of 10 RAI.2: 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 the proposed routing of the cables that will extend from these sensors toward the location of the read-ouUdisplay device.

Response

Below are excerpts from plant drawings, being used as sketches, that depict the preliminary design and locations of the two permanently mounted level probes within the SFP area and the cable routing to locate the electronics to a non-harsh environment outside the SFP area. The level transmitter electronics will be located in the intermediate building elevation (El.) 654'6", which is separated from the SFP area by one floor. The level transmitters located in the intermediate building have a local display, although the credited display units will be located in the main control room on the east wall, in panel 1 H13P0970. L-14-024 Page 4 of 10 g i-n l--* t* aiiffi'$iih tri g $ffi rlllr li:Ir ;ll q# $$ iHrii{#ln'g#i$ffi )lpffi'"'-"t

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Attachment 6 L-14-024 Page 6 of 10 1g tLL[,'r& im:fii

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I -I UJ L-14-024 Page 7 of 10 The inside dimensions of the fuel preparation pool, which installed, are 20' 2" x 36' 0". Reference the excerpt from is where the sensors will be a plant drawing below.

q iffEJ lFqu ilgii
d

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fi*l*iiu./ '\\i ,/r f / ,.1,/ -\\lrt \\ / }\\ I Fffi EriS*1 I 2F42.FG&*r I l .l ffiff."ffi ryt 4 F - l L-\\4-024 Page 8 of 10 RAI.3: 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. (a) The mounting bracket for the sensing probe will be designed according to the plant design basis, inclusive of loads from a Safe Shutdown Earthquake (SSE). Loads that will be considered in the evaluation of the bracket and its mounting are: 1) Static loads, inclusive of the dead weight of the mounting bracket in addition to the weight of the level sensing instruments, and cabling; 2) Dynamic loads including the seismic load due to excitation of the dead weight of the system in addition to the hydrodynamic effects resulting from the excitation of the SFP water. A response spectra analysis will be performed for the seismic evaluation of the mounting bracket using a Finite Element Analysis (FEA) software and using floor response spectrum at the operating deck elevation (that is, mounting floor elevation). Damping values will be according to SSE and consistent with the design basis of the station. The material properties that will be used for the bracket and its mounting will take into consideration the environmental conditions in the SFP area following an event. Hydrodynamic effects on the mounting bracket will be evaluated using TID-7024 (Nuclear Reactors and Earthquakes, dated 1963). Plant acceptance criteria and applicable codes will be used for the design of the bracket and its anchorage. (b) The bracket will be attached to the pool deck using installed anchors that will be designed according to the plant existing specification for design of concrete anchors. This is the only support for this instrument. The pedestal will be adjusted to the height of the poolside curb to ensure the SFP bracket extends over the pool horizontally level. The probe attaches to the bracket's support plate via a 1 112" NPT (National Pipe Thread Taper) threaded connection. Non-movable connections of parts will be welded. The specifics of the bracket design have yet to be finalized: therefore, FENOC intends to provide a schematic in the August 2014 six-month update. L-14-A24 Page 9 of 10 (c) The attachment of the seismically qualified bracket to the pool deck will be through permanently installed anchors. With the permanently installed anchors, the bracket pedestal will be secured to the poolside deck with adequate washers and bolts. RAI.5: For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/equipment.

Response

Westinghouse has conducted seismic testing of the level sensor electronics bracket and electronics enclosure, which include the mounting details, according to Institute of Electrical and Electronics Engineers, Inc. (IEEE) Standard 344 (2004), against the seismic spectra defined in the product design specification. All steel plates will conforrn to American Society for Testing and Materials (ASTM) Standard A240 Type 304 steel. All bolts will conform to ASTM Standard F593C. All weld material will be the same as base metal or compatible. Loads applied consist of self-weight, dead load of the instrumentation (the probe assembly including the launch plate), seismic load, and hydrodynamic load due to the seismic effect. The seismic loads are obtained from plant response spectra curves. Convective pressure associated with hydrodynamic loads will be considered for sloshing analysis by conservatively using the longest span of the pool and the height of the water between the top of the fuel racks and the high water level since the bracket cantilevers over the SFP water. The calculation of the convective pressure is based on TID-7024. Load combinations will be used in accordance with plant seismic criteria. Seismic forces in all three directions are combined using GT STRUDL, Version32, analysis. Dead weight, seismic and convective pressure results are combined in absolute values. The FENOC engineering change process will be used to address the effect of this added instrumentation to plant structures, and it will be analyzed per the plant design basis for equipment loads. RAI.8: 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 practicable. (b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays. L-14-024 Page 10 of 10

Response

(a) Within the SFP area, the brackets will be mounted as close to the northeast (primary sensor) and southwest (back-up sensor) corners of the fuel preparation

pool, as permanent plant structures allow. Placing the brackets and probes in the corners allows for natural protection from a single event or missile from disabling both systems.

The cabling within the SFP area will be routed in separate hard-pipe conduit. All conduit routing and location of system components will be selected such that there will not be any seismic 2-over-1 hazard. Site safety related separation requirements will be followed. (b) Each system will be installed using completely independent cabling structures, including routing of the interconnecting cable within the SFP area in separate hard-pipe conduits. Power sources will be routed to the electronics enclosures from electrically separated sources ensuring the loss of one train or bus will not disable both channels. The system displays will be installed in separate qualified National Electrical Manufacturers Association (NEMA) Type 4X or better enclosures in the intermediate building El. 654', with the primary and back-up display in the main control room. Primary and backup systems will be completely independent of each other, having no shared components. RAI.9: Please provide the following: (a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

Response

Each instrument channel is normally powered by non-class 1 E 120 volts alternating current (VAC) distribution panels to support continuous monitoring of the SFP level. The 120VAC distribution panels for the primary and backup channels at each unit are powered by different 480V buses. Therefore, the loss of any one 480V bus will not result in the failure of both instrument channels. On loss of normal 120VAC power, each channel's uninterruptible power supply (UPS) automatically transfers to a dedicated backup battery. lf normal power is restored then the channel will automatically transfer back to the normal alternating current (AC) power. The 7?-hour backup batteries are maintained in a charged state by UPSs.}}

v t e Letter Sequence Other
TAC:MF0799, (Open) TAC:MF0800, (Approved, Closed) TAC:MF0802, (Open) TAC:MF0960, (Open)
Initiation Request Acceptance... Administration Questions 25 June 2013 19 November 2013 Answers 18 July 2013 Results Approval... Other: L-13-035, Firstenergy Nuclear Operating Companys Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-1, L-13-057, Overall Integrated Plan in Response to March 12, 2012 Commission Order Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051), L-13-244, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses Re Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), L-14-024, Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), L-14-259, Firstenergy Nuclear Operating Companys (Fenocs) Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), L-15-001, Firstenergy Nuclear Operating Companys (Fenocs) Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool, L-15-208, Provides Notification of Completion of Required Action by NRC Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, ML15152A218, ML15292A139
MONTHYEAR2013-08-05 [Table View]

L-14-024, Firstenergy Nuclear Operating Companys (Fenocs) Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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