PLA-7138, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) PLA-7138

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Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) PLA-7138
ML14059A079
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 02/27/2014
From: Rausch T
Susquehanna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, PLA-7138, TAC MF0890, TAC MF0891
Download: ML14059A079 (28)
v • d • e


Text

Timothy 5. Rausch PPL Susquehanna, LLC Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3345 Fax 570.542.1504 FEB 2 7 2014 tsrausch@ pplweb.com TM U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION SECOND SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION (NRC ORDER EA-12-051) Docket No. 50-387 PLA-7138 and No. 50-388

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012
3. 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, dated August 2012
4. PPL Letter (PLA -6925), "Initial Status Report 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 October 29, 2012
5. PPL Letter (PLA-6980), "Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013
6. PPL Letter (PLA-7073), "First 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)," dated August 26, 20I3
7. PPL Letter (PLA-7026), "Response To Request For Additional Information On Overall Integrated Plan In Response To Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation,"'

dated July 3, 2013

8. NRC Letter titled, "Susquehanna Steam Electric Station, Units 1 and 2 -Interim Staff Evaluation And Request For Additional Information Regarding The Overall Integrated Plan For Implementation Of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NOS. MF0890 and MF0891),"

dated November 6, 2013 The purpose of this letter is to provide PPL Susquehanna, LLC's (PPL) second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. Enclosure 1 provides an update of milestone accomplishments since the last status report, including any

Document Control Desk PLA-7138 changes to the compliance method, schedule, or need for relief and the basis, if any. This letter also provides PPL's response in Enclosure 2 to the NRC's latest Request for Additional Information identified in Reference 8. Enclosure 2 of this letter contains sketches containing security-related information to be withheld from public notice in accordance with 10 CFR 2.390 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")

issued an order (Reference 1) to PPL Susquehanna, LLC (PPL). Reference 1 was immediately effective and directed PPL to install reliable spent fuel pool level instrumentation. 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 IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided PPL' s initial status report regarding Spent Fuel Pool Level Instrumentation. Reference 5 provided PPL' s overall integrated plan for Spent Fuel Pool Level Instrumentation.

Reference 1 requires submission of status reports at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provided PPL's first six-month update.

Reference 7 addressed the NRC's initial Request for Additional Information for the overall integrated plan submitted under Reference 5.

This letter contains no new or revised regulatory commitments.

If you have any questions regarding this report, please contact Mr. John L. Tripoli at 570-542-3100.

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

Executed on:

Document Control Desk PLA-7138

Enclosures:

1) PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation.
2) PPL Susquehanna, LLC' s Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA 051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013.

Note: Attached sketches contain Security-Related Information- Withhold from Public Notice in Accordance with 10 CFR 2.390 Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP

Enclosure 1 to PLA-7138 PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation

Enclosure 1 to PLA-7138 Page 1 of 3 PPL Susquehanna, LLC's Second Six Month Status Report for the Implementation of NRC Order EA-12-051, Order Modifying Licenses with Regard to Requirements for to Reliable Spent Fuel Pool Instrumentation

1. Introduction PPL Susquehanna, LLC (PPL) developed an Overall Integrated Plan (Reference 1),

documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFP LI), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

[NOTE: References cited in this enclosure are contained in Section 8]

2. Milestone Accomplishments No milestone(s) have been completed since the first six-month update submitted under Reference 6, and are current as of January 31, 2014.
3. Milestone Schedule Status The following provides a milestone schedule that supports the Overall Integrated Plan. 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.

Revised Target Activity Target Milestone Completion Status Completion Date Date Submit 60-Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Not Started Update 4 Feb 2015 Not Started Update 5 Aug 2015 Not Started

Enclosure 1 to PLA-713 8 Page 2 of 3 Revised Target Activity Target Milestone Completion Status Completion Date Date Modifications:

Modification Scoping July 2013 Complete Evaluation Issue Unit 1 and Unit 2 March 2014 Started Engineering Changes Implementation Outage June 2015 Not Started Procedures:

Create Procedures March 2015 Not Started Training:

Develop Training Plan Dec 2014 Started Training Complete March 2015 Not Started Full Site SFP LI Implementation June 2015 Not Started Submit Completion Report August 2015 Not Started

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).
5. Need for Relief/Relaxation and Basis for the Relief/Relaxation PPL expects to comply with the order implementation date and no relief/relaxation is required at this time.
6. Open Items from Overall Integrated Plan and Draft Safety Evaluation See Enclosure 2 for the current status of Susquehanna responses to NRC's Request for Additional Information (RAis) in Reference 7.

Enclosure 1 to PLA-7138 Page 3 of3

7. Potential Draft Safety Evaluation Impacts None- PPL Susquehanna has not received a draft Safety Evaluation at this time but has received Interim Staff Evaluation (Reference 7).
8. References The following references support the updates to the Overall Integrated Plan described in this enclosure.
1. PPL Letter (PLA-6980), "Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013.
2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.
3. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Rev 0," dated August 29, 2012
4. NEI 12-02, "Industry Guidance for Compliance with Order EA-12-051 to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," Revision 1, August 2012
5. PPL Letter (PLA-7026), "Response to Request for Additional Information on Overall Integrated Plan in Response to Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation,"' dated July 3, 2013
6. PPL Letter (PLA-7073), "First 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),"

dated August 26, 2013

7. NRC Letter titled, "Susquehanna Steam Electric Station, Units 1 and 2- Interim Staff Evaluation And Request For Additional Information Regarding The Overall Integrated Plan For Implementation Of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NOS. MF0890 and MF0891)," dated November 6, 2013

Enclosure 2 to PLA-7138 PPL Susquehanna, LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013.

Note: Attached sketches contain Security-Related Information- Withhold from Public Notice in Accordance with 10 CFR 2.390

Enclosure 2 to PLA-7138 Page 1 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response 1 RAI-l- Please explain how water at the selected elevation 1- Level 1 has been changed from Elevation 816 ft. 9 in. to Elevation of 816ft. 9 in., for Levell, supports adequate operation of 817 ft. 1 in. Elevation 817 ft. 1 in. is the elevation at the top of the the normal fuel pool cooling system. Spent Fuel Pool (SFP) weir plates (See attached Sketch-SFPI-1).

As long as water level is above the weir plate, water flows over the weir plates through the weirs into the skimmer surge tank. The spent fuel pool cooling pumps take suction from the skimmer surge tank. The discharge piping from the fuel pool cooling pumps enters the fuel pool above the water level, and is dispersed along the fuel pool floor through diffusers. The diffuser piping is

' equipped with anti-siphoning devices to prevent siphoning of the fuel pool through this piping. There are no connections to the fuel pool that would allow draining the pool.

2 RAI Please identify the final SFP level instrumentation 2- The final SFP level instrumentation (SFP Ll) measurement range is measurement range. from Elevation 818ft. 0 in. to Elevation 794ft. 4 in. (See attached Sketch-SFPI-1), pending vendor confirmation.

3 RAI-3.a- Please provide a description of the *operational 3.a- A description of the operational circumstances under which the circumstances under which the gates are expected to be gates are installed is provided in the Susquehanna SES (SSES) '

installed, and describe how continuous backup monitoring Final Safety Analysis Report (FSAR) Section 9.1.3.3 and Technical (e.g., direct visual observation) is available when the gates Requirements Manual (TRO 3.7.10). The FSAR states, "The spent are installed. fuel pools are normally maintained in a cross-tied configuration during dual unit operation and refueling outages." The FSAR also Note- This information was previously requested as RAI-3.a states, "Certain specific plant evolutions will require the pools to be in the NRC letter dated June 17, 2013.

isolated. These evolutions will be procedurally controlled to ensure that sufficient cooling systems are available given the plant configuration at the time of the evolution." The procedural controls reside in maintenance and operating procedures and the TRO 3.7.10.

Enclosure 2 to PLA-7138 Page 2 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response These gates have not been installed since 2006 when PPL implemented a new dry fuel storage process that precludes the need to install the gates.

No operational circumstances have occurred since 2006 and none are anticipated that will warrant installation of the gates.

Thus, maintaining the gates to both pools open is the normal plant configuration.

4 RAI-3.b- Demonstrate that both the primary and backup 3.b- See attached Sketch-SFPI-1 that identifies the bottom of the probe instruments can simultaneously measure the same lower and the bottom of the cask storage pool gate.

level when the gates are open by indicating the bottom elevation of the gate openings.

Note - This information was previously requested as RAI-3.b in the NRC letter dated June 17, 2013.

5 RAI-3.c - Update Sketches 2 and 3 as needed. 3.c- See attached Sketches-SFPI-2 and SFPI-3 that identify the routing and separation of the instrument channels.

Note - This information was previously requested as RAI-3.c in the NRC letter dated June 17, 2013.

6 RAI Please describe the impact of the installation of the 4- The existing fuel pool level monitoring instrumentation, associated gate on the reliability of the SFP level instrumentation for alarms and indications that is installed in each pool is not being each SFP, and what compensatory measures would be taken removed. During normal operation, this instrumentation will to ensure reliable level indication in each SFP when the gate provide an additional indication that the fuel pool levels are in the normal range whether the gates are removed or installed. As is installed identified in the SSES FSAR Section 9.1.3.3, this instrumentation is designed to operate following an Operating Basis Earthquake and under boiling spent fuel pool conditions. While not classified as Class lE equipment, the instruments receive power from

Enclosure 2 to PLA-7138 Page 3 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response independent Class IE power supplies that are Diesel Generator backed.

Given the robust design of the new fuel pool level instrumentation being installed, the robust design of the existing fuel pool instrumentation, the fact that the pools have been cross-tied since 2006 and are anticipated to remain cross-tied, no additional means to provide fuel pool level indication are wananted.

7 RAI Please provide clearly labeled sketch or marked-up 5- See attached Sketches-SFPI-2 and SFPI-3 that identify the routing plant drawing of the plan view of the SFP area, depicting the and separation of the instrument channels.

proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.

Note - This infonnation was previously requested as RAI-4 in the NRC letter dated June 17, 2013.

8 RAI Please provide additional information describing 6- The design meets the Order requirements to arrange the SFP LI how the final arrangement of the SFP instrumentation and channels in a manner that provides reasonable protection of the routing of the cabling between the level instruments, the level indication function against missiles that may result from electronics and the displays, meets the Order requirement to damage to the structure over the SFP as follows:

arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication

  • Locating the probes in opposite ends of the Spent Fuel Pool. In function against missiles that may result from damage to the addition, each probe is located in a corner of the Spent Fuel I structure over the SFP. Pool.
  • Routing the cables through different Units. Cable routing for Unit 1's SFP LI will be routed through the Unit 1 Reactor Building while Unit 2's SFP LI will be routed through the Unit 2 Reactor Building. In the Common Control Structure,

Enclosure 2 to PLA-7138 Page 4 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response Unit 1's SFP LI will be located in the Unit 1 Control Room while Unit 2's SFP LI will be located in the Unit 2 Control Room.

  • Using diverse power supplies. Unit 1's SFP LI will be powered by a Division I power supply while Unit 2's SFP LI will be powered by a Division IT power supply.
  • Utilizing instrumentation that is continuously self-checking. A random failure in the electronics of the SFP LI of either Unit will be promptly reported by the instrumentation. The probability of a simultaneous failure of both SFP LI is very small.
  • The signal from each probe is not cross-connected at any point.
  • See attached Sketches -SFPI-2 and SFPI-3 for more information.

9 RAI-7.a- Please provide the design criteria that will be used 7.a- The loading on the probe mount and probe body includes both I to estimate the total loading on the mounting device(s), seismic and hydrodynamic loading using seismic response spectra including static weight loads and dynamic loads. Describe that bounds the site design basis maximum seismic loads applicable the methodology that will be used to estimate the total to the installation locations. The static weight load is accounted for loading, inclusive of design basis maximum seismic loads in the modeling but is insignificant in comparison to seismic and and the hydrodynamic loads that could result from pool hydrodynamic loads.

sloshing or other effects that could accompany such seismic Analytic modeling was petformed in accordance with Institute of forces. Electrical and Electronic Engineers (IEEE)-344 2004 methodology.

Enclosure 2 to PLA-7138 Page 5 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response Note- This information was previously requested as RAI-5.a A detailed computational SFP hydrodynamic model was in the NRC letter dated June 17, 2013. developed. The computational model accounts for multi-dimensional fluid motion, pool sloshing, and loss of water from the pool.

Seismic loading response of the probe and mount was separately modeled using finite element modeling software. Fluid motion hydrodynamic load terms are added to the calculated seismic loading terms in the finite element model to provide a conservative estimate of the combined seismic and hydrodynamic loading terms for the probe and probe mount.

10 RAI-7.b- Provide a description of the manner in which the 7.b- The probe flange will be bolted to a rigid steel mounting bracket level sensor (and stilling well, if appropriate) will be attached that will be welded to the SFP wall liner plate. The liner plate at to the refueling floor and/or other support structures for each this location is backed by a W6X20 steel embedment. The planned point of attachment of the probe assembly. Indicate electrical connection will be located at the end of the level in a schematic the portions of the level sensor that will serve element's lead. See attached Sketches -SFPI-1 and SFPI-4.

as points of attachment for mechanical/mounting or electrical connections.

Note- This information was previously requested as RAI-5.b in the NRC letter dated June 17, 2013.

Enclosure 2 to PLA-7138 Page 6 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response 11 RAI-7.c - Provide a description of the manner by which the 7.c- See response to RAI-7.b (Item 10).

mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

Note- This information was previously requested as RAI-5.c in the NRC letter dated June 17, 2013.

12 RAI For RAI #7(a) above, please provide the analyses 8- The requested information does not currently exist and is being used to verify the design criteria and methodology for developed as part of our design process. The information will be seismic testing of the SFP instrumentation and the provided as part of an upcoming required 6-month update to the electronics units, including, design basis maximum seismic Overall Integrated Plan, or as a separate transmittal, but is expected loads and the hydrodynamic loads that could result from to be supplied no later than August 28, 2014.

pool sloshing or other effects that could accompany such seismic forces 13 RAI For each of the mounting attachments required to 9- The requested information does not currently exist and is being attach SFP level equipment to plant structures, please developed as part of our design process. The information will be describe the design inputs, and the methodology that was provided as part of an upcoming required 6-month update to the used to qualify the structural integrity of the affected Overall Integrated Plan, or as a separate transmittal, but is expected structures/equipment. to be supplied no later than August 28, 2014.  !

14 RAI-10.a- Please provide a description of the specific 10.a- Two NEMA 4X boxes (one for Unit 1 and one for Unit 2) for level method or combination of methods you intend to apply to display and electronics will be mounted in the Main Control Room.

demonstrate the reliability of the permanently installed equipment under Beyond-Design-Basis (BDB) ambient Temperature: Information provided by the vendor states that this temperature, humidity, shock, vibration, and radiation box is suitable for an environment of approximately 15° F to conditions. approximately 130° F. Physical testing in an environmental chamber demonstrates normal operation at this operating

Enclosure 2 to PLA-7138 Page 7 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response Note- This information was previously requested as RAI-6.a temperature.

in the NRC letter dated June 17, 2013.

Humidity: The boxes, as described above are designed as NEMA 4X boxes and are defined as Type 4 Enclosures. The boxes are constructed for either indoor or outdoor use to provide a degree of protection to personnel against access to hazardous parts; to provide a degree of protection of the equipment inside the .

enclosure against ingress of solid foreign objects (falling dirt and windblown dust); to provide a degree of protection with respect to harmful effects on the equipment due to the ingress of water (rain, sleet, snow, splashing water, and hose directed water); and that will be undamaged by the external formation of ice on the enclosure.

The Main Control Room is an indoor location and the NEMA 4X enclosure provides more than adequate protection against the effects on normal humidity. The Main Control Room is located in the Control Structure and not the Reactor Building where the Spent Fuel Pool is located. The Main Control Room is environmentally controlled normally and not subject to temperature or humidity excursions. If the Spent Fuel Pool were to boil, the Main Control Room is not in close proximity to the Spent Fuel Pool therefore, a humidity excursion will not occur.

The probe assemblies are located in the Spent Fuel Pool. These probes are constructed of materials with properties and have a usage history, which have been used in steam generator applications at significantly higher temperatures and pressures, as well as a saturated steam environment, than those of a boiling spent fuel pool. A boiling spent fuel pool is under normal atmospheric

Enclosure 2 to PLA-7138 Page 8 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response conditions and thus the temperature could be no more than 212° F and 100% humidity.

Shock:

\

  • Signal processor: Physical testing to commercial and/or military standards using shake-table and shock/vibration testing.

Vibration:

  • Signal processor: Physical testing to applicable commercial and/or military standards using shake-table and drop testing.
  • Probe assembly: The probe assembly and bracket together form a simple static uni-body structure with intrinsic vibration resistance that is additionally subject to substantial damping due to the surrounding water medium. This was modeled using finite element modeling in conjunction with seismic modeling I

described above.

Radiation:

  • Signal processor: The EFP signal processor is installed in a mild environment with radiation levels similar to background radiation, with the acknowledgement that the radiation limit for the EFP is similar to other commercial-grade complementary-metal-oxide-semiconductor (CMOS)-based electronics. Radiation testing is not planned. It should be noted that the instrument performs self-diagnostics before

Enclosure 2 to PLA-7138 Page 9 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response measurements are obtained and the electronics are easily accessible for periodic replacement.

  • Probe assembly: The probe will be analyzed for a Total Integrated Radiation Dose. The probe's primary material make-up has minimal degradation from radiation being composed primarily of stainless steel. The insulators in the probe are also subject to long-term radiation exposure. The insulator material is less susceptible to radiation degradation than other materials.

15 RAI-10.b- Please provide a description of the testing and/or 10.b- See response to RAI-10.a (Item 14).

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.

Note- This information was previously requested as RAI-6.b in the NRC letter dated June 17, 201.

16 RAI-10.c- Include a discussion of this seismic reliability 10.c- Level Sensor mounted in the SFP:

demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read- Seismic and hydrodynamic finite element analysis will be out and re-transmitting devices that will be employed to performed in accordance with IEEE-344 2004 methodology (using convey the level information from the level sensor to the enveloping conditions) applicable to the mounting locations.

plant operators or emergency responders.

Note- This information was previously requested as RAI-6.c This analysis will demonstrate that the probe waveguide's in the NRC letter dated June 17, 2013. geometric dimensions do not change and cause system

~-

Enclosure 2 to PLA-7138 Page 10 of20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response inaccuracies.

Control boxes, electronics, or read-out and re-transmitting devices:

Triaxial shake-table testing will be performed using IEEE-344 2004 methodology.

The* accuracy of system electronics will be demonstrated following seismic excitation as part of the seismic testing protocol previously discussed.

17 RAI-10.d- Please provide a description of the specific 10.d- See response to RAI-10.c (Item 16).

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 accuracy.

Note - This information was previously requested as RAI-6.d in the NRC letter dated June 17, 2013.

18 RAI For RAI #10 above, please provide the results 11- The requested information does not currently exist and is being from the selected methods, tests and analyses used to developed as part of our design process. The information will be demonstrate the qualification and reliability of the installed provided as part of an upcoming required 6-month update to the equipment in accordance with the Order requirements. Overall Integrated Plan, or as a separate transmittal, but is expected to be supplied no later than August 28, 2014.

Enclosure 2 to PLA-7138 Page 11 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response 19 RAI-12.a- Please provide a description of how the two 12.a- See response to RAI-6 (Item 8).

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.

Note- This information was previously requested as RAI-7.a in the NRC letter dated June 17, 2013.

20 RAI-12.b- Further information on how each level 12.b- See response to RAI-6 (Item 8).

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.

Note- This information was previously requested as RAI-7.b in the NRC letter dated June 17, 2013.

21 RAI-13.a- Please provide a description of the electrical ac 13.a- The two Spent Fuel Pool Level instruments use two separate Safety power sources and capabilities for the primary and backup Related power supplies to power the two units. One power supply channels. is from Division I and the other from Division II. The sources are breakers located in the two separate Units, respectively. One source being from Unit 1 and one being from Unit 2. These power supplies are backed by the station's Emergency Diesel generators and will be backed by the FLEX Generators.

Enclosure 2 to PLA-7138 Page 12 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response 22 RAI-13.b- Please provide the results of the calculation 13.b- The requested information does not currently exist and is being depicting the battery backup duty cycle requirements developed as part of our design process. The information will be demonstrating that its capacity is sufficient to maintain the provided as part of an upcoming required 6-month update to the level indication function until offsite resource availability is Overall Integrated Plan, or as a separate transmittal, but is expected to be supplied no later than August 28, 2014.

reasonably assured.

23 RAI-14.a- Please provide an estimate of the expected 14.a- The requested information does not currently exist and is being instrument channel accuracy performance under both (i) developed as part of our design process. The information will be normal SFP level conditions (approximately Level 1 or provided as part of an upcoming required 6-month update to the higher), and (ii) at the BDB conditions (i.e., radiation, Overall Integrated Plan, or as a separate transmittal, but is expected temperature, humidity, and post-seismic and post-shock to be supplied no later than August 28, 2014.

conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

Note - This information was previously requested as RAI-9.a in the NRC letter dated June 17, 2013.

24 RAI-14.b- Please provide a description of the methodology 14.b- The requested information does not currently exist and is being I that will be used for determining the maximum allowed developed as part of our design process. The information will be deviation from the instrument channel design accuracy that provided as part of an upcoming required 6-month update to the will be employed under normal operating conditions as an Overall Integrated Plan, or as a separate transmittal, but is expected acceptance criterion for a calibration procedure to flag to to be supplied no later than August 28, 2014.

operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

Note - This information was previously requested as RAI-9.b in the NRC letter dated June 17, 2013.

Enclosure 2 to PLA-7138 Page 13 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response 25 RAI-15.a- Please provide a description of the capability and 15.a- The instrument automatically monitors the integrity of the installed provisions the proposed level sensing equipment will have to level measurement system using built-in diagnostic capability.

enable periodic testing and calibration, including how this Periodic calibration checks of the signal processor electronics will capability enables the equipment to be tested in-situ. be achieved through the use of standard measurement and test equipment.

Note - This information was previously requested as RAJ-10.a in the NRC letter dated June 17, 2013. The probe itself is a petforated tubular coaxial waveguide with defined geometry and need not be calibrated. It will be periodically visually inspected to demonstrate that the probe assembly has not experienced any mechanical deformation.

Each instrument electronically logs a record of measurement values over time in a non-volatile memory that can be compared to demonstrate constancy, including any changes in pool level, such as that associated with the normal evaporative loss/refilling cycle.

The channel level measurements are able to be directly compared to each other (i.e., regular cross-channel comparisons) and existing SFP level instrumentation.

26 RAI-15.b- Please provide a description of how such testing 15.b- Each instrument electronically logs a record of measurement values and calibration will enable the conduct of regular channel over time in non-volatile memory that can be-compared to checks of each independent channel against the other, and demonstrate constancy, including any changes in pool level, such against any other permanently-installed SFP level as that associated with the normal evaporative loss/refilling cycle.

instrumentation. The channel level measurements can be directly compared to each other (i.e., regular cross-channel comparisons) and existing SFP Note - This information was previously requested as RAJ-level instrumentation.

10.b in the NRC letter dated June 17, 2013.

Enclosure 2 to PLA-7138 Page 14 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response 27 RAI-15.c- Please provide a description of how functional 15.c- Functional checks are automated and/or semi-automated (requiring checks will be petformed, and the frequency at which they limited operator interaction) and will be performed through the will be conducted. Describe how calibration tests will be instrument menu software. There are a number of other internal performed, and the frequency at which they will be system tests that are performed by system software on an conducted. Provide a discussion as to how these essentially continuous basis without user intervention but can also surveillances will be incorporated into the plant surveillance be performed on an on-demand basis with diagnostic output to the program.

display for the operator to review. Other tests such as menu button Note - This information was previously requested as RAJ- tests, level alarm, and alarm relay tests can also be pe1formed.

10.c in the NRC letter dated June 17, 2013. Functional checks are described in detail in the Vendor Operator's Manual.

Functional tests will be performed periodically based on the recommendations of the equipment vendor and in accordance with station processes and procedures.

28 RAI-15.d- Please provide a description of what preventative 15.d- Preventative maintenance tasks and associated performance maintenance tasks are required to be performed during intervals will be petformed based on the vendor recommendations normal operation, and the planned maximum surveillance for applicable system components and station processes and interval that is necessary to ensure that the channels are fully procedures.

conditioned to accurately and reliably perform their functions when needed.

Note - This information was previously requested as RAJ-10.d in the NRC letter dated June 17, 2013.

Enclosure 2 to PLA-7138 Page 15 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAJ and enhanced identifiers PPL Response 29 RAI Please provide a list of the procedures addressing 16- The requested information does not currently exist anq is being operation (both normal and abnormal response), calibration, developed as part of our design process. The information will be test, maintenance, and inspection procedures that will be provided as part of an upcoming required 6-month update to the developed for use of the SFP instrumentation. The licensee Overall Integrated Plan, or as a separate transmittal, but is expected is requested to include a brief description of the specific to be supplied no later than August 28, 2014.

technical objectives to be achieved within each procedure.

30 RAI-17.a- Please provide further information describing the 17.a- The maintenance and testing program requirements that will ensure maintenance and testing program the licensee will establish design and system readiness will be established in accordance with and implement to ensure that regular testing and calibration procedures and design processes considering vendor I is performed and verified by inspection and audit to recommendations to ensure that appropriate regular testing, channel demonstrate conformance with design and system readiness checks, functional tests, periodic calibration, and maintenance is requirements. Include a description of your plans for performed, as appropriate.

ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for The necessary channel checks, functional tests and periodic the level measurement system and its supporting equipment. calibration will be implemented, tracked and the results addressed as defined by station processes and procedures.

Note - This information was previously requested as RAJ-12.a in the NRC letter dated June 17, 2013.

31 RAI -17 .b - Please provide a description of how the guidance 17.b- The guidance contained in NEI 12-02 Section 4.3 regarding in NEI 12-02 section 4.3 regarding compensatory actions for compensatory actions for one of both non-functioning channels will one or both non-functioning channels will be addressed. be addressed in accordance with station processes and procedures.

Note - This information was previously requested as RAJ-12.b in the NRC letter dated June 17, 2013.

Enclosure 2 to PLA -713 8 Page 16 of 20 PPL Susquehanna LLC's Response to Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 6, 2013 Item# NRC RAI and enhanced identifiers PPL Response 32 RAI-17.c- Please provide a description of what 17 .c- The requested information does not currently exist and is being compensatory actions are planned in the event that one of the developed as pmt of our design process. The information will be instrument channels cannot be restored to functional status provided as part of an upcoming required 6-month update to the within 90 days. Overall Integrated Plan, or as a separate transmittal, but is expected to be supplied no later than August 28, 2014.

Note - This information was previously requested as RAJ-12.c in the NRC letter dated June 17, 2013.

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