PNP 2014-084, 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)

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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)
ML14240A278
Person / Time
Site: Palisades Entergy icon.png
Issue date: 08/28/2014
From: Vitale A
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, PNP 2014-084
Download: ML14240A278 (16)
v • d • e


Text

{{#Wiki_filter:.- ~ Entergy s-i Lt1çJ Entergy Entergy Nuclear Palisades 27780 27780 Blue Covert, Nuclear Operations, Palisades Nuclear Blue Star Covert, MI Operations, Inc. Nuclear Plant Plant Star Memorial Inc. Memorial Highway MI 49043-9530 49043-9530 Highway Tel Tel 269 269 764 764 2000 2000 Anthony J. Anthony J. Vitale Vitale PNP PN 2014-084 P 2014-084 Site Site Vice Vice President President August 28, 2014 August28,2014 u.s. U.S. Nuclear Regulatory Regulatory Commission Document Control Desk ATTN: Document 11555 Rockville 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Palisades Nuclear Plant 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) Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20

REFERENCES:

EA-1 2-051, Order To Modify Licenses With

1. NRC Order Number EA-12-051, Regard To Reliable Spent Fuel Pool Instrumentation, dated March 12, 12, 2012 (ADAMS Accession No. ML ML12054A682) 12054A682)
2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, EA-12-0S1, Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339) 29,2012 ML12221A339)
3. NEI 12-02, Industry Guidance for Compliance with NRC Order NEI12-02, EA- 12-05 1, ITo EA-12-0S1, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Instrumentation," Revision 1, 1, dated August 2012 (ADAMS Accession No. ML ML12240A307) 12240A307)
4. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-092, Initial Status Report in Response to March 12, 12, 2012 Commission Order Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

EA-12-0S1), dated dated October October 25, 2012 25,2012 (ADAMS (ADAMS Accession No. ML12300A067) Accession No. ML12300A067) 5.

5. Entergy Entergy Nuclear Nuclear Operations, Inc.Inc. letter to NRC, letter to NRC, PNP PNP 2013-009, 2013-009, Overall Integrated Plan in Response to March 12, 2012 Commission Order 12,2012 Order Modifying Modifying License With Regard to Reliable Spent Fuel Pool Instrumentation (Order (Order Number Number EA- 12-05 1), dated EA-12-0S1), dated February February 28, 2013 28,2013 (ADAMS Accession No. ML1 Accession No. 3060A360)

ML13060A360) 6.

6. Entergy Nuclear Operations, Entergy Nuclear Operations, Inc.

Inc. letter letter to to NRC, NRC, PNP PNP 2013-065, 2013-065, Palisades Palisades Nuclear Nuclear Plant Plant First First Six-Month Six-Month Status Status Report Report inin Response Response to to March 12, 2012 March 12, 2012 Commission Commission OrderOrder Modifying Modifying Licenses with Regard Licenses with Regard to to Reliable Spent Fuel Reliable Spent Fuel Pool Pool Instrumentation (Order (Order Number Number EA-12-051), EA-12-0S1), dated dated August August 28, 2013 (ADAMS 28,2013 (ADAMS Accession Accession No. No. ML1 3241 A235) ML13241A235)

PNP PN 2014-084 P 2014-084 Page 2 of 3

7. NRC Interim NRC Interim Staff Evaluation, Evaluation, Palisades-Interim Palisades-Interim Staff Evaluation Evaluation and Information Regarding Request for Additional Information Regarding the Overall Integrated Integrated Implementation of Order EA-12-051, Reliable Spent Fuel Pool Plan for Implementation Instrumentation (TAC No. MF0769), dated November 26,2013 26, 2013 (ADAMS Accession No. ML ML113312A423) 331 2A423)
8. 201 4-010, Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-010, Pailsades Palisades Nuclear Plant Second Six-Month Status Report in Response 12, 2012 Commission Order Modifying Licenses with Regard to March 12,2012 to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-EA 28, 2014 (ADAMS Accession No. ML 051), dated February 28,2014 ML14059A078) 14059A078)

Dear Sir or Madam:

12, 2012, the Nuclear Regulatory Commission (NRC) issued an order On March 12,2012, (Reference 1) to Entergy Nuclear Operations, Inc. (ENO). This order was immediately effective and directed ENO to install reliable spent fuel pool level instrumentation at the Palisades Nuclear Plant (PNP). Reference 1 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 11 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. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 1 (Reference 3) with clarifications and exceptions identified in Reference

2. Reference 4 provided the PNP initial status report regarding mitigation strategies.

Reference 5 provided the PNP overall integrated plan. Reference 6 provided the first six-month status report. Reference 7 contains a request for additional information regarding the overall integrated plan for implementation of Order EA-12-051. Reference 8 provided the second six-month status report. The purpose of this letter is to provide the third 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. 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. This letter also provides information in response to the request for additional information in Reference 7. This letter contains no new commitments and no revised commitments. II declare under penalty of perjury that the foregoing is true and correct; executed on August 28, 2014. Sincerely, ajv/jse

PNP PN P 2014-084 Page 3 of 3

Attachment:

Palisades Nuclear Plant Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent 12,2012 EA-12-051) Fuel Pool Instrumentation (Order Number EA-12-0S1) cc: Office Director, NRR, USNRC Ill, USNRC Administrator, Region III, Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC

Attachment Palisades Nuclear Plant 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-12-0S1)EA-12-051) 11 Introduction Entergy Nuclear Operations, Inc. (ENO) developed for Palisades Nuclear Plant (PNP) an overall integrated plan (Reference 11 in Section 8), documenting the requirements to install reliable spent fuel pool level instrumentation (SFPI), in response to Reference 2 in Section 8. 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 Milestone Accomplishments The following milestone(s) have been completed since January 31,201431, 2014 and are current as of July July31, 2014. 31,2014.

  • Second Six-Month Status Report - February 2014
  • Third Six-Month Status Report - Complete with submission of this document in August 2014.

3 Milestone Schedule Status The following provides a line item update to milestone schedule to support the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. Revised Target Target Completion Activity Milestone Completion Datet Datet Status Date SFPI Installed Reliable SFPllnstalied FaIl 2015 Refueling Fall In Progress N/A Outage Response to NRC Request for Additional Information August 19, 19, 2013 Submitted N/A N/A (received July 18,18, 2013) August 19, 19, (Reference 33 in Section 8) 2013 Response to NRC ISE ISE Request for Additional March 31, 2015 31,2015 In Progress Progress N/A N/A Information Information (received November November 26, 26, 2013) 2013) 11 of 13 13

tTarget Completion Date is the last submitted date from either the overall integrated plan or tTarget previous six-month update. 4 Changes to Compliance Method 1 of the Overall Integrated Plan (Reference 11 in Section 8) shows Channel A mounted against the north wall near the northwest corner of the Spent Fuel Pool (SFP). The location of Channel A has been moved to the west wall near the northwest corner of the SFP. SEP. See Section 7 for additional discussion. Section 7 also contains a figure with the new cable SEP area. routing for the SFP SEP area shall be The Overall Integrated Plan states in Section 6 that SFPI cables in the SFP routed in seismically mounted rigid metal conduit. This is true for the coaxial cable, but does 22 stainless steel armored cable. See Section 7 for additional discussion. Si0 not apply to the Si0 of the Overall Integrated Plan shows SFPI Channel A being powered by MCC-7 SEPI Channel A will now be powered by MCC-1 via Lighting Panel via Lighting Panel EL-25. SFPI EL-25B. 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation END expects to comply with the order implementation date and no relief/relaxation is required ENO at this time. 6 Open Items from Overall Integrated Plan and Interim Staff Evaluation END has received an Interim Staff Evaluation for PNP that includes 18 ENO 18 Requests for Additional Information (RAls). (RAIs). Responses to the RAls RAIs are due by March 31,2015 31, 2015 and are discussed in Section 9 of this six-month status report. The following table provides a status RAIs documented in the Interim Staff Evaluation. of any RAls RAI # Response Status 1 1 See Section 9 2 See Section 9 3 See Section 9 4 See Section 9 55 See Section 9 66 See Section 9 7 See Section 9 88 See Section 9 9 See Section 9 10 10 See Section 9 1111 See See Section 9 12 12 See Section 99 13 13 See Section 99 2 of of 13 13

14 14 Section 99 See Section See 15 15 Section 99 See Section See 16 16 Section 99 See Section See 17 17 See Section 99 See Section 18 18 See Section See Section 99 7 Potential Interim Staff Evaluation Impacts Section 3.4 of the IInterim Section nterim Staff Evaluation discusses the arrangement of the SFPI channels and references the sketch in in Attachment 11 of the Overall Integrated Plan. As discussed in instrument has been moved to the west SFP Section 4, the location of the Channel A level instrument 12 of the northwest SFP wall, within 12" SEP corner. Section 3.4 of the Interim Staff Evaluation also refers to a statement that declares cables in the SFP area will be routed in seismically mounted rigid metal conduit. It should be noted that this statement does not apply to the first 20 feet of cable run, which is comprised of Si0 22 Si0 stainless steel armored cable, routed in seismically mounted 12 gauge unistrut channel with a 22 stainless steel armored cable then transitions to coaxial cable, at S1O closure strip. The Si0 which point the coaxial cable will be installed in seismically mounted rigid metal conduit for the remainder of the run in the SFPSEP area. This cable installation is applicable to both Channel A and Channel B. An updated sketch of the SFPI arrangement showing the current Channel A and Channel B B cable routings is provided below in Figure 1. There are no additional potential impacts to the Interim Staff Evaluation identified at this time except for those identified in Section 6 of this report. 33 of of 13 13

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References 88 References The following The following references references support support the the updates updates to to the the overall overall integrated integrated plan described in plan described in this this attachment. attachment.

1. ENO letter
1. ENO letter to to NRC, NRC, PNP PNP 2013-009, 2013-009, Overall Overall Integrated Integrated Plan in Response Plan in Response to March 12, to March 12, 2012 Commission 2012 Commission Order Order Modifying Modifying License License WithWith Regard Regard to Reliable Spent to Reliable Fuel Pool Spent Fuel Pool Instrumentation (Order (Order Number Number EA-12-051),

EA-12-051), dated February February 28,2013 28, 2013 (ADAMS (ADAMS Accession No. No. ML ML113060A360) 3060A360) NRC Order

2. NRC Order Number Number EA-12-051, EA-1 2-051, Order Order ToTo Modify Modify Licenses Licenses With With Regard Regard To To Reliable Reliable Spent Fuel Fuel Pool Instrumentation, Instrumentation, dated March 12,2012 12, 2012 (ADAMS Accession No.

2054A682) ML112054A682) ML NRC email to ENO,

3. NRC ENO, Palisades Nuclear Plant - Requests for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (TAC MFO 769), dated July 18, 2013 (ADAMS Accession No. ML MF0769), ML13200A328) 13200A328)
4. NRC letter to ENO, Palisades -Interim 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 (TAG NO. MF0769),

MFO 769), dated 26, 2013 (ADAMS Accession No. ML November 26,2013 ML13312A423) 13312A423)

5. Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation, dated December 26, (ML1133478030) 2013 (ML 3347B030) 55 of of 13 13

9 Responses to the Interim Staff Evaluation Requests for Additional Information (RAls) (RAIs) RAI #1 RAI#1 Given the potential for varied dose rates from other materials stored in the SFP, please describe how level 2 will be adjusted to other than the elevation provided in section 22 above. ENO Response: Compliance with Order EA-12-051, Reliable Spent Interim Staff Guidance JLD-ISG-2012-03, "Compliance Instrumentation, states The Fuel Pool Instrumentation," The NRC staff considers that the methodologies and guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, subject to the clarifications and exceptions in Attachment 11 to this ISG, are an acceptable means of EA-12-051. meeting the requirements of Order EA-12-051." NEI 12-02, Revision 1, Section 2.3.2, states "LevelLevel 2 - level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck." deck. Level 2 represents the range of water level where any necessary operations in the vicinity of the spent fuel pool can be completed without significant dose consequences from direct gamma radiation from the stored spent fuel. Level 2 is based on either of the following: 

            *           (+1- 11 foot) above the highest point of any fuel rack seated in the spent 10 feet (+/-

fuel pools, or

  • a designated level that provides adequate radiation shielding to maintain personnel radiological dose levels within acceptable limits while performing local operations in the vicinity of the pool. This level shall be based on either plant-specific or appropriate generic shielding calculations, considering the emergency conditions that may apply at the time and the scope of necessary local operations, including installation of portable SFP instrument channel components. Additional guidance can be found in EPA-400 (Reference 4),

USNRC Regulatory Guide 1.13 1.13 (Reference 5), and ANSI/ANS-57.2-1983 (Reference 6). ENO has selected the 10-foot option, which has been determined by the NRC to meet the requirements of the order with no further evaluation or review required. RAI#2 Please provide the analyses verifying the seismic capability of the level probes, the mounting brackets, and the electronics units, and provide the results of the analysis of the combined maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly exposed to the potential sloshing effects. Show that the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure. 66 of 13 13

Response

ENO Response: ENO See draft bridging See draft bridging document document Topics Topics #8,9, 

                                             #8, 9, && 12 12 located located on on ePortal.

ePortal. [Note: [Note: Preliminary Preliminary responses are available responses are available in the in the draft bridging document, draft bridging document, which which will will be be finalized finalized upon issuance upon issuance of the of the NRC NRC audit audit report report for for the SFPI vendor the SFPI vendor (MOHR).] (MOHR).] RAI #3 RAI#3 For each For each of the the mounting mounting attachments required required to attach attach SFP SFP Level equipment equipment to plant structures, please describe the design inputs, and structures, and the the methodology methodology that will be used to qualify the structural integrity of qualify of the the affected structures/equipment. ENO Response: ENO Response: See draft bridging document Topics #8, 9, 12, & 13 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] (MOHR).J RAI #4 RAI#4 Please address how other hardware stored in the SFP will not create adverse interaction with the fixed instrument location(s). ENO Response: The SFP and Auxiliary Building are Seismic Category 1 1 Structures. As a part of the Engineering Change (EC) process for PNP, SFPI probe locations were verified to be free of stored SFP SEP hardware. Future hardware additions to the SFP SEP are controlled by procedure. RAI#5 Please provide analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the sensor electronics will be exposed. Also, please provide documentation indicating the radiological dosage the electronics for this equipment are capable of withstanding. Please discuss the time period over which the analyzed total integrated dose is evaluated to be applied. ENO Response:

Response

The The Channel Channel A display containing the system electronics will the system will be be mounted mounted in in the Main Main Control Control Room, a mild Room, a mild radiation environment. The Channel The Channel BB display display is is located inin the the C-40 C-40 Panel

Room, Room, which which isis aa mild mild radiation area.

area. Both Both the Main Main Control Control Room Room andand C-40 C-40 Panel Panel Room Room are not affected are not affected by by increased increased radiation radiation levels levels due due to receding SEPSFP water water level. level. No No analysis analysis is is necessary necessary to to evaluate evaluate the the system system electronics electronics for for exposure exposure toto radiation. radiation. 77 of of 13 13

RAI#6 RAI#6 Please provide Please provide information information indicating indicating the the maximum maximum expected expected ambient ambient temperature temperature in in the the room in room which the in which the sensor sensor electronics electronics will will be located under be located under BOB BDB conditions conditions with with no no ac power ac power available to available to run Heating Ventilation run Heating Ventilation and and Air Conditioning Conditioning (HVAC) (HVAC) systems, systems, and and whether whether the the sensor electronics sensor electronics are are capable capable of continuously continuously performing performing required required functions functions under under this this expected temperature expected temperature condition. condition. ENO Response: ENO Response: See draft bridging See bridging document Topic #3 located on ePortal. [Note: Preliminary responses are available inin the draft bridging bridging document, which will be finalized upon upon issuance of the NRCNRC audit report for the SFPI vendor (MOHR).] RAI #7 RAI#7 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BOB BDB conditions, with no ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition. ENO Response: See draft bridging document Topic #3 in located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC (MOHR).J audit report for the SFPI vendor (MOHR).] RAI #8 RAI#S Please provide a description of the specific method or combination of methods that will be used to demonstrate the reliability of the permanently installed equipment under BOB BDB shock and vibration conditions. Identify the specific commercial and/or military standards that will be used to establish the testing requirements, and the specific acceleration levels and frequencies that will be simulated. ENO Response: See draft bridging bridging document document Topic #14 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, document, which will be finalized uponupon issuance issuance of of the NRC audit report audit report for the SFPI vendor the SFPI vendor (MOHR).] 88 of of 13 13

RAI#9 RAI#9 For RAI #8 For RAI #8 above, above, please provide the please provide the results results for for the the selected selected methods, methods, tests tests and and analyses analyses used to demonstrate used to demonstrate the the qualification qualification and rellabillty of and reliability the installed of the installed equipment equipment in in accordance accordance with the with the Order Order requirements. requirements.

Response

ENO Response: ENO draft bridging document See draft document Topic Topic #14 located located onon ePortal. [Note: [Note: Preliminary Preliminary responses responses are available in the available the draft bridging bridging document, document, which will will be be finalized upon issuance issuance of the NRC NRC report for the SFPI vendor (MOHR).] audit report (MOHR).J RAI#1O RAI #10 Please provide an evaluation of the vendor analysis and seismic testing results and show that rellabillty, following exposure to simulated seismic conditions the instrument performance reliability, representative of the environment anticipated for the SFP structures at Palisades, has been adequately demonstrated. ENO Response: See draft bridging document Topic #8 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] RAI#11 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective. ENO Response: Instrument Channel A is being powered from Lighting Panel (L-25B) through existing 20A breaker #5, which is supplied from MCC #1. Instrument Channel B B is being powered from Lighting Lighting Panel Panel (L-76) through existing 20A 20A breaker #12, #12, which isis supplied from MCCMCC #82. These two buses represent independent independent 480 V power sources. RAI#12 RAI#12 Please provide provide the results of of the calculation depicting the batterybattery backup duty cycle requirements demonstrating batterybattery capacity is sufficient to maintain maintain the level indication indication function until until offsite offsite resource availability availability is reasonably assured. 99 of of 13 13

ENO Response: ENO Response: See draft See draft bridging document Topic bridging document #18 located Topic #18 located on ePortal. [Note: on ePortal. [Note: Preliminary Preliminary responses responses areare available in available in the the draft draft bridging bridging document, document, which which will will be finalized upon be finalized upon issuance issuance ofof the the NRC NRC audit report for audit report for the the SFPI SFPI vendor vendor (MOHR).] (MOHR).} RAI#13 RAI#13 Please, provide an analysisanalysis verifying verifying the proposed instrument performance is is consistent with with these estimated these estimated accuracy normal and BOB 8DB values. values. Please demonstrate the the channels channels will will these accuracy performance values following retain these following a loss of power and subsequent restoration of power. ENO Response: See draft bridging document Topics #16, 17 & 18 located on ePortal. [Note: Preliminary Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] RAI#14 Please provide a description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy to be employed under normal operating conditions as an acceptance criterion for a calibration callbration procedure to alert operators and technicians of the need for adjustment to within normal design accuracy. ENO Response: In general relative to normal operating conditions, any applicable calibration procedure tolerances (or acceptance criterion) will be established based on the vendor manuals stated/recommended reference accuracy (or design accuracy). The methodology used will be based on the vendor manuals and captured in plant procedures and/or programs. See draft bridging document document Topics #20 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report for the SFPI SFPI vendor (MOHR).] RAI#15 Please provide a description description of the in-situ calibration calibration process at at the SFP location thatthat will result in the channel calibration being maintained at its design accuracy. accuracy. ENO Response:

Response

The The process process willwill be be captured captured in in ENO ENO procedures procedures established established based based onon manufacturers manufacturer's recommendations and and ENO ENO process process and and procedures. procedures. The The instrument instrument automatically automatically monitors monitors the the integrity integrity of its level of its level measurement measurement system system using in-situ capability. using in-situ capability. Deviation Deviation ofof measured measured test test parameters parameters from from manufactured manufactured oror as-installed as-installed configuration configuration beyond beyond aa configurable configurable threshold prompts operator intervention. threshold prompts operator intervention. 10 10 of of 13 13

See draft See draft bridging bridging document document Topic #20 located Topic #20 located on on ePortal. ePortal. [Note: [Note: Preliminary Preliminary responses responses are are available in available in the the draft draft bridging bridging document, document, which which will will be finalized upon be finalized upon issuance issuance of of the the NRC NRC audit report audit report for for the the SFPI vendor (MOHR).] SFPI vendor (MOHR).] RAI#16 RAI#16 For the For SFP level the SFP level instrumentation instrumentation backup backup display display located located in in the the radwaste radwaste control control panel room, room, please please describe the the evaluation used to vaildate used to validate the display location can be the display be accessed accessed without without unreasonable delay following a BOB unreasonable BDB event. Include Include the time available the time available for personnel toto access the the display as credited credited in the evaluation, as well as the actual time (e.g., (e.g., based on on walk-throughs) that it will will take take for for personnel toto access the backup display. display. Additionally, please include a description of of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB BDB event. Describe whether personnel are continuously stationed at the backup display or monitor the display periodically. ENO Response: The backup display will be mounted in the Radwaste Control Panel Room Cabinet C104 Cl 04 at 590 elevation of the Aux. Building. This cabinet is located in Room 121, and can be the 590' accessed via Stairwell No. 16 and Door 75, or via Corridor 106A 1 06A through Door 190. Both Stairwell 16 and Corridor 106A can be approached from the north, east, and west via Corridor 106. The back-up channel display can be considered promptly accessible, because it can be reached within the 30 minute deployment requirement that exists for portable instrumentation (Section 3.1 of NEI 12-02). The impact to habitability would be primarily from elevated temperatures, as the C-40 panel room is considered a mild radiation environment. Habitability will be assured by heat stress countermeasures and rotation of personnel to the extent feasible. Personnel will not be continuously stationed at the backup display, it will be monitored periodically. The site FLEX Support Guidelines will provide guidance for personnel to evaluate the room temperature and take actions as necessary. In addition, site procedures already use passive cooling technologies for response personnel. The FLEX staffing plan has not been finalized at this time. The results of the staffing plan will be included in a future six month status report. IfIf necessary, portable portable radios willwill be used to communicate with decision makers. 11 of 11 of 13 13

RAI#17 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 SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure. ENO Response: The calibration and test procedures developed by MOHR are provided in the technical manuals developed by MOHR. See bridging document Topics #10,19, #10, 19, & 20 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report for the SFPI vendor (MOHR).] The objectives are to measure system performance, determine if there is a deviation from normal tolerances, and return the system to normal tolerances. Diagnostic procedures developed by MOHR are provided as automated and semi-automated routines in system software alerting the operator to abnormal deviation in selected system parameters such as battery voltage, 4-20 mA loop continuity, and TDR waveform of the transmission cable. The technical objective of the diagnostic procedures is to identify system conditions that require operator attention to ensure continued reliable liquid level measurement. Manual diagnostic procedures are also provided in the event that further workup is determined to be necessary. Maintenance procedures developed by MOHR are provided in the technical manual. These EFP-lL system maintenance to ensure that system functionality allow a technician trained in EFP-IL is maintained. An operation procedure will provide sufficient instructions for operation and use of the system. ENO procedures will be developed in accordance with the vendor manuals provided by MOHR and ENO procedures and processes. MQHR FLEX Support Guidelines will provide sufficient instructions for use of the SFPI during a beyond design basis external event. 12 12 of of 13 13

RAI#18 RAI #18 Please provide 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 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. ENO Response: SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness will be established in accordance with ENO processes and procedures and in consideration of vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance are performed (and available for inspection and audit). See draft bridging document Topics #10 and #20 located on ePortal. [Note: Preliminary responses are available in the draft bridging document, which will be finalized upon issuance of the NRC audit report (MOHR).J for the SFPI vendor (MOHR).] 13 13 of 13 13}}

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