ML14245A400

Six-month Status Report in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-015)

ML14245A400
Person / Time
Site:	Millstone
Issue date:	08/26/2014
From:	Mark D. Sartain Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-390, EA-12-051
Download: ML14245A400 (21)

Text

Dominion Nuclear Connecticut, Inc. DomlniOn 5000 Dominion Boulevard, Glen Allen, VA 23060 --

Web Address: www.dom.coni 10 CFR 2.202 EA-12-051 August 26, 2014 Attention: Document Control Desk Serial No.: 14-390 U.S. Nuclear Regulatory Commission NL&OS/MAE: R1 Washington, D.C. 20555-0001 Docket Nos.: 50-336/423 License Nos.: DPR-65 NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNITS 2 AND 3 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)

References:

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

2. Dominion Nuclear Connecticut, Inc.'s Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (Serial No. 12-165B)

3. Dominion Nuclear Connecticut, Inc's 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 February 28, 2014 (Serial No. 12-165D)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Dominion Nuclear Connecticut, Inc. (DNC). Reference 1 was immediately effective and directed DNC to install reliable spent fuel pool level instrumentation.

Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2) pursuant to Section IV, Condition C. Reference 1 also required submission of a status report at six-month intervals following submittal of the OIP.

Attachments 1 and 2 of this letter provide the third six-month status report for Millstone Power Station Units 2 and 3, respectively, and an update of milestone accomplishments since the submittal of the second six-month status report (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Page 2 of 3 If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.

Sincerely, Mark D. Sartain Vice President Nuclear Engineering Dominion Nuclear Connecticut, Inc.

Attachments (2)

Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me thisd-7day of , 2014.

My Commission Expires: J 3iA 3 d_0*

(SAL PUKNotary Public (SEAL) c" "7tof

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 2100 Renaissance Blvd.

Suite 100 King of Prussia, PA 19406-2713 Mr. M. C. Thadani NRC Senior Project Manager Millstone Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment I Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Millstone Power Station Unit 2 Dominion Nuclear Connecticut, Inc. (DNC)

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 1 of 8 Six-Month Status Report for the Implementation of Order EA-12-051 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (OIP)

(Reference 1) documenting the requirements to install reliable Spent Fuel Pool (SFP)

Level Instrumentation in response to Order EA-12-051 (the Order) (Reference 2). This attachment provides an update of milestone accomplishments since submittal of the last status report for Millstone Power Station Unit 2 (MPS2) (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the MPS2 OIP for Order EA-12-051 and are current as of July 31, 2014.

1. Submit Overall Integrated Plan

2. Commence Engineering and Design 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the MPS2 OIP.

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.

Target ARevised Target Milestone Completion Status Completion Date Date Submit Overall Integrated Plan Feb 2013 Complete Commence Engineering and March 2013 Complete Design Complete Engineering and June 2014 In-Progress September 2014*

Design Complete Procurement of SFP June 2014 In-Progress August 2014**

Instruments

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 2 of 8 Target Revised Target Milestone Completion Status Activity Cmlto Completion Date Date Commence Installation of SFP August 2014 Not Started September 2014*

Instruments Level Measurement System October 2014 Not started December 2014*

Functional

• The revised milestone target completion dates for 'Complete Engineering and Design,'

'Commence Installation of SFP Instruments,' and 'Level Measurement System Functional' do not impact the Order implementation date for MPS2.

• • The components of the SFP Level Instrumentation system required for installation have been procured and delivered. However, as of the effective date of this status report (July 31, 2014),

the calibration kit has not been delivered to the site, but will be available by the revised target completion date.

4 Changes to Compliance Method There are no changes to DNC's compliance method with NEI 12-02 (Reference 4).

5 Need for Relief/Relaxation and Basis for the RelieflRelaxation DNC 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 Interim Staff Evaluation No open items were identified in the MPS2 OIP. However, the Requests for Additional Information (RAIs) identified in the Interim Staff Evaluation (Reference 5) are considered as Open Items. The following table provides a summary of these RAI Open Items from the Millstone Power Station Interim Staff Evaluation and the status of each item. Several of the RAIs in the following table have been addressed as part of the on-going NRC audit process for the Order regarding FLEX Mitigating Strategies, EA-12-049 (Reference 6). Per direction from the NRC Project Manager, this process has been applied to the Order regarding Spent Fuel Level Instrumentation, EA-12-051.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 3 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide a clearly labeled sketch or marked-up The response to this RAI plant drawing of the plan view of the SFP area, depicting has been addressed as part the SFP inside dimensions, the planned of the on-going NRC audit locations/placement of the primary and back-up SFP process for Order EA-1 2-level sensor, and the proposed routing of the cables that 051. In addition, this RAI will extend from these sensors toward the location of the was addressed during the read-out/display device. July 2014 NRC onsite audit.

Please provide the analyses used to verify the design The response to this RAI criteria and methodology for seismic testing of the SFP was provided in Attachment instrumentation and the electronics units, including, 3 to the February 28, 2014 2 design basis maximum seismic loads and the Six-Month Status Report hydrodynamic loads that could result from pool sloshing letter (Reference 3).

or other effects that could accompany such seismic forces.

For each of the mounting attachments required to attach The response to this RAI SFP Level equipment to plant structures, please has been addressed as part 3 describe the design inputs, and the methodology that of the on-going NRC audit was used to qualify the structural integrity of the affected process for Order EA-1 2-structures/equipment. 051.

Please provide analysis of the maximum expected The response to this RAI radiological conditions (dose rate and total integrated has been addressed as part dose) to which the equipment (including transmitters, of the on-going NRC audit control boxes, and display panels) will be exposed. Also, process for Order EA 4 please provide documentation indicating how it was 051.

determined that the electronics for the SFP level instrumentation is capable of withstanding a total integrated dose of 1X10 4 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 4 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide information indicating (a) what are the The response to this RAI temperature ratings and whether the temperature ratings has been addressed as part for the system electronics (including transmitters, control of the on-going NRC audit boxes, and display panels) are continuous duty ratings; process for Order EA 5 and, (b) what will be the maximum expected ambient 051.

temperature in the rooms in which the system electronics will be located under BDB conditions in which there are no AC power available to run Heating Ventilation and Air Conditioning (HVAC) systems?

Please provide information indicating the maximum The response to this RAI expected relative humidity in the rooms in which the has been addressed as part system electronics will be located under BDB conditions, of the on-going NRC audit 6 in which there are no AC power available to run HVAC process for Order EA systems, and whether the sensor electronics are 051.

capable of continuously performing its required functions under this expected humidity condition.

Please provide information describing the evaluation of The response to this RAI the comparative sensor design, the shock test method, was provided in Attachment test results, and forces applied to the sensor applicable 3 to the February 28, 2014 7 to its successful tests demonstrating that the referenced Six-Month Status Report previous testing provides an appropriate means to letter (Reference 3).

demonstrate reliability of the sensor under the effects of severe shock.

Please provide information describing the evaluation of The response to this RAI the comparative sensor design, the vibration test was provided in Attachment method, test results, and the forces and their frequency 3 to the February 28, 2014 8 ranges and directions applied to the sensor applicable to Six-Month Status Report its successful tests, demonstrating that the referenced letter (Reference 3).

previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 5 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide information describing the evaluation of The response to this RAI the comparative system electronics (including was provided in Attachment transmitters, control boxes, and display panels) ratings 3 to the February 28, 2014 9 against postulated plant conditions. Also provide results Six-Month Status Report of the manufacturer's shock and vibration test methods, letter (Reference 3).

test results, and the forces and their frequency ranges and directions applied to the system electronics and display panel associated with its successful tests.

The response to this RAI Please provide the following: was provided in Attachment 3 to the February 28, 2014 a) A description of the testing and/or analyses that will Six-Month Status Report be conducted to provide assurance that the equipment letter (Reference 3).

will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor 10 mounted in the SFP area, and (b) any control boxes, electronics, or read-out and retransmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

b) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment during and following seismic conditions to maintain its required accuracy.

For RAI #10 above, please provide the results for the The response to this RAI selected methods, tests and analyses used to was provided in Attachment 11 demonstrate the qualification and reliability of the 3 to the February 28, 2014 installed equipment in accordance with the Order Six-Month Status Report requirements. letter (Reference 3).

Please provide the NRC staff with the final configuration The response to this RAI of the power supply source for each channel so that the has been addressed as part staff may conclude that the two channels are of the on-going NRC audit independent from a power supply assignment process for Order EA-1 2-perspective. 051. In addition, this RAI was addressed during the July 2014 NRC onsite audit.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 6 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide the results of the calculation depicting The response to this RAI the battery backup duty cycle requirements was provided in Attachment 13 demonstrating that its capacity is sufficient to maintain 3 to the February 28, 2014 the level indication function until offsite resource Six-Month Status Report availability is reasonably assured. letter (Reference 3).

Provide the following:

The response to this RAI a) A description of the methodology that will be used for was provided in Attachment determining the maximum allowed deviation from the 3 to the February 28, 2014 instrument channel design accuracy that will be Six-Month Status Report employed under normal operating conditions as an letter (Reference 3).

acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires 14 adjustment to within the normal condition design accuracy.

b) Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BDB values. Please demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

a) The specific location for the primary and backup The response to this RAI instrument channel display. has been addressed as part of the on-going NRC audit b) For any SFP level instrumentation displays located process for Order EA outside the MCR, please describe the evaluation used to 051.

validate that the display location can be accessed without unreasonable delay following a BDB event.

Include the time available for personnel to access the 15 display as credited in the evaluation, as well as the actual time (e.g., based on walk-through) that it will take for personnel to access the display. Additionally, please include a description 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 BDB event.

Describe whether personnel are continuously stationed at the display or monitor the display periodically.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 7 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide a list of the procedures addressing The response to this RAI operation (both normal and abnormal response), has been addressed as part calibration, test, maintenance, and inspection of the on-going NRC audit 16 procedures that will be developed for use of the spent process for Order EA-1 2-SFP instrumentation. The licensee is requested to 051.

include a brief description of the specific technical objectives to be achieved within each procedure.

Please provide the following: The response to this RAI has been addressed as part a) Further information describing the maintenance and of the on-going NRC audit testing program the licensee will establish and process for Order EA implement to ensure that regular testing and calibration 051.

is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Please include a description of the plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance 17 will be conducted for the level measurement system and its supporting equipment.

b) Information describing compensatory actions when both channels are out-of-order, and the implementation procedures.

c) Additional information describing expedited and compensatory actions in the maintenance procedure to address when one of the instrument channels cannot be restored to functional status within 90 days.

7 Potential Interim Staff Evaluation (ISE) Impacts In the second Six Month Status Report letter (Reference 3), DNC reported a change in the SFP Level Instrumentation vendor and reported conclusions of a comparison between the Westinghouse SFP Level Instrumentation design and the details that were previously provided to the staff and included in the ISE (Reference 5).

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 1 Page 8 of 8 8 References The following references support the update to the MPS2 SFP Level Instrumentation OIP described in this attachment:

1. "Dominion Nuclear Connecticut, Inc's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying 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. "Dominion Nuclear Connecticut, Inc's 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 February 28, 2014 (Serial No. 12-165D).

4. NEI 12-02 (Revision 1), Industry Guidance for Compliance with NRC Order EA 051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 2012.

5. "Millstone Power Station, Units 2 and 3: Interim Staff Evaluation and Request for Additional Information Regarding to Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," dated October 29, 2013.

6. NRC Letter, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049," dated August 28, 2013.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Millstone Power Station Unit 3 Dominion Nuclear Connecticut, Inc. (DNC)

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 1 of 8 Six-Month Status Report for the Implementation of Order EA-1 2-051 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (OIP)

(Reference 1) documenting the requirements to install reliable Spent Fuel Pool (SFP)

Level Instrumentation in response to Order EA-12-051 (the Order) (Reference 2). This attachment provides an update of milestone accomplishments since submittal of the last status report for Millstone Power Station Unit 3 (MPS3) (Reference 3), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the MPS3 OIP for Order EA-12-051 and are current as of July 31, 2014.

1. Submit Overall Integrated Plan

2. Commence Engineering and Design

3. Complete Engineering and Design

4. Commence Installation of SFP Instruments 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the MPS3 OIP.

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 Overall Integrated Plan Feb 2013 Complete Commence Engineering and Design March 2013 Complete Complete Engineering and Design June 2014 Complete Complete Procurement of SFP June 2014 In-Progress August 2014*

Instruments Commence Installation of SFP Instruments June 2014 Complete Level Measurement System Functional September Started 2014

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 2 of 8

• The components of the SFP Level Instrumentation system required for installation have been procured. However, as of the effective date of this status report (July 31, 2014), the calibration kit has not been delivered to the site, but will be available by the revised target completion date.

4 Changes to Compliance Method There are no changes to DNC's compliance method with NEI 12-02 (Reference 4).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DNC 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 Interim Staff Evaluation No open items were identified in the MPS3 OIP. However, the Requests for Additional Information (RAIs) identified in the Interim Staff Evaluation (Reference 4) are considered as Open Items. The following table provides a summary of these RAI Open Items from the Millstone Power Station Interim Staff Evaluation and the status of each item. Several of the RAIs in the following table have been addressed as part of the on-going NRC audit process for the Order regarding FLEX Mitigating Strategies, EA-12-049 (Reference 6). Per direction from the NRC Project Manager, this process has been applied to the Order regarding Spent Fuel Level Instrumentation, EA-1 2-051.

Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide a clearly labeled sketch or marked-up The response to this RAI plant drawing of the plan view of the SFP area, depicting has been addressed as part the SFP inside dimensions, the planned of the on-going NRC audit 1 locations/placement of the primary and back-up SFP process for Order EA-1 2-level sensor, and the proposed routing of the cables that 051. In addition, this RAI will extend from these sensors toward the location of the was addressed during the read-out/display device. July 2014 NRC onsite audit.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 3 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide the analyses used to verify the design The response to this RAI criteria and methodology for seismic testing of the SFP was provided in Attachment instrumentation and the electronics units, including, 3 to the February 28, 2014 2 design basis maximum seismic loads and the Six-Month Status Report hydrodynamic loads that could result from pool sloshing letter (Reference 3).

or other effects that could accompany such seismic forces.

For each of the mounting attachments required to attach The response to this RAI SFP Level equipment to plant structures, please has been addressed as part 3 describe the design inputs, and the methodology that of the on-going audit was used to qualify the structural integrity of the affected process.

structures/equipment.

Please provide analysis of the maximum expected The response to this RAI radiological conditions (dose rate and total integrated has been addressed as part dose) to which the equipment (including transmitters, of the on-going audit control boxes, and display panels) will be exposed. Also, process.

4 please provide documentation indicating how it was determined that the electronics for the SFP level instrumentation is capable of withstanding a total integrated dose of 1X10 4 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

Please provide information indicating (a) what are the The response to this RAI temperature ratings and whether the temperature ratings has been addressed as part for the system electronics (including transmitters, control of the on-going audit boxes, and display panels) are continuous duty ratings; process.

5 and, (b) what will be the maximum expected ambient temperature in the rooms in which the system electronics will be located under BDB conditions in which there are no AC power available to run Heating Ventilation and Air Conditioning (HVAC) systems?

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 4 of 8 Interim Staff Evaluation Ooen Items (RAIs&

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(\ .... A RAI # Description Status Please provide information indicating the maximum The response to this RAI expected relative humidity in the rooms in which the has been addressed as part system electronics will be located under BDB conditions, of the on-going audit 6 in which there are no AC power available to run HVAC process.

systems, and whether the sensor electronics are capable of continuously performing its required functions under this expected humidity condition.

Please provide information describing the evaluation of The response to this RAI the comparative sensor design, the shock test method, was provided in Attachment test results, and forces applied to the sensor applicable 3 to the February 28, 2014 7 to its successful tests demonstrating that the referenced Six-Month Status Report previous testing provides an appropriate means to letter (Reference 3).

demonstrate reliability of the sensor under the effects of severe shock.

Please provide information describing the evaluation of The response to this RAI the comparative sensor design, the vibration test was provided in Attachment method, test results, and the forces and their frequency 3 to the February 28, 2014 8 ranges and directions applied to the sensor applicable to Six-Month Status Report its successful tests, demonstrating that the referenced letter (Reference 3).

previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

Please provide information describing the evaluation of The response to this RAI the comparative system electronics (including was provided in Attachment transmitters, control boxes, and display panels) ratings 3 to the February 28, 2014 9 against postulated plant conditions. Also provide results Six-Month Status Report of the manufacturer's shock and vibration test methods, letter (Reference 3).

test results, and the forces and their frequency ranges and directions applied to the system electronics and display panel associated with its successful tests.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 5 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide the following: The response to this RAI was provided in Attachment a) A description of the testing and/or analyses that will 3 to the February 28, 2014 be conducted to provide assurance that the equipment Six-Month Status Report will perform reliably under the worst-case credible design letter (Reference 3).

basis loading at the 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 retransmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

b) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment during and following seismic conditions to maintain its required accuracy.

For RAI #10 above, please provide the results for the The response to this RAI selected methods, tests and analyses used to was provided in Attachment 11 demonstrate the qualification and reliability of the 3 to the February 28, 2014 installed equipment in accordance with the Order Six-Month Status Report requirements. letter (Reference 3).

Please provide the NRC staff with the final configuration The response to this RAI of the power supply source for each channel so that the has been addressed as part staff may conclude that the two channels are of the on-going NRC audit independent from a power supply assignment process for Order EA perspective. 051. In addition, this RAI was addressed during the July 2014 NRC onsite audit.

Please provide the results of the calculation depicting The response to this RAI the battery backup duty cycle requirements was provided in Attachment 13 demonstrating that its capacity is sufficient to maintain 3 to the February 28, 2014 the level indication function until offsite resource Six-Month Status Report availability is reasonably assured. letter (Reference 3).

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 6 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Provide the following: The response to this RAI was provided in Attachment a) A description of the methodology that will be used for 3 to the February 28, 2014 determining the maximum allowed deviation from the Six-Month Status Report instrument channel design accuracy that will be letter (Reference 3).

employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires 14 adjustment to within the normal condition design accuracy.

b) Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BDB values. Please demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

a) The specific location for the primary and backup The response to this RAI instrument channel display. has been addressed as part of the on-going audit b) For any SFP level instrumentation displays located process.

outside the MCR, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BDB event.

Include the time available for personnel to access the 15 display as credited in the evaluation, as well as the actual time (e.g., based on walk-through) that itwill take for personnel to access the display. Additionally, please include a description 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 BDB event.

Describe whether personnel are continuously stationed at the display or monitor the display periodically.

Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 7 of 8 Interim Staff Evaluation Open Items (RAIs)

RAI # Description Status Please provide a list of the procedures addressing The response to this RAI operation (both normal and abnormal response), has been addressed as part calibration, test, maintenance, and inspection of the on-going audit 16 procedures that will be developed for use of the spent process.

SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

Please provide the following: The response to this RAI has been addressed as part a) Further information describing the maintenance and of the on-going audit testing program the licensee will establish and process.

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. Please include a description of the plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance 17 will be conducted for the level measurement system and its supporting equipment.

b) Information describing compensatory actions when both channels are out-of-order, and the implementation procedures.

c) Additional information describing expedited and compensatory actions in the maintenance procedure to address when one of the instrument channels cannot be restored to functional status within 90 days.

7 Potential Interim Staff Evaluation Impacts In the second Six Month Status Report letter (Reference 3), DNC reported a change in the SFP Level Instrumentation vendor and reported conclusions of a comparison between the Westinghouse SFP Level Instrumentation design and the details that were previously provided to the staff and included in the ISE (Reference 5).

j Serial No.14-390 Docket Nos. 50-336/423 Order EA-12-051 Attachment 2 Page 8 of 8 8 References The following references support the update to the MPS3 GIP described in this attachment.

1. "Dominion Nuclear Connecticut, Inc's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying 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. "Dominion Nuclear Connecticut, Inc's 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 February 28, 2014 (Serial No. 12-165D).

4. NEI 12-02 (Revision 1), Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated August 2012.

5. Millstone Power Station, Units 2 and 3: "NRC Interim Staff Evaluation and Request for Additional Information Regarding to Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation,"

dated October 29, 2013.

6. NRC Letter, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049," dated August 28, 2013.