Text

NextEra Energy Point Beach, Llc'S Full Compliance Report for the March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
	ML14353A047
Person / Time
Site:	Point Beach
Issue date:	12/19/2014
From:	Mccartney E; Point Beach
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-051, NRC 2014-0077
	Download: ML14353A047 (28)
	v • d • e

NEXTeraM ENERGY~

.~

December 19, 2014 NRC 2014-0077 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant, Units 1 and 2 Docket 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energy Point Beach. LLC's Full Compliance Report for the March 12. 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

(1) U.S. Nuclear Regulatory Commission, Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately)," dated March 12, 2012 [ML12056A044]

(2} U.S. Nuclear Regulatory Commission, Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 [ML12221A339]

(3} NEI12-02, 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 [ML12240A307]

(4) NextEra Energy Point Beach, LLC's 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 26, 2012 [ML12305A200]

(5) NextEra Energy Point Beach, LLC's 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 22, 2013 [ML13053A399]

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Point Beach, LLC (Point Beach). Reference (1) was immediately effective and directed NextEra to install reliable spent fuel pool level instrumentation.

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 the Point Beach initial status report regarding mitigation strategies. Reference (5) provided the Point Beach Overall Integrated Plan.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 Reference (1) requires submission of a report to the Commission when full compliance with requirements described in Attachment 2 or Attachment 3 of Reference (1) is achieved. The purpose of this letter is to provide the full compliance report to the Commission pursuant to Section IV, Condition C.3, of Reference (1). The Enclosure to this letter provides the full compliance report.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Mike Millen, Licensing Manager, at 920/755-7845.

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

Executed on December 19, 2014.

Very truly yours, NextEra Energy Point Beach, LLC

b-=-~~

Eric McCartney Site Vice President Enclosure cc: Director, Office of Nuclear Reactor Regulation Administrator, Region Ill, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Ms. Lisa M. Regner, NRR/JLD/PMB, USNRC Mr. Blake A. Purnell, NRRIJLD/PMB, USNRC Mr. Steven R. Jones, NRRIDSS/SBPB, USNRC

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT FULLCOMPUANCEREPORTFORTHE MARCH 12,2012 COMMISSION ORDER TO MODIFY UCENSES WITH REGARD TO REUABLE SPENT FUEL POOL INSTRUMENTATION (ORDER NUMBER EA-12-051)

INTRODUCTION NextEra Energy Point Beach, LLC (Point Beach) has installed two independent full scale level monitors for our Spent Fuel Pools (SFPs) in response to Order EA-12-051, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (Reference 2). The information provided herein documents full compliance for Point Beach Units 1 and 2 with Reference 2.

Request for Information - All RAis were either responded to, and closed, in response letter (Reference 3) or were incorporated into the ISE Open Items.

ISE Open Items- All Point Beach ISE Open Items have been closed.

ISE Confirmatory Items- Complete pending NRC Closure.

Licensee Identified Open Items- Complete pending NRC Closure.

Point Beach had provided a response via e-portal for the items requested in Reference 7 and considers them to be complete. (See Table 1 below)

MILESTONE SCHEDULE -ITEMS COMPLETE Point Beach Milestone Completion Date Commence Engineering and Design 10 2013 Complete Design 20 2014 Complete Procurement of SFP 30 2014 Instruments Complete Installation of SFP Instruments 40 2014 Instruments Operational and Training 40 2014 completed Page 1 of 26

ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Point Beach, as well as the Site response submittal (Reference 1), the 6-Month Status Reports (References 4, 5 and 6), and the response to request for additional information (Reference 3), demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING- COMPLETE Point Beach has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.

INSTRUMENT DESIGN FEATURES- COMPLETE The design of the instruments installed at Point Beach comply with the requirements specified in the order and described in NEI 12-02 "Industry Guidance for Compliance with NRC Order EA-12-051." The instruments have been installed in accordance with the station design control process.

The instruments have been arranged to provide reasonable protection against missiles. The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their designed accuracy following a power interruption and are designed to allow for routine testing and calibration.

The instrument display is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.

PROGRAM FEATURES- COMPLETE Training for Point Beach has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures, for Point Beach have been developed, and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

Page 2 of 26

TABLE 1 NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

Please provide the following: a) All SFPIS equipment will be designed in accordance with the Point Beach Nuclear Plant Safe Shutdown Earthquake (SSE) design requirements.

a) The design criteria that will be used to estimate the total The vendor, Westinghouse, has evaluated the structural integrity of the mounting brackets in calculation CN-PEUS-13-28. The loading on the mounting GTSTRUDL model, used by Westinghouse to calculate the stresses in the bracket assembly, considers load combinations for device(s), including static the dead load, live load and seismic load on the bracket. The reactionary forces calculated from these loads become the weight loads and dynamic design inputs to design the mounting bracket anchorage to the refuel floor to withstand a Safe Shutdown Earthquake (SSE).

loads. Describe the methodology that will be Seismic used to estimate the total loading, inclusive of design The seismic loads are obtained from Point Beach Nuclear Plant's response spectra. The following methodology was used in basis maximum seismic determining the stresses on the bracket assembly:

loads and the hydrodynamic loads that could result from

Frequency analysis, taking into account the dead weight and the hydrodynamic mass of the structure, is performed to pool sloshing or other effects obtain the natural frequencies of the structure in all three directions.

that could accompany such seismic forces.

SSE response spectra analysis is performed to obtain member stresses and support reactions .

Modal responses are combined using the Ten Percent Method per U.S. NRC Regulatory Guide 1.92, Revision 1, b) A description of the manner "Combining Modal Responses and Spatial Components in Seismic Response Analysis". This method is endorsed per in which the level sensor Appendix A.5 of the Updated FSAR for Point Beach Nuclear Plant.

1 (and stilling well, if

The seismic loads for each of the three directions are combined by the Square Root of the Sum of Squares (SRSS) appropriate) will be attached Method.

to the refueling floor and/or other support structures for

Sloshing analysis is performed to obtain liquid pressure and its impact on bracket design .

each planned point of

The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum.

attachment of the probe These combined results are compared with the allowable stress values.

assembly. Indicate in a schematic the portions of the Sloshing level sensor that will serve Sloshing forces were obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic as points of attachment for mechanical/mounting or Energy Commission, approach has been used to estimate the wave height and natural frequency. Horizontal and vertical electrical connections. impact force on the bracket components was calculated using the wave height and natural frequency obtained using TID-7024 approach. Using this methodology, sloshing forces have been calculated and added to the total reactionary forces that would c) A description of the manner be applicable for bracket anchorage design. The analysis also determined that the level probe can withstand a credible design by which the mechanical basis seismic event. During the design basis event, the SFP water level is expected to rise and parts of the level sensor probe connections will attach the are assumed to become submerged in borated water. The load impact due to the rising water and submergence of the level instrument to bracket components has also been considered for the overall sloshing impact. Reliable operation of the level measurement permanent SFP structures so sensor with a submerged interconnecting cable has been demonstrated by analysis of previous Westinghouse testing of the as to support the level sensor cable, and the vendor's cable qualification. Boron build up on the probe has been analyzed to determine the potential effects assembly.

Page 3 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

on the sensor.

The following Westinghouse documents provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a. CN-PEUS-13 Pool-side Bracket Seismic Analysis

b. WNA-TR-03149-GEN- Sloshing Analysis

c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353- Seismic Qualification of other components of SFPI Point Beach Nuclear Plant specific calculation NEE-009-CALC-006 -Anchorage Qualification for Spent Fuel Pool Instrumentation System Upgrades provides the qualification for the anchorage of the SFPIS equipment. The design criteria used in this calculation meets the requirements to withstand a 2x SSE and will meet the Point Beach seismic 1 installation requirements. The methods used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, will be suspended from the launch plate via coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors. Attachment 1 shows a schematic of the level sensor with mechanical attachment points.

c) The bracket assembly that supports the sensor probe and launch plate will be mechanically connected to the SFP structure.

The mechanical connection consists of four concrete expansion anchors that will bolt the bracket assembly to the SFP structure via the base plate. The concrete expansion anchors will be designed to withstand SSE and will meet the Point Beach seismic installation requirements. The qualification details of the bracket are provided in Westinghouse's Pool-side bracket Seismic Analysis CN-PEUS-13-28 and the qualification of the anchorage to the floor is provided in Point Beach specific calculation NEE-009-CALC-006- Anchorage Qualification for Spent Fuel Pool Instrumentation System Upgrades.

The following Westinghouse documents provide the analyses used to verify the design criteria and describe the methodology for seismic testing of the SFP instrumentation and electronics units, inclusive of design basis maximum seismic loads and hydrodynamic loads that could result from pool sloshing and other effects that could accompany such seismic forces:

Please provide the analyses used to verify

a. CN-PEUS-13 Pool-side Bracket Seismic Analysis the design criteria and methodology for seismic testing of the SFP instrumentation b. WNA-TR-03149-GEN- Sloshing Analysis and the electronics units, including, design 2 c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353- Seismic Qualification of other components of SFPI basis maximum seismic loads and the hydrodynamic loads that could result from No equipment failures were noted as a result of seismic test runs. Seismic test data has been documented in the seismic test pool sloshing or other effects that could reports, referenced above.

accompany such seismic forces.

Point Beach specific calculations NEE-009-CALC-006- Anchorage Qualification for Spent Fuel Pool Instrumentation System Upgrades, addresses the seismic qualification of the SFPIS equipment to the primary building structure. The design criteria used in this calculation satisfies the requirements to withstand 2x SSE and will meet the Point Beach seismic installation requirements for mounting the readout displays in the Primary Auxiliary Building.

Page 4 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

RAI-2 provides the design criteria and methodology used by Westinghouse for the mounting attachments. The Westinghouse documents provide the analyses used to verify the design criteria and describe the methodology for seismic testing of the SFP For each of the mounting attachments instrumentation and electronics units, inclusive of design basis maximum seismic loads and hydrodynamic loads that could result required to attach SFP level equipment to from pool sloshing and other effects that could accompany such seismic forces:

plant structures, please describe the 3

design inputs, and the methodology that Point Beach specific calculations NEE-009-CALC-006 -Anchorage Qualification for Spent Fuel Pool Instrumentation System was used to qualify the structural integrity Upgrades, addresses the seismic qualification of the SFPIS equipment to the primary building structure. The design criteria used in of the affected structures/equipment this calculation satisfies the requirements to withstand 2x SSE and will meet the Point Beach seismic installation requirements for mounting the readout displays in the Primary Auxiliary Building.

Please provide the following: a) Beyond Design Basis Environment- Westinghouse qualified the components (probe, connector, cable) of the SFPIS located in the SFP area to the beyond design basis environment. Components of the system were subjected to beyond design basis conditions of heat and humidity, thermal and radiation aging mechanisms. This testing confirmed functionality of these system a) A description of the specific components under these beyond design basis environmental conditions. Westinghouse performed testing to ensure aging of method or combination of the components in the SFP area will not have a significant effect on the ability of the equipment to perform following a plant methods you intend to apply to design basis earthquake. Reports with the test results document compliance to the Order. Subsequent to Westinghouse's demonstrate the reliability of the environmental testing and placing the instruments in service at Point Beach, Westinghouse identified a potential condition permanently installed equipment under evaluation which may warrant upgrade of coax connections in the spent fuel pool area. This potential condition is under beyond-design-basis documented and being addressed under the plant's corrective action program. Reference Westinghouse documents EQ-TP-ambient temperature, humidity, 351, WNA-TR-03149-GEN, and EQ-TP-354 for description of specific qualification methods.

shock, vibration, and radiation conditions. Mild Environment- Westinghouse qualified the system components (display panel, sensor) that reside in the mild environment conditions to determine that the components can satisfactorily perform to those conditions. Westinghouse has determined that b) A description of the testing and/or analyses that will be conducted aging does not have a significant effect on the ability of the equipment to perform following a plant design basis earthquake.

to provide assurance that the Reports with the test results document compliance to the Order. Reference Westinghouse documents EQ-QR-269, 4 equipment will perform reliably WNA-TR-03149-GEN for description of specific methods.

under the worst-case credible design basis loading at the Shock and Vibration- SFPIS pool side brackets were analyzed for SSE design requirements per NRC order EA-12-051 and location where the equipment NEI 12-02 guidance. As provided by the NRC Order EA-12-051, the NEI 12-02 guidance and as clarified by the NRC interim will be mounted. Include a staff guidance, the probe, coaxial cable, and the mounting brackets are "inherently resistant to shock and vibration loadings."

discussion of this seismic reliability demonstration as it As a result, no additional shock and vibration testing is required for these components. SFPIS pool side brackets for both the applies to a) the level sensor primary and backup Westinghouse SFP measurement channels will be permanently installed and fixed to rigid refuel floors, mounted in the SFP area, and b) which are Seismic Category 1 structures. The SFPI system components, such as level sensor and its bracket, display any control boxes, electronics, enclosure and its bracket, were subjected to seismic testing, including shock and vibration test requirements. The results for or read-out and re-transmitting shock and vibration tests were consistent with the anticipated shock and vibration expected to be seen by mounted equipment.

devices that will be employed to The level sensor electronics are enclosed in a NEMA-4X housing. The display electronics panel utilizes a NEMA-4X rated convey the level information stainless steel housing as well. These housings will be mounted to a seismically qualified wall and will contain the active from the level sensor to the plant electronics, and aid in protecting the internal components from vibration induced damage.

operators or emergency responders.

Reference Westinghouse reports WNA-DS-02957, WNA-TR-04757-GEN for shock and vibration.

Page 5 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

c) A description of the specific below listed standards:

method or combination of methods that will be used to

IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Electrical Equipment for Nuclear confirm the reliability of the Power Generating Stations permanently installed

IEEE-323-1974, Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations equipment such that following a seismic event the instrument

US NRC Regulatory Guide 1.1 00, Rev. 3 will maintain its required accuracy.

USNRC Regulatory Guide 1.92, Rev. 1

NEE-009-CALC-006 -Anchorage Qualification for Spent Fuel Pool Instrumentation System Upgrades Seismic adequacy of the level sensor probe supporting bracket within the SFP area was demonstrated by analysis as discussed in response to RAI-2.

c) Westinghouse has seismically qualified the SFPI instrument and its components. CN PEUS-13-28 describes Pool-side Bracket Seismic Analysis, EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 describe remaining seismic qualifications of the instrument components. With the instrument being seismically qualified and installed as described in RAI 2b response, the instrument is assured to maintain reliable and accurate indication when required. Westinghouse report WNA-CN-00301-GEN and Point Beach Engineering Change 276803 provide the channel accuracy from measurement to display.

Reference Attachment 2 - items 8, 12, 17 Below is a summary of the test conditions used by Westinghouse to qualify the SFPIS. These test conditions are also documented in Attachment 2, Items 3 thru 8. Environmental conditions for SFPIS components installed in the spent fuel pool area at Point Beach are bounded by the test conditions. The radiation TID for beyond design basis conditions (BOB) at the floor above the SFP when the SFP water level is at Level 3 is 9.4E+06 R y, based on the results of calculation N-89-024, Dose Rates at Elev.

66' From Opt. Fuel Assembly in Reactor Cavity During Varying Depths of Water. The results of calculation N-89-024 were adjusted using a conservative "1/r" distance correction to reflect the difference in the location of the top of the fuel rack in the SFP For RAI No. 4 above, please provide the (EI. 39'0") and the location used in the calculation (EI. 55'2") and a conservative power correction factor of 1.3 to reflect changes in results for the selected methods, tests and the fuel assembly source term due to power uprate. The BOB radiation value to which the Westinghouse equipment is qualified to analyses utilized to demonstrate the is 1E+09 R y for the probe stainless steel cable in the spent fuel pool and 1E+07 R y for the equipment above the pool, per 5 qualification and reliability of the installed Section 5.1.2 of WNA-TR-03149-GEN. When the SFP water level is at Level 3, the only components of the SFPI that are exposed equipment in accordance with the Order to high radiation are the stainless steel probe and anchor. These components are manufactured from materials that are resistant requirements.

to radiation effects and which can withstand a 40 year radiation dose. The radiation TID for BOB conditions at the floor above the SFP when the SFP water level is at Level 2 is 8E+01 R y based on the results of calculation N-89-024 and corrected in the same manner described earlier. Westinghouse updated the design specification (WNA-DS-02957-GEN) and LTR-SFPIS-13-35, Revision 1 ,documentation to include the above technical justification.

Environmental Conditions for SFPIS Components in the Spent Fuel Pool Area Level sensor probe, coax coupler and connector assembly, launch plate and pool side bracket assembly, coax cable are Page 6 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

designed and qualified to operate reliably in the below specified environmental conditions. I BOB Parameter Normal Temperature 50-140°F 212°F Pressure Atmospheric Atmospheric Humidity 0-95% RH 100% (saturated steam)

Radiation TIDy 1E03 Rads 1E07 Rads (above pool)

Radiation Tl D y 1E09 Rads (12" above top of fuel rack) 1E07 Rads (probe and weight only)

Environmental Conditions Outside of the Spent Fuel Pool Area The level sensor transmitter and bracket, electronics display enclosure and bracket are designed and qualified to operate reliably in the below specified environmental conditions.

BOB Normal BDB Parameter (Level Sensor Electronics Only)

Temperature 140°F 140°F 50-120°F Pressure Atmospheric Atmospheric Atmospheric Humidity 0-95% 0-100%

0-95% RH (non-condensing) (non-condensing)

Duration 7 days 7 days

?days Radiation Tl D y s 1E03 R y s 1E03 R s 1E03 R Page 7 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

Thermal and Radiation Aging - organic components in SFP area Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-03149-GEN (Attachment 2, item 6) provide thermal and radiation aging program details for the SFPI components. Westinghouse completed their thermal and radiation aging testing programs to qualify the SFPI components to 10 years. The Westinghouse summary report, EQ-QR-269, contains an open item to track resolution of the potential shortfall of the radiation dose calculation by Steris.

Westinghouse provided an interim position response for the radiation aging program performed on the SFPIS. (LTR-EQ-14-163) It was concluded by Westinghouse that the radiation program for the SFPIS included requirements for margin and uncertainty based on the industry standards and known accuracy of the Steris dosimetry equipment. The radiation aging certificate for the SFPIS equipment identifies that a minimum of 12.1 Mrads was achieved; therefore, it is shown that the actual minimum radiation dose that was achieved for the SFPIS equipment is sufficient for a 10-year specimen. NextEra is tracking closure of this open item. NextEra will complete the test report reviews when available.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirms that the SFPIS meets the seismic requirements of the vendor's design specification (Attachment 2, item 1). Westinghouse's design specification satisfies the Point Beach installation requirements to withstand a SSE.

Vibration Justification As specified in RAI-4, components of the system (i.e., bracket, transmitter enclosure, display enclosure, and readout display) will be permanently installed to meet the requirements to withstand a SSE and will meet the Point Beach seismic installation requirements.

Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification The sloshing calculation performed by Westinghouse (Attachment 2, item 9) was reviewed for a design basis seismic event and found acceptable. Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

Page 8 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

The primary level channel will be powered from a 120VAC Emergency Lighting Panel, 37-E. This panel can be aligned to the Unit 2 Please provide the NRC staff with the final Train A backup 1E Emergency power supply via MCC 2B-32 which is fed from 2B-03 which is fed from 2A-05 and can be aligned to configuration of the power supply source EDG G-02 (normal) or EDG G-01 (alternate). Panel 37-E is located in the PAB, accessible from plant elevation 66 foot and Is for each channel so the staff may conclude located on the north wall near the Spent Fuel Pool.

6 the two channels are independent from a power supply assignment perspective. The backup level channel is powered from 120VAC Emergency Lighting Panei31-E. Panei31-E is powered from MCC 1B-42 which is fed from 1B-04 which is fed from 1A-06 and can be aligned to EDG G-03 (normal) or EDG G-04 (alternate). Panel 31-E is located in the PAB, accessible from plant Elevation 66 foot and is located on the south wall near the Spent Fuel Pool Please provide the results of the calculation depicting the battery backup The Westinghouse Report, WNA-CN-00300-GEN, provides the results of the calculation depicting the battery backup duty cycle.

duty cycle requirements demonstrating This calculation demonstrates that battery capacity is 4.22 days to maintain the level indicating function to the display location, 7 that the capacity is sufficient to located in the 26 foot Primary Auxiliary Building at Point Beach. The Flex designated guidelines for Point Beach is 3 days; maintain the level indication function therefore, the results of the calculation meet the requirements laid out by the site.

until offsite resource availability assured.

Please provide the following:

a) The Westinghouse documents WNA-CN-00301-GEN (Attachment 2, item 17) and WNA DS 02957-GEN (Attachment 2, item 1) describe the channel accuracy under both (a) normal SFP level conditions and (b) at the Beyond Design Basis (BDB) a) An estimate of the expected conditions that would be present if SFP level were at Level 2 and Level 3 datum points. Each instrument channel will be instrument channel accuracy accurate to within +/-3"during normal spent fuel pool level conditions. The instrument channels will retain this accuracy after performance under both (a) normal SFP level conditions (approximately BDB conditions, in accordance with the above Westinghouse documents. This value is within the channel accuracy Level 1 or higher) and (b) at the requirements of the Order (+/-1 foot).

beyond design-basis conditions (i.e., radiation, temperature, b) The Westinghouse document WNA-TP-04709-GEN (Attachment 2, item 20) describes the methodology for routine humidity, post-seismic and post- testing/calibration verification and calibration methodology. This document also specifies the required accuracy criteria under shock conditions) that would be normal operating conditions. Point Beach calibration and channel verification procedures will follow the guidance and criteria present if the SFP level were at the provided in this document.

8 Level 2 and Level 3 datum points. Instrument channel calibration will be performed if the level indication reflects a value that is outside the acceptance band established in the Point Beach calibration and channel verification procedures.

b) A description of the Instrument channel loop accuracy and set point deviation/error are determined using the Point Beach Design Guide, DG-101 methodology that will be used for determining the maximum allowed for safety related instruments. The methodology used to determine the set point deviation in this standard is consistent with deviation from the instrument ANSI/ISA-67.04.01-2000. Per this methodology, since drift value was not specified by the vendor, a default random drift value channel design accuracy that will of +/-1% of span (or +/-1% of full scale, for conservatism) for mechanical components was assigned. A setting tolerance of twice be employed under normal the reference accuracy, which is a typical value, was applied to the indicator to yield an overall setting tolerance of +/- 2% of full operating conditions as an scale. This value will be used for the calibration procedure being developed for this instrument loop. The resultant non-acceptance criterion for a negligible terms (Reference Accuracy, Drift, Readability, Measurement and Test Equipment Effect, and Setting Tolerance) are calibration procedure to flag to all random terms, and will be combined using the Square Root Sum of Squares (SRSS) methodology given in Design Guide operators and to technicians that Page 9 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

the channel requires adjustment DG-101. Thus, the maximum deviation introduced by the indicator, in percent of full span, is computed.

to within the normal condition design accuracy. Calibration will be performed once per refueling cycle for Point Beach. Per Westinghouse document WNA-TP-04709-GEN (Attachment 2, item 20) calibration on a SFP level channel is to be completed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g. 25%). This is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation.

Please provide the following:

a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be a) Westinghouse calibration procedure WNA-TP-04709-GEN (Attachment 2, item 20) and functional test procedure tested in-situ. WNA-TP-04613-GEN (Attachment 2, item 10) describe the capabilities and provisions of SFPI periodic testing and calibration, including in-situ testing. Point Beach will utilize the Westinghouse calibration procedure for the functional check at the pool b) A description of the ways testing and side bracket.

calibration will enable performance of b) The level displayed by the channels will be verified per the Point Beach administrative and operating procedures, as regular channel checks of each recommended by Westinghouse vendor technical manual WNA-G0-00127-GEN (Attachment 2, item 19). If the level is not independent channel against the other within the required accuracy per Westinghouse recommended tolerance in WNA-TP-04709-GEN (Attachment 2, item 20),

and against any other permanently-9 channel calibration will be performed.

installed SFP level instrumentation.

c) Functional checks will be performed per Westinghouse functionality test procedure WNA-TP-04613-GEN (Attachment 2, c) A description of how functional checks item 10) at the Westinghouse recommended frequency. Calibration tests will be performed per Westinghouse calibration will be performed, and the frequency at procedure WNA-TP-04709-GEN (Attachment 2, item 20) at the Westinghouse recommended frequency.

which they will be conducted. Describe d) Point Beach will develop preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the how calibration tests will be performed, technical manual WNA-G0-00127-GEN (Attachment 2, item 19) to assure that the channels are fully conditioned to accurately and the frequency at which they will be and reliably perform their functions when needed.

conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.

d) A description of what preventive maintenance tasks are required to be performed during normal operation, and Page 10 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE !

No.

the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

The location for the SFP wide range level instrument displays will be on the 26 foot elevation of the PAS near the C-59 Waste Disposal Control Panel. The displays will be approximately 40 feet below the level sensors in an adjacent area, outside the area surrounding the SFP floor and are physically separated from each other within the PAB. They will be physically protected from the environmental and radiological conditions resulting from a beyond design basis (BDB) event.

Westinghouse documents EQ-QR-269 and WNA-TR-03149-GEN (Attachment 2, item 5) provide qualification details for the SFPI Please describe the evaluation used to components as discussed in RAI-5 above. Site specific calculation 2013-0020, PAS Scenarios for Fukushima Coping, determined the 140 degree temperature and 95% humidity for the location of the equipment at the 26 foot elevation of the PAS was acceptable validate that the display location can be for the site specific conditions.

accessed without unreasonable delay following a BDB event. Include the time Analysis was performed using a commercial shielding program (MicroShyshine) to determine the expected dose rate in the 26 foot available for personnel to access the elevation where the equipment would be located. The fuel assembly data (dimensions and density) in N-89-024 was used; display as credited in the evaluation, as however, the fuel assembly activity was calculated using the data contained in Table 14.3.5-1, Core Activities. The data in Table well as the actual time (e.g. based on 14.3.5-1 is at shutdown and is based on a core power level of 1811 MWt. The source term for the fuel assembly was calculated by walk-throughs) that it will take for dividing the core activity by the number of fuel assemblies in the core and then decaying it for 65 hours7.523148e-4 days 0.0181 hours 1.074735e-4 weeks 2.47325e-5 months . The geometry modeled in personnel to access the display. the program was with the fuel assembly in a SFP storage location with one foot of water over the top of the fuel, the El. 46 foot Additionally, include a description of the concrete floor with a thickness of 18" and the dose point at Elevation 30' (four feet above floor level). The dose point was placed at radiological and environmental a lateral distance of 150 feet from the center of the fuel assembly. The calculated dose rate was 8 mrem/hr for a 40 fuel assembly 10 conditions on the paths personnel might array. It is concluded based on this analysis that the equipment is bounded by the testing performed by Westinghouse and the take. Describe whether the display location is accessible for personnel during a BDBE.

location remains habitable for radiological, heat and humidity, and The 26 foot elevation of the PAB is contained within a Seismic Class I structure that has multiple access routes. Normal access is other environmental conditions provided from the south through the Radiation Protection Checkpoint. Alternate access routes are available from the Unit 1 Turbine following a BOB event. Describe whether Hall 8 foot elevation through door number 20 to the PAS and up the stairs to the C-59 panel area. Another alternate access route is personnel are continuously stationed at available from Unit 2 Turbine Hall 8 foot elevation through door number 12 to the PAS and up the stairs to the C-59 area.

the display or monitor the display Environmental conditions on the 26 foot and 8 foot levels are expected to remain habitable and accessible at saturation conditions periodically. in the SFP. Calculation 2013-0020 indicated that with an outside air temperature of 105 degrees that the temperature in the C-59 area reaches a maximum of 105 degrees in the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months assuming the SFP reached saturated conditions in 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months .

The 26 foot elevation near the C-59 panel is a designated watch station and manned with a qualified Auxiliary Operator during normal operating conditions. During a beyond design basis event qualified operators would be implementing the FLEX strategies near the wide range level displays and would be available to obtain readings and relay that information to the control room with minimal delays. In the event that no operators are in the vicinity of the level displays it is reasonable to assume that individuals could be dispatched from the control room or the Technical Support Center, obtain readings and report level to the control room in less than one hour. This is based on transient time from the control room to the C-59 area is less than 15 minutes including time to process through the radiation checkpoint. Hand held radios, person to person contact or the PBX phone system are communication Page 11 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

systems available to transmit the information.

As stated in PBN's OIP the worst case time to boil is approximately 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months with an additional 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months estimated for the level in the SFP to reach 2 feet 11 inches above the fuel. This allows sufficient time to determine SFP level and initiate makeup flow to the SFP.

Please provide a list of the procedures addressing operation (both normal and abnormal response),

calibration, test, maintenance, and inspection that will be Answered in Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to 11 developed for use of the SFP Reliable Spent Fuel Pool Instrumentation, dated February 28, 2014 (ML14059A086).

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

Please provide the following:

a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate Answered in Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to 12 conformance with design and system Reliable Spent Fuel Pool Instrumentation, dated February 28, 2014 (ML14059A086).

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

b) A description of how the guidance in Page 12 of 26

NRC NRC QUESTION DESCRIPTION LICENSEE QUESTION RESPONSE No.

NEI12-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

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

Westinghouse calibration procedure WNA-TP-04709-GEN (Attachment 2, item 20) and functional test procedure WNA-TP-04613-GEN (Attachment 2, item 10) describe the capabilities and provisions of SFPI periodic testing and calibration, Please provide a description of the in-situ including in-situ testing. Point Beach will utilize the Westinghouse calibration procedure for the functional check at the pool side calibration process at the SFP location 13 bracket. The level displayed by the channels will be verified per the Point Beach administrative and operating procedures, as that will result in the channel calibration recommended by Westinghouse vendor technical manual WNA-G0-00127-GEN (Attachment 2, item 19). If the level is not within being maintained at its design accuracy.

the required accuracy per Westinghouse recommended tolerance in WNA-TP-04709-GEN (Attachment 2, item 20), channel calibration will be performed.

Page 13 of 26

REFERENCES The following references support the Point Beach SFPI Compliance Document:

1. NextEra Energy Point Beach, LLC's 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 22, 2013 (ML 13053A39)

2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," March 12,2012 (ML12056A044)

3. NextEra Energy Point Beach, LLC, Response to Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation," dated July 3, 2013 (ML13186A012)

4. NextEra Energy Point Beach, LLC's First Six Month Status Report 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 August 28, 2013 (ML13241A202)

5. NextEra Energy Point Beach, LLC's Second Six Month Status Report 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 28,2014 (ML14059A086)

6. NextEra Energy Point Beach, LLC's Final Six Month Status Report 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 August 28, 2014 (ML14241A268)

7. NRC Letter to NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, 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. MF0729 and MF0730), dated November 18, 2013 (ML13309A011)

Page 14 of 26

ATTACHMENT -1 Point Beach Schematic of the Level Sensor with Mechanical Attachment Points c;t_ ~SE PlATE. 5o'81i' &OL TS, r UfTING ROOS, HOU:!S, & ANCHORS

(;'\'4 *11'2"~ X 13, 7!1' LONG I

I

\VLIF-liNO ROOS-BOTTOM 0,75* i~EACED AS 1.'2-13 I I

<t. HOLES II, 11'&" THICK PL t-t+----' (I !J,2!i)--+li------..-t I - SEE StU HOK 1-4--H---+-(5)-.....-++- i::NCI,.OS\.IRE ATTACtit~T 1

r.o.c, El.EV, I I I I I (~)

-~1 -~h-l7,2!1)11fii*~iJ;.._:_

I ~_.:

I smr nr:vATtefol I FACF: OF UNER PLATE F AC!:. loP eot,Gl: Of SOX SUCH TH4T ll<=

r o com"' It uoo v IN~ACE IS FLAi TO CN' 'PJ FiE E!oCt. T

riASQI~ t:!IIJ.t t1l l ,,..PI"" ~'J- Hi THRV. n-£ eono~ 8VE 0"' THE HO-E I!: ti'IJ.L.t..o ",,. x o.~ CJt:t,. rQt4 T!iRS4.0 Ct..E~'-CE ~SEE CET.-JL ~1 T~Qul DOt T 10 n I TolD~~ ::>"10!

SECTION 0*0 NUl Page 15 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation Summary Results Document#

1 Design SFPIS WNA-DS-02957- Contains technical N/A Specification Requirements GEN SFPIS requirements NextEra has determined that WNA-DS-derived from based on NRC order, 02957-GEN bounds the Point Beach References 1, 2, & 3 NEI guidance, and requirements from References 1, 2 and 3.

the ISG listed above.

2 Test Strategy Per Requirements. WNA-PT-00188- Strategy for N/A GEN performing the testing NextEra has determined WNA-PT -00188-and verification of the GEN to be acceptable for the current design.

SFPIS and pool-side bracket.

3 Environmental 50° F to 140° F, EQ-QR-269 and Results are Test passed Temperature is :s; 140°F and humidity is :s; qualification for WNA-TR-03149- summarized in EO- conditions 95% RH for abnormal conditions in the 26 electronics 0 to 95% RH GEN for all QR-269 and WNA- described. foot general areas of the Primary Auxiliary enclosure with conditions. TR-03149-GEN. Building (Reference 4). The above values Display are bounded by the values in Section 3.3 of WNA-TR-03149-GEN.

TID :s; 1E03 Ry Radiation Aging The normal and abnormal TID of< 1.E03 R normal (outside verification y from Reference 5 (for Primary Auxiliary SFP area) summarized in Building) is bounded by the justification for Section 5 of WNA- TID less than 1 E03 rads from Section 5.1.2 TR-03149-GEN. of WNA-TR-03149-GEN.

TID :s; 1E03 R y abnormal (outside Aging Tests- Westinghouse completed its SFP area) aging qualification of SFPIS to 10 years.

Westinghouse has provided an interim position regarding the aging qualification Page 16 of 26

ATIACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment

Licensee Evaluation Summary Results Document#

and the open item from Steris. NextEra will complete the test report reviews when provided.

4 Environmental 50 ° F to 212° F and EQ-TP-351 Testing summarized Passed Testing for Level 100% humidity in section 3.2. The temperature and humidity values of Sensor 212°F and 100% RH from Reference 6 (for components in PAB) are bounded by Section 3.2 of WNA-SFP area- TR-03149-GEN.

Saturated Steam

& Radiation 1E03 R y normal WNA-TR-03149- Thermal Aging & Passed The normal operating dose in the SFP area (SFP area) GEN radiation aging per Reference 5 is< 1.E03 R y, which is verification bounded by Section 5.1.1 of WNA-TR-summarized in 03149-GEN.

Sections 4.1 and 5 (entire system) of WNA-TR-03149-GEN.

1EO? R y BOB (SFP EQ-TP-354 Additional thermal & Additional aging The BOB radiation TID, 12" above top of fuel area) (procedure) radiation aging program is in rack for Point Beach is 7.2E06 R y, per programs being progress to calculation N-89-024- Dose Rates at Elev.

Actual test report is conducted under test achieve longer 66' From Opt. Fuel Assembly In Reactor in progress. procedure EQ-TP- life. Cavity during Varying Depths of Water. The Page 17 of 26

ATIACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation' Summary Results '

Document#

354. BOB radiation value to which the Westinghouse equipment is qualified to is 1.E09 R y for the probe stainless steel cable and weight and 1EO?R y for the equipment above the pool, per Section 5.1.2 of WNA-TR-03149-GEN. The radiation value of 7.2E06 R y is lower than 1.E07 R y to which Westinghouse qualified the instrument to.

With SFP water level at Level 3 the only components of SFPI that are exposed to high radiation are the stainless steel probe and the stainless steel anchor. The materials with which the probe and the anchor are manufactured are resistant to radiation effects. The stainless steel anchor and stainless steel probe can withstand 40 year dose. The BOB radiation value for Level 2 is 6.4E01 R y, per calculation N 024. Westinghouse updated the design specification (WNA-OS-02957-GEN) and LTR-SFPIS-13-35, Revision 1 documentation to include the above technical justification.

Aging Tests- Westinghouse completed its aging qualification of SFPIS to 10 years.

Westinghouse has provided an interim position regarding the aging qualification and the open item from Steris. NextEra will complete the test report reviews when provided.

Page 18 of 26

ATTACHMENT- 2 Westinghouse Parameter TestQrAnalysi~ .

Topic Reference '

Additional. Comment Licensee Evaluation*

Summary i' Results Document#

5 Environmental 50° F to 140° F, WNA-TR-03149- Testing summarized Passed Temperature is::; 140°F and humidity is::;

Testing for Level GEN in section 3.3 95% RH for abnormal conditions in the Sensor 0 to 95% RH Primary Auxiliary Building. The above values Electronics are bounded by the values in Section 3.3 of Housing- WNA-TR-03149-GEN.

outside SFP TID::; 1E03 R y WNA-TR-03149- Radiation Aging Passed normal (outside GEN verification The normal and abnormal TID of < 1.E03 R SFP area) summarized in y from Reference 5 (for Primary Auxiliary Section 5. Building) is bounded by Section 5.1.2 of TID s 1E03 R y WNA-TR-03149-GEN.

abnormal (outside SFP area) 6 Thermal & 1 E03 R y normal EQ-QR-269 and Thermal Aging & Passed NextEra has determined EQ-QR-269 and Radiation Aging - (SFP area) WNA-TR-03149- radiation aging WNA-TR-03149-GEN documents provided organic GEN verification to be acceptable for Point Beach installation.

components in summarized in See response to Item 4 above.

SFP area Sections 4.1 and 5 (entire system) of WNA-TR-03149-GEN.

1 EO? R y BDB (SFP EQ-TP-354 Additional thermal & Additional aging Aging Tests- Westinghouse completed its area) (procedure) radiation aging program is in aging qualification of SFPIS to 10 years.

programs being progress to Westinghouse has provided an interim Actual test report is conducted under test achieve longer position regarding the aging qualification in progress. procedure EQ-TP- life. and the open item from Steris. NextEra will 354. complete the test report reviews when provided.

Page 19 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation Summary Results Document#

7 Basis for Dose SFP Normal LTR-SFPIS-13-35 Explanation of Basis Passed for all NextEra has determined the basis Requirement Conditions: and for Radiation Dose conditions documents to be acceptable.

WNA-DS-02957- Requirement 1E03 R y TID GEN (includes the The normal operating dose in the SFP area (above pool) clarification of per Reference 5 is< 1.E03 R y, which is production bounded by Section 5.1.1 of WNA-TR-1E09 R y TID (1' equivalency of 03149-GEN.

above fuel rack) electronics enclosure used for Seismic and The BDBE radiation of 7.2E06 Rem above SFP BDBE EMC Testing) the pool high water level (Level 1) from Conditions: Reference 9 is bounded by Section 5.1.1 of WNA-TR-03149-GEN.

1E07 R yTID (above pool) Radiation values 1' above the fuel rack are 2E07 Rem from Reference 5. However, the

< 1EO? R y TID (1' justification for components that are above fuel rack) inherently resistant to radiation effects in Section 5.1.1 of WNA-TR-03149-GEN is bounding for Point Beach.

8 Seismic Per Spectra in EQ-QR-269 EQ-QR-269 Passed The Spectra in Reference 6 for the pools ide Qualification WNA-DS-02957- summarizes the mounting brackets bounds Point Beach for GEN testing performed by meeting the requirements to withstand a Westinghouse SSE. Instrument panel mounting is qualified by Reference 6.

WNA-TR-03149- WNA-TR-03149-GEN Passed GEN provides high level summary of the pool-side bracket analysis and optional RTD.

Page 20 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additionai.Comment Licensee Evaluation Summary Results Document#

EQ-TP-353 Seismic Pull test for Passed (procedure) new connectors is in progress under procedure, EQ-TP-353.

9 Sloshing N/A LTR-SEE-11-13-47 Calculation to Passed NextEra has determined WNA-TR-03149-demonstrate that GEN to be acceptable. Adequate sloshing probe will not be forces (inclusive of vertical and horizontal sloshed out of the impact forces, hydrodynamic forces) were SFP. accounted to calculate the overall sloshing forces. These forces were added to design WNA-TR-03149- Sloshing is also Passed the bracket anchorage, to ensure the probe GEN addressed in Section will not be sloshed due to a beyond design 7.2. basis seismic event.

I 10 Spent Fuel Pool Acceptance Criteria WNA-TP-04613- Test procedure used See applicable NextEra has determined WNA-TP-00189-Instrumentation for Performance GEN to demonstrate that EO test. GEN "Integrated Functional Test Plan" to be System during EO testing SFPIS meet its acceptable.

Functionality Test operational and Procedure accuracy requirements during Equipment Qualification Testing programs.

11 Boron Build-Up Per requirement in WNA-TR-03149- Boron build up Passed Next Era has determined WNA-TP-00189-WNA-DS-02957- GEN demonstrated GEN "Integrated Functional Test Plan" to be GEN through Integrated acceptable.

Page 21 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation Summary Results.

Document#

Functional Test (1FT).

12 Pool-side Bracket N/A CN-PEUS-13-28 Also includes Passed See response to RAI No. 4. Point Beach Seismic Analysis hydrodynamic forces, seismic requirements to withstand a SSE as appropriate. are bounded by Reference 6 for the pools ide mounting brackets.

13 Additional N/A WNA-DS-02957- Weights provided to N/A See response to RAI No. 4. Point Beach Brackets (Sensor GEN licensees for their has evaluated the seismic mounting Electronics and own evaluation. requirements. Instrument panel mounting is Electronics qualified by Reference 6.

Enclosure) 14 Shock & WNA-DS-02957- WNA-TR-03149- Section 7 provides N/A NextEra has determined the Westinghouse Vibration GEN GEN rationale and evaluation of shock and vibration in WNA-summary of RTD. TR-03149-GEN is acceptable.

15 Requirements Maps Requirements WNA-DC-00246- The compliance N/A NextEra has reviewed the compliance matrix Traceability to documentation I WEP matrix maps the provided by Westinghouse. Some items do Matrix evidence that requirements of the not apply to Point Beach and should be Requirement is met NRC order, NEI removed from the matrix. There are items guidance, ISG to the that do apply requiring revision.

applicable technical requirements in the SFPIS design specification and maps the design specification requirements to the documentation demonstrating the Page 22 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation Summary Results Document#

requirement is met.

I 16 Westinghouse 1FT Functional WNA-TP-04752- The Integrated Point Beach 1FT NextEra has reviewed the final test reports Factory Requirements from GEN Functional Test (1FT) executed/passed and found them to be acceptable.

Acceptance Test, WNA-DS-02957- demonstrates including testing GEN functionality of the full of dead-zones system for each customer's FAT, which includes calibration of each channel.

12" dead-zone at top WNA-TP-04752- Dead-zone tests are N/A of probe GEN in Section 9.6.2.

4" dead-zone at bottom of probe 17 Channel +1- 3 inches per WNA-CN-00301- Channel accuracy Passed NextEra has reviewed WNA-DS-02957-GEN Accuracy WNA-DS-02957- GEN from measurement to and WNA-CN-00301-GEN and found that GEN display. channel accuracy requirements are met.

Point Beach calculated channel accuracy is

+/-6 inches.

Page 23 of 26

ATTACHMENT- 2 Westinghouse Parameter Test or Analysis

Topic Reference Additional Comment Licensee Evaluation Summary Results Document#

18 Power 3 day battery life WNA-CN-00300- N/A Passed Point Beach has reviewed WNA-CN-00300-Consumption (minimum) GEN GEN and concluded that battery life of > 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is available for Westinghouse display 0.257 Amps power enclosure and meets the Order consumption requirements. The 0.257 A loading does not challenge the Point Beach electrical distribution system.

19 Technical Manual N/A WNA-G0-00127- Information and N/A Point Beach will utilize WNA-G0-00127-GEN instructions for GEN as input for procedure preparation.

Operation, Installation, use, etc. !

are included here.

20 Calibration Routine WNA-TP-04709- Also, includes N/A Point Beach will utilize WNA-TP-04709-GEN Testing/calibration GEN preventative as input for procedure preparation.

verification and maintenance actions Calibration method such as those for Boron buildup and cable probe inspection.

21 Failure Modes N/A WNA-AR-00377- Addresses N/A Point Beach will utilize WNA-AR-00377-and Effects GEN mitigations for the GEN as input for procedure preparation.

Analysis (FMEA) potential failure modes of the system.

22 Emissions RG 1.180, Rev. 1 WNA-TR-03149- N/A Passed NextEra has reviewed the test report and Testing test conditions GEN found it meets requirements for radiated EQ-QR-269 emissions limits and criterion B for susceptibility testing based on the modifications implemented.

Page 24 of 26

ATIACHMENT- 2

REFERENCES:

1) ML12056A044, NRC Order EA-12-051, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION," Nuclear Regulatory Commission, March 12, 2012.

2) ML12240A307, 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" August, 2012.

3) ML12221A339, Revision 0, JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, August 29, 2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate.

4) 2013-0020- PAB Scenarios for Fukushima Coping Calculation

5) N-89-024- Dose Rates at Elev. 66' From Opt. Fuel Assembly In Reactor Cavity during Varying Depths of Water

6) Westinghouse Calculation CN-PEUS-13 Seismic Analysis of the SFP Mounting Bracket at Point Beach Units 1&2 and St. Lucie Units 1&2 Revision 2

7) NEE-009-CALC-006- Anchorage Qualification for Spent Fuel Pool Instrumentation System Upgrades

8) Engineering Change Package 276803 - Spent Fuel Pool Instrumentation - Fukushima

9) Point Beach UFSAR Table 14.3.5-1 Core Activities

10) Westinghouse Proprietary Document, WNA-DS-02957-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System Design Specification," Revision 4.

11) Westinghouse Proprietary Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy," Revision 2.

12) Westinghouse Proprietary Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation," Revision 0

13) Westinghouse Proprietary Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report,"

Revision 0

14) Westinghouse Proprietary Document, EQ-TP-351, "Environmental Qualification Test Procedure for the Spent Fuel Pool Instrumentation System Coaxial Cable and Connectors Inside the Spent Fuel Pool Area," Revision 0

15) Westinghouse Proprietary Document, EQ-TP-354, "Mechanical Preconditioning, Thermal Aging, and Radiation Aging Procedure for the Spent Fuel Pool Instrumentation System Coaxial Cables and Couplers," Revision 0

16) Westinghouse Proprietary Document, EQ-TP-360, "Environmental Test Procedure for the Sensor Housing for Spent Fuel Pool Instrumentation System," Revision 0

17) Westinghouse Proprietary Document, LTR-SFPIS-13-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronics Enclosure Used for Seismic Testing," Revision 1.

18) Westinghouse Proprietary Document, LTR-SEE-11-13-47, "Determination if the Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out of the Spent Fuel Pool during a Seismic Event," Revision 0 Page 25 of 26

ATTACHMENT- 2

19) Westinghouse Proprietary Document, WNA-TP-04613-GEN, "Spent Fuel Pool Instrumentation System Functionality Test Procedure,"

Revision 5.

20) Westinghouse Proprietary Document, WNA-DC-00246-WEP, "Spent Fuel Pool Instrumentation System FPUNextEra- Point Beach 1&2 Compliance Matrix," Revision 1

21) Westinghouse Proprietary Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Procedure," Revision 1.

22) Westinghouse Proprietary Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis,"

Revision 1.

23) Westinghouse Proprietary Document, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation," Revision 1.

24) Westinghouse Proprietary Document, WNA-G0-00127-GEN, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual," Revision 1.

25) Westinghouse Proprietary Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure," Revision 4.

26) Westinghouse Proprietary Document, WNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis," Revision 3.

27) Westinghouse Proprietary Document, LTR-EQ-14-163, "Interim Position for Radiation Aging of the Spent Fuel Pool Instrumentation System" Page 26 of 26