ML15202A536
| ML15202A536 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/17/2015 |
| From: | Dent J Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2.15.051, EA-12-051, TAC MF0777, TAC MF0778 | |
| Download: ML15202A536 (53) | |
Text
Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station Entergy 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent Jr.
Site Vice President July 17, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, OWFN-2 FL Rockville, MD 20852-2738
SUBJECT:
Pilgrim Nuclear Power Station's Notification of Full Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 PNPS Letter 2.15.051
REFERENCES:
- 1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A682)
- 2. Entergy Letter to NRC (PNPS 2.13.014), 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 (ML13063A097 and ML13063A098)
- 3. NRC Letter Regarding Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (TAC No. MF0778) (ML1333A910), dated December 5, 2013 (PNPS Letter 1.13.065)
- 4. NRC Letter Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0777 and MF0778), dated January 26, 2015 (PNPS Letter 1.1 5.003)
PNPS Letter 2.15.051 Page 2 of 3
Dear Sir or Madam:
The purpose of this letter is to notify the NRC that Pilgrim Nuclear Power Station (PNPS) is in full compliance with Order EA-12-051. On March 12, 2012, the U. S. Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Entergy Nuclear Operations, Inc. (Entergy). Reference 1 was immediately effective and directed Entergy to install reliable spent fuel pool level instrumentation (SFPI).
Order EA-12-051,Section IV.A.2 requires completion of full implementation to be no later than two refueling cycles after submittal of the Overall Integrated Plan (OIP), as required by Condition C. 1 .a, or December 31, 2016, whichever comes first. In addition,Section IV.C.3 of Order EA-12-051 requires that Licensees and CP holders report to the NRC when full compliance is achieved. The OIP for EA-12-051 was submitted (Reference 2) on February 28, 2013. On May 20, 2015, PNPS entered Mode 2 (startup) following refueling outage 20 which was two refuel cycles after submittal of the OIP. Full compliance with Orders EA-12-051 was achieved at that time as discussed in the attachments.
This letter, along with the attachments, provides the notification required by Section IV.C.3 of the Order that full compliance with the requirements described in Attachment 2 of the Order has been achieved for PNPS. The attached responses as requested from References 3 and 4 are based on information and analyses that have been completed as of the date of full compliance. As such, Energy considers these items complete pending NRC closure.
The notification of full compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events was submitted under separate cover via PNPS Letter No. 2.15.050 dated July 17, 2015. This was separated since no Final Integrated Plan is required for the SFPI Order as was required with the Mitigation Strategies Order submittal.
This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Everett (Chip) Perkins Jr., Manager, Regulatory Assurance at (508) 830-8323.
I declare under penalty of perjury that the foregoing is true and correct; executed on July 17, 2015.
Sincerely, Site Vice President JAD/rmb
PNPS Letter 2.15.051 Page 3 of 3 Attachments: 1. Compliance Bases for Order EA-12-051
- 2. NRC Requests for Information and Responses
- 3. NRC Audit Questions and Status
- 4. Drawing C2900 PNPS Fuel Pool Levels and References
- 5. Drawing E304 SEP Layout (partial) cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 Mr. Richard V. Guzman, Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555-000 1 Mr. John Giarrusso Jr.
Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 NRC Resident Inspector Pilgrim Nuclear Power Station Stephen Monarque, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop OWEN Washington, DC 20555-0001
Attachment 1 to Pilgrim Letter 2.15.051 Compliance Bases for Order EA-12-051 to Pilgrim Letter 2.15.051 Page 1 of 9 Compliance with Order EA-12-051 BACKGROUND On March 12, 2012, the NRC issued Order EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation(Reference 1) to Entergy Operations, Inc.
(Entergy). This Order was effective immediately and directed Entergy to install reliable SEP instrumentation as outlined in Attachment 2 of the Order at Pilgrim Nuclear Power Station (PNPS). The information provided herein documents full compliance by PNPS in response to the Order.
COMPLIANCE Entergy has installed two independent full scale level monitors in the PNPS SFP in response to Reference 1.
Entergy submitted PNPS's Overall Integrated Plan (OIP) by Reference 2. By Reference 4 the NRC provided requests for additional information (RAIs) for the OIP. Entergy provided responses to the RAIs by References 3 and 7. By Reference 6, the NRC provided its interim staff evaluation (ISE) and requested additional information necessary for completion of the review. The above cited RAI revisions impact the ISE and said RAI related discussion within the ISE. Entergy provided responses and/or updates to these ISE RAIs by References 5, 7, 8, 9, ePortal, and this submittal (per inclusion in Attachment 2 as the bridging document).
Strategies to ensure that SFP water level addition is initiated at an appropriate time and that supporting plant power systems are repowered with portable independent equipment are being established as required by implementation of Order EA-12-049 (Reference 11 ).
ACTIONS COMPLETED EC-45088 (PNPS SFP Level Instrumentation (SEPI) for NRC Order EA-12-051 ) has been implemented providing SEP level monitoring capability in the Control Room.
to Pilgrim Letter 2.15.051 Page 2 of 9 IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE PNPS Level 1: 115 feet 8 inches Level that is adequate to support operation of the normal fuel pool cooling system.
PNPS Level 2: 111 feet 3 inches Level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool and operating deck.
PNPS Level 3: 93 feet 10 inches Level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.
INSTRUMENT DESIGNED FEATURES - COMPLETE PNPS SEP level instrument loops incorporate two permanently installed, physically independent, and physically separated loops (with loop separation in accordance with existing plant design basis requirements). Sensors at the SFP are spatially separated near opposite corners of the SEP with cables both being protected by metal raceway and maintaining relative spatial separation until promptly exiting the SEP floor. Displays are installed in the Control Room. Power sources include 1) independent plant alternating current (AC) power sources, 2) loop-specific stand-alone battery power with analyzed seven-day capacity, as well as 3) connections and cables for external direct current (DC) alternate power source capability.
Equipment and raceway are mounted/installed to PNPS Seismic Category I requirements.
PROGRAM FEATURES - COMPLETE Training has been conducted as needed. Procedure 1.3.34 has been implemented to control functionality and actions for non-functionality. Routine monitoring is provided per operations log entry implementation.
MILESTONE SCHEDULE - ITEMS COMPLETE PNPS Milestones Completion Date PNPS Reliable SEPI Design Modification Package March 12, 2014 Developed/Issued (EC-45088)
PNPS Reliable SEPI Installed (startup from outage May 19, 2015)
- 1 NRC RAIs (Received June) (1.13.031) July 19, 2013 (2.13.057)
Based on the above, the requirements of Order EA-12-051 have been achieved for PNPS. A summary of PNPS's compliance with Reference 1 is provided as follows:
to Pilgrim Letter 2.15.051 Page 3 of 9 COMPLIANCE ELEMENTS
SUMMARY
In accordance with NRC Order EA-12-051, Entergy shall have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel:
(1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.
Per References 3 and 10, key SEP water levels, including the three critical levels defined in Nuclear Energy Institute (NEI) 12-02 Revision 1 were identified. Both the primary and backup instrument level loops are permanent, mounted directly within the SFP, and measure level over a single continuous span from above Level 1 down to below the upper limit of Level 3. Access to the SEP area is not required to operate the instrument loops or obtain level data. Displays and signal processors are located in the control room. The three critical levels for PNPS are as follows:
LEVEL 1: Level 1 is the level adequate to support operation of the normal SEP cooling system associated with the level at which reliable pump suction loss occurs due to uncovering the coolant inlet pipe or any weirs or vacuum breakers since it is more limiting than level associated with pump net positive suction head requirements. This level, is established for PNPS based on nominal coolant inlet pipe elevation [as it does not incorporate a vacuum (or siphon breaker)]. The elevation associated with this level is 115 feet 8 inches.
LEVEL 2: Level 2 is the level adequate to provide substantial radiation shielding for a person standing on the SEP operating deck. Entergy selected the ten-foot option which has been determined by the NRC to meet the requirements of the order with no further evaluation or review required. Pilgrim then decided to make Level 2 the same as the current Technical Specification Limit which is approximately 19 feet above the top of the fuel racks. Procedure 1.16.1 "Spent Fuel Pool Non-SNM Inventory Control" provides controls for irradiated material and equipment stored in the SEP. Because Level 2 has been chosen as nineteen feet (greater than the ten feet requirement) above the highest point of any fuel rack seated in the SEP, no additional analysis is required. Additionally, the PNPS ELEX strategy ensures that activities in the proximity of the SEP are completed prior to the calculated time to boil and thus prior to reduction of SEP level; therefore, this strategy ensures that necessary operations in the vicinity of the SEP can be completed without significant dose consequences. The elevation associated with this level is 111 feet 3 inches.
LEVEL 3: Level 3 is the level where fuel remains covered. It is defined as the highest point of any fuel rack seated in the SEP (within +/- one foot). The highest point (nominal) of any fuel rack seated in the SFP is 92 feet 10 inches. Therefore, Level 3 is elevation is 93 feet 10 inches.
to Pilgrim Letter 2.15.051 Page 4 of 9
- 1. In accordance with NRC Order EA-12-051, the SFP level instrumentation shall include the following design features:
- a. Instruments: The instrumentation shall consist of a permanent, fixed primary instrument channel and a backup instrument channel. The backup instrument channel may be fixed or portable.
Per References 3 and 10, both PNPS primary and backup SFP level instrument loops are fixed or permanently installed. Both instrument probes are permanently installed within one foot of the northwest and southwest corners of the SEP. Both instrument displays/processors are permanently installed in the Control Room.
- b. Arrangement: The SFP level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP. This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the SFP area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the SFP structure.
Per References 8 and 10, and in accordance with the guidance of Section 3.2 of NEI 12-02 Revision 1, PNPS primary and backup SEP level instrument probes are spatially separated and installed within one foot of separate SEP corners. Corner locations provide inherent protection of the probes. Loop separation for cable routing away from the probes maintains the same relative spatial separation distance as the SEP corner mounting locations. Loop routing on the SEP floor is limited with prompt exit to below the SEP floor. Probe top section and loop cabling are protected by metallic raceway and the probe mounting bracket structure itself, all of which incorporate a low profile design.
Concrete curbs in the vicinity that rise a few inches above floor elevation provide additional inherent protection. Additional protection is provided by the Auxiliary bridge which is generally 'parked' at the west end of the SEP above the probes. As described, reasonable protection of the SEP level function is provided from potential SEP area overhead structure missiles.
- c. Mounting: Installed instrument channel equipment within the SFP shall be mounted to retain its design configuration during and following the maximum seismic ground motion considered in the design of the SFP structure.
Per References 3 and 8, the entire PNPS SEP instrument loop (equipment from the SEP to the Control Room) is mounted and designed to requirements equal to or greater than PNPS seismic design bases, seismic category I requirements. As such, the SEP instrument loops are designed and installed to retain their design configuration during and following maximum requirements of the PNPS seismic design bases.
to Pilgrim Letter 2.15.051 Page 5 of 9
- d. Qualification: The primary and backup instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the SFP water at saturation conditions for an extended period. This reliability shall be established through use of an augmented quality assurance process (e.g., a process similar to that applied to the site fire protection program).
Per References 3 and 10, the entire PNPS SFP instrument loop (equipment from the SFP to the Control Room) is designed and qualified to PNPS environmental extremes applicable for the area of interest (e.g., SFP, Control Room). The SFP area environmental extremes are in accordance with NEI 12-02 Revision 1 SEP example conditions. The SFP instrumentation loops have been designated as Augmented Quality per Entergy processes covering procurement, design, and installation. As such, the SEP instrument loops have demonstrated reliability through establishment of Augmented Quality processes at applicable environmental extremes.
- e. Independence: The primary instrument channel shall be independent of the backup instrument channel.
Per References 8 and 10, the SEP instrument loops have highly reliable independent power sources (as described in Section f below) and loop independence achieved by incorporation of two permanently installed, physically independent, and physically separated loops (with loop separation in accordance with existing plant design basis requirements) that are designed and installed to seismic category I requirements (as described in Section "c" above). As such, the SEP instrument loops are independent.
- f. Power supplies: Permanently installed instrumentation channels shall each be powered by a separate power supply. Permanently installed and portable instrumentation channels shall provide for power connections from sources independent of the plant AC and DC power distribution systems, such as portable generators or replaceable batteries. Onsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.
Per References 8 and 10, the two PNPS SEP instrument loops are powered from opposing power AC power sources. Power is supplied for one loop (LI-4816B) from 120 VAC Panel Y1. Power is supplied for the other loop (LI-4816A) from 120 VAC Panel Y2.
The two PNPS SEP instrument channels incorporate independent plant power sources
[not only originating from different buses (NEI 12-02 required) but also from different power divisions (NEI 12-02 preferred) as well as incorporating loop-specific stand-alone backup battery power of sufficient capacity (NEI 12-02 acceptable in and of itself coupled with power restoration strategy)]. The permanently installed replaceable and rechargeable backup batteries are configured for an analyzed seven-day capacity. A third power alternative is available per external connections and cables included for each battery panel supplying each SEP processor/display panel to permit powering the system from an external DC source independent of plant sources.
to Pilgrim Letter 2.15.051 Page 6 of 9 As such, the SEP instrument loops have highly reliable power sources, originating from separate power sources, with power capability independent from plant sources, and with on-board battery capacity analyzed for full event duration (e.g., seven days) or maximum offsite resource availability time frames which is well beyond FLEX strategy restoration time frames. An installed alternate power source is provided for instrument loop power with sufficient capacity to maintain the level indication function for full event duration including until offsite resource availability is reasonably assured.
SIMPLIFIED DIAGRAM SHOWING THE INDEPENDENT NORMAL POWER SUPPLIES AND THE INDEPENDENT BACKUP BATTERIES A6 via X-22 S X-21 X-21 81Bi 15 via M'G Set B1X51via J1 .... . ...
Iu-48168 o-48168 717 L 4816Aj 14816A
- g. Accuracy: The instrument channels shall maintain their designed accuracy following a power interruption or change in power source without recalibration.
Per Reference 10, the SEP instrument loops have a high certified design accuracy of equal to or better than +/- three inches which is not affected by power interruption as supported by vendor test documentation. As such, the SEP instrument loops have been documented to maintain their designed accuracy following power interruption or change in power source without recalibration being required.
to Pilgrim Letter 2.15.051 Page 7 of 9
- h. Testing: The instrument channel design shall provide for routine testing and calibration.
Per References 3, 8, and 10, the SEP instrument loops automatically monitor the integrity of the measurement system using in-situ capability or on board diagnostics.
Deviation of measured test parameters from manufactured or as-installed configuration beyond a configurable threshold prompts operator intervention. The probe itself is a perforated tubular coaxial waveguide with defined geometry and is not calibrated. Loop design provides capability for calibration or validation against known/actual SFP level.
As such, the SEP instrument loop's design provides for routine testing and calibration.
i.Display: Trained personnel shall be able to monitor the SFP water level from the control room, alternate shutdown panel, or other appropriate and accessible location. The display shall provide on-demand or continuous indication of SFP water level.
Per Reference 10, the PNPS SEP instrument loop displays are located in the PNPS Control Room. Level is displayed continuously when on primary AC power and on-demand when on backup DC power. As such, the SEP water level indication can be monitored by trained personnel from the Control Room either continuously or on-demand.
- 2. In accordance with NRC Order EA-12-051, the SFP instrumentation shall be maintained available and reliable through appropriate development and implementation of the following programs:
- a. Training: Personnel shall be trained in the use and the provision of alternate power to the primary and backup instrument channels.
Two PNPS instrument and control maintenance technicians received training on the MOHR EFP-IL SEP Level Monitoring System at the vendor (MOHR) facilities.
Presentation, EC-45088 PNPS SEP Instrumentation, and Section 2.6.13 of System Training Manual 1-73, SFP Instrumentation, training has been provided to operations, the necessary members of the emergency response organization, chemistry, and radiation protection personnel.
Training on alternate power sources (on board seven day battery capacity, external DC power source capability, primary AC safety-related EDG and battery-backed power source restoration per ELEX strategies) has been addressed initially by the above. It is noted that ELEX strategies are being established as required by implementation of Order EA-1 2-049 (Reference 11 ).
On-site training is governed by Entergy Training processes including Systematic Approach to Training for both initial and continuing elements and target audience.
to Pilgrim Letter 2.15.051 Page 8 of 9
- b. Procedures: Procedures shall be established and maintained for the testing, calibration, and use of the primary and backup SFP instrument channels.
The calibration and test procedure developed by MOHR is provided in their technical manual. The objectives are to measure system performance, determine if there is a deviation from normal tolerances, and return the system to normal tolerances.
Diagnostic procedures developed by MOHR are provided as automated and semi-automated routines in system software alerting the operator to abnormal deviation in selected system parameters such as battery voltage, 4-20 mA loop continuity, and TDR waveform of the transmission cable. The technical objective of the diagnostic procedures is to identify system conditions that require operator attention to ensure continued reliable liquid level measurement. Manual diagnostic procedures are also provided in the event that further workup is determined to be necessary.
Maintenance procedure 8.E.19 has been revised to address the functional check of the SFP level instruments. The procedure allows a technician trained in the EFP-IL system maintenance to ensure that system functionality is maintained.
Operations procedure 2.2.85 "Fuel Pool Cooling and Filtering System" provides sufficient instructions for operation of the equipment.
- c. Testing and Calibration: Processes shall be established and maintained for scheduling and implementing necessary testing and calibration of the primary and backup SFP level instrument channels to maintain the instrument channels at the design accuracy.
SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness will be established in accordance with Entergy's processes and procedures and vendor recommendations.
This will ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit).
to Pilgrim Letter 2.15.051 Page 9 of 9 REFERENCES
- 1. NRC Order Number EA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool (SFP) Instrumentation, dated March 12, 2012 (1.12.015) (ML12054A679).
- 2. OIP in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable SFP Instrumentation (Order Number EA-1 2-051 ), dated February 28, 2013 (2.13.014) (ME13063A097)
- 3. Response to Request for Additional Information for the Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ), dated July 19, 2013 (2.13.057) (ML13207A142)
- 4. Request for Additional Information for the Overall IntegratedPlan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ), dated June 20, 2013 (1.13.031 )
- 5. Pilgrim Nuclear Power Station's First Six-Month Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation(Order Number EA-12-051 ), dated August 28, 2013 (2.13.070)
- 6. Pilgrim Nuclear Power Station - Interim Staff Evaluation And Request For Additional Information Regardling The Overall Integrated Plan For Implementation Of Order EA 051, "Issuance Of Order To Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation"(TAC NO. MF0778), dated December 5, 2013 (1.13.065)
- 7. Pilgrim Nuclear Power Station's Second 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 (2.14.01 2)
(ML1 406gA307)
- 8. Pilgrim Nuclear Power Station's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ), dated August 28, 2014 (2.14.062)
- 9. Pilgrim Nuclear Power Station's Fourth 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 27, 2015 (2.15.006)
- 11. Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (Order Number EA-1 2-049), dated March 12, 2012 (1.12.013) (ML12054A736)
Attachment 2 to Letter 2.15.051 NRC Requests for Information and Responses to Letter 2.15.051 Page 1 of 27 NRC Requests for Information As stated in Attachment 1, Entergy submitted PNPS's Overall Integrated Plan (OIP) by Attachment 1, Reference 2 and minor updates per References 5, 7, 8, and 9 of Attachment.
By Reference 4 of Attachment 1 the NRC provided requests for additional information (RAIs) for the OIP. Entergy provided responses to the RAls by Reference 3.
RAI RAI Response Number RAl-1 .a A clearly labeled sketch depicting the The requested information is provided in Attachments 4 and 5. The attachments indicate elevation view of the proposed typical Levels 1, 2, and 3 as well as the approximate location of the proposed mounting bracket mounting arrangement for the portions incorporating the Seismic Category I attachment. The sensor is a perforated tubular of instrument channel consisting of coaxial waveguide that provides continuous level measurement axially and is sensitive permanent measurement channel over its entire length. These sketches apply to both the primary and backup loops.
equipment (e.g., fixed level sensors The spent fuel pool (SFP) level lower instrument span or probe bottom extends down to and/or stilling wells, and mounting at least three inches below the upper limit of the range of Level 3 to account for loop brackets). Indicate on this sketch the accuracy or instrument loop uncertainty. Therefore, the SEP level probe bottom/span datum values representing Level 1, extends down to at least elevation 93 feet 6 inches (see Figure 1). The SEP level upper Level 2, and Level 3 as well as the top instrument span, at a minimum, includes normal water level high alarm. Note that Level of the fuel. Indicate on this sketch the 3 is shown in accordance with Nuclear Energy Institute (NEI) 12-02 Revision 1 guidance portion of the level sensor relative to the top of the rack; the top of the fuel is not shown.
measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.
I -I-RAl-1 .b The OIP states, "Other hardware stored NEI 12-02 gives two options to determine Level 2. The first option defines Level 2 as ten in the SFP will be evaluated to ensure feet above the highest point of any fuel rack, based on the guidance in Regulatory Guide that it does not adversely interact with 1.13, Revision 2. The second option states that Level 2 is based on the need to provide the SFP instrument probes during a adequate radiation shielding to maintain personnel radiological dose levels within seismic event." Given the potential for acceptable limits while performing local operations in the vicinity of the pool. The varied dose rates from other materials evaluation of the level needed to provide personnel protection should consider the scope to Letter 2.15.051 Page 2 of 27 RAI RAI Response Number stored in the SFP, describe how level 2 of the local operations, including installation of portable FLEX components, along with will be adjusted to other than the the emergency conditions that may apply at the time of operator actions.
elevtio prvide insecion abve. Level 2 has been adjusted to account for materials stored in the SEP by specifying Level 2 at the Technical Specification minimum limit (refer to Attachment 4).
RAI-2.a The design criteria that will be used to The loading on the probe mount and probe body includes both seismic and estimate the total loading on the hydrodynamic loading using seismic response spectra that bounds the Pilgrim design mounting device(s), including static basis maximum seismic loads applicable to the installation location(s). The static weight weight loads and dynamic loads, load is also accounted for in the modeling described below but is insignificant in Describe the methodology that will be comparison to seismic and hydrodynamic loads. Analytic modeling is being performed used to estimate the total loading, by the instrument vendor using Institute of Electrical and Electronic Engineers IEEE 344-inclusive of design basis maximum 2004 methodology.
seismic loads and the hydrodynamic Thsipeuioysrcueothprbasebymkitaandtefrnltc loads that could result from poolThsipeuioysrcueothprbasebymkitaandtefrnltc sloshing or other effects that could modeling and the dimensions of the probe and complex hydrodynamic loading terms in accompany such seismic forces. any case preclude meaningful physical testing.
A detailed computational SEP hydrodynamic model has been developed for the instrument vendor by Numerical Applications, Inc., author of the GOTHIC computational fluid dynamics code. The computational model accounts for multi-dimensional fluid motion, pool slosh ing, and loss of water from the pool.
Seismic loading response of the probe and mount is separately modeled using finite element modeling software. The GOTHIC-derived fluid motion profile in the pool at the installation site and resultant distributed hydrodynamic loading terms are added to the calculated seismic loading terms in the finite element model to provide a conservative estimate of the combined seismic and hydrodynamic loading terms for the probe and probe mount, specific to the chosen installation location for the probe.
RAI-2.b A description of the manner in which The proximal portion of the level probe is designed to be attached near its upper end the level sensor (and stilling well, if (refer to vendor schematic Figure 2) to a Seismic Category I mounting bracket
______appropriate) will be attached to the configured to suit the requirements of a particular SEP. The bracket may be bolted to Letter 2.15.051 Page 3 of27 RAI RAI Response Number refueling roof and/or other support and/or welded to the SFP deck and/or SEP liner/wall according to the requirements of structures for each planned point of the particular installation per Seismic Category I requirements.
attachment of the probe assembly.
Indicate in a drawing the portions of the level sensor that will serve as points of attachment for mechanical/mounting and electrical connections.
RAI-2.c A description of the manner by which See RAI-2.b response above.
the mechanical connections will attach the level instrument to permanent spent fuel pool structures so as to support the level sensor assembly.
RAI-2.d Address how other hardware stored in An evaluation of non-special nuclear material inventory located in the SFP will be the SEP will not create adverse performed during the SEPI modification process. Non-special nuclear material access to interaction with the fixed instrument the SEP is governed by Procedure 1.16.1, Spent Fuel Pool Non-SNM Inventory Control.
location(s). This procedure will be used to prevent any instrument interference from non-special nuclear materials. Special nuclear materials are stored in SEP racks, under the administrative controls of EN-NF-200 RAI-3.a A description of the specific method or As stated in NEI 12-02, "Components in the area of the SEP will be designed for the combination of methods that will be temperature, humidity, and radiation levels expected during normal, event, and post-applied to demonstrate the reliability of event conditions .... " Components in other areas are planned to be designed for their the permanently installed equipment corresponding maximum conditions. The discussion below describes the testing and under Beyond-Design-Basis (BDB) qualification intended to demonstrate equipment reliability as needed for the expected ambient temperature, humidity, shock, conditions associated with the SEP level loop active components (signal processor and vibration, and radiation conditions. probe assembly including vendor-supplied hardline coaxial cable pigtail). Class 1 E nuclear-qualified interconnecting coaxial cable is planned to be utilized between the vendor-supplied probe coaxial cable pigtail and the signal processor / display located in the Control Room Annex adjacent to the Main Control Room door (an area that is classified as a mild environment).
to Letter 2.15.051 Page 4 of 27 RAI RAI Response Number Temperature:
Signal processor: Designed for mild environment installation. Physical testing in an environmental chamber to demonstrate normal operation at the operating temperatures specified for the instrument.
Probe assembly: Qualification by materials properties and use history of substantially similar probe designs in steam generator applications at significantly higher temperatures and pressures and saturated steam environments.
Humidity:
Signal processor: Designed for mild environment installation. Physical testing in an environmental chamber to demonstrate normal operation at the operating humidity specified for the instrument.
Probe assembly: Qualification by materials properties and use history as noted above.
Shock:
Signal processor: Physical testing to commercial and/or military standards using shake-table and drop testing.
Probe assembly: Finite element analysis in conjunction with seismic modeling described above.
Vibration:
Signal processor: Physical testing to applicable commercial and/or military standards using shake-table and drop testing.
Probe assembly: The probe assembly and bracket together form a simple static unibody structure with intrinsic vibration resistance that is additionally subject to substantial damping due to the surrounding water medium. This is planned to be modeled using finite element modeling in conjunction with seismic modeling described above.
Radiation:
Sia Drcssr Th sin Ipoesri ntle na idevrnetwt aito to Letter 2.15.051 Page 5 of 27 RAI RAI Response Number levels similar to background radiation, with the acknowledgement that the radiation limit for the signal processor is similar to other commercial-grade complementary-metal-oxide-semiconductor (CMOS)-based electronics. Radiation testing is not planned. It should be noted that the instrument performs self-diagnostics before measurements are obtained and the electronics are easily accessible for periodic replacement.
Probe assembly: Materials properties qualification is used.
RAI-3.b A description of the testing and/or Signal processor (electronics): Triaxial shake-table testing is planned to be performed analyses that will be conducted to by the vendor to envelope seismic category 1 safe shutdown earthquake (SSE) provide assurance that the equipment conditions or Pilgrim design basis maximum seismic loads (relative to the location where will perform reliably under the worst- the equipment is mounted) using IEEE-344-2004 methodology.
case credible design basis loading at Probe assembly (level sensor): Seismic and hydrodynamic finite element analysis is the location where the equipment will performed by the vendor using relevant IEEE 344-2004 methodology (using enveloping be mounted. Include a discussion of seismic category 1 SSE conditions or Pilgrim design basis maximum seismic loads this seismic reliability demonstration as relative to the location where the equipment is mounted), as described in the RAI-3.a it applies to (1) the level sensor response above mounted in the spent fuel pool area, and (2) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
RAI-3.c A description of the specific method or combination of methods that will be With respect to the probe assembly, combined seismic and hydrodynamic analysis will used to confirm the reliability of the be used to demonstrate that the probe waveguide's geometric dimensions do not change permanently installed equipment such significantly as a result of the seismic conditions. In the absence of alteration to the that following a seismic event, the geometric configuration of the probe waveguide there is no mechanism for seismic instrument will maintain its required excitation of the probe assembly to alter system accuracy.
accuracy. The accuracy of system electronics will be demonstrated following seismic excitation as
_______ ___________________________part of the seismic testing protocol.
to Letter 2.15.051 Page 6 of 27 RAI RAI Response Number RAI-4.a A description of how the two channels The primary instrument (Loop A) will be in the southwest corner of the SEP and the of the proposed level measurement backup instrument (Loop B) will be in the northwest corner of the SEP. Locating the new system meet this requirement so that instruments in the corners of the SEP takes advantage of missile and debris protection the potential for a common cause event inherent in the corners. Loop A and B displays will be located in the Control Room to adversely affect both channels is Annex adjacent to the Control Room door.
minimized to the extent practicable.
The conceptual design provides two independent level instruments in the SEP with cabling routed to two display/processors mounted in the Main Control Room Annex by the door to the Main Control Room. The Control Room Annex is classified as a mild environment. Power for each loop is provided from independent 120 VAC, 60 Hz power sources. Backup power is provided by a battery capable of providing continuous display operation for at least three days. The battery will be provided with the display/processor.
The design prevents failure of a single loop from causing the alternate loop to fail. Loop separation and independence are maintained consistent with existing design basis requirements.
-I-RAI-4.b Eurther information on how each level The design provides two identical non-safety related wide-range level instruments which measurement system, consisting of feed two independent trains of non-safety cable and indicators to provide a highly reliable level sensor electronics, cabling, and remote display of SEP water level in the Control Room Annex. Physical separation of readout devices will be designed and the two loops will be accomplished by separately routing cable and conduit as much as installed to address independence practical. The use of conduit on refueling floor will provide additional protection from through the application and selection of damage due to debris during a BDB event.
independent power sources, independence of signals sent to the location(s) of the readout devices, and Each display/processor will have a battery installed in the display enclosure which is the independence of the displays. capable of providing power for at least three days.
to Letter 2.15.051 Page 7 of 27 RAI RAI Response Number See RAI-4.a response above.
+/-
RAI-5 Please provide the design criteria that The sample rate estimates have been developed by the vendor using conservative will be applied to size the backup instrument power requirements and measured battery capacity with draw-downs during battery in a manner that ensures, with and following exposure of the batteries to their maximum operating temperature for up to margin, that the channel will be seven days. The instrument configuration is planned to be established for an automated available to run reliably and sample rate when under battery power consistent with seven days continuous operation.
continuously following the onset of the Permanent installed battery capacity for seven days continuous operation is planned BDB event for the minimum duration consistent with NEI 12-02 duration without reliance on or crediting of potentially more needed, consistent with the plant rapid FLEX Program power restoration. Batteries are readily replaceable via spare stock mitigation strategies for beyond-design- without the need for recalibration to maintain accuracy of the instrument. These basis external events (Order EA measures ensure adequate power capacity and margin.
049).
RAI-6.a An estimate of the expected instrument The instrument loop level accuracy will be specified as less than + 3.0 inches for all channel accuracy performance (e.g., in expected conditions.
% of span) under both (a) normal spent The expected instrument loop accuracy performance would be approximately +/-1 % of fuel pool level conditions (approximately span (based on the sensitive range of the detector).
Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SEP level were at the Level 2 and level 3 datum points.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
RAI-6.b A description of the methodology that In general relative to normal operating conditions, any applicable calibration procedure will be used for determining the tolerances (or acceptance criterion) are planned to be established based on maximum allowed deviation from the manufacturer's stated/recommended reference accuracy (or design accuracy). The instrument channel design accuracy methodology used is planned to be captured in plant procedures and/or programs that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that
________the channel requires adjustment to ________________________________________
to Letter 2.15.051 Page 8 of 27 RAI RAI Response Number within the normal condition design accuracy.
RAI-7.a A description of the capability and The level instrument automatically monitors the integrity of its level measurement system provisions the proposed level sensing using in-situ capability. Deviation of measured test parameters from manufactured or as-equipment will have to enable periodic installed configuration beyond a configurable threshold prompts operator intervention.
testing and calibration, including how this capability enables the equipment to Periodic calibration checks of the signal processor electronics to extrinsic National be tested in-situ. Institute of Standards and Technology (NIST)-traceable standards can be achieved through the use of standard measurement and test equipment.
The probe itself is a perforated tubular coaxial waveguide with defined geometry and is not calibrated. It is planned to be periodically inspected electromagnetically using time-domain reflectometry (TDR) at the probe hardline cable connector to demonstrate that the probe assembly meets manufactured specification and visually to demonstrate that there has been no mechanical deformation or fouling.
RAI-7.b A description how such testing and Each instrument electronically logs a record of measurement values over time in non-calibration will enable the conduct of volatile memory that is compared to demonstrate constancy, including any changes in regular channel checks of each pool level, such as that associated with the normal evaporative loss/refilling cycle. The independent channel against the other, loop level measurements can be directly compared to each other (i.e., regular cross-loop and against any other permanently- comparisons). The two displays are installed in close proximity to each other, thus installed spent fuel pool level simplifying cross loop checks. Direct measurements of SEP level may be used for instrumentation, diagnostic purposes if cross-loop comparisons are anomalous.
RAI-7.c A description of the calibration and Performance tests (functional checks) are automated and/or semi-automated (requiring functional checks that will be limited operator interaction) and are performed through the instrument menu software performed, the frequency at which they and initiated by the operator. There are a number of other internal system tests that are will be conducted with a discussion on performed by system software on an essentially continuous basis without user the measures taken to detect when the intervention but which can also be performed on an on-demand basis with diagnostic instrumentation is operable but output to the display for the operator to review. Other tests such as menu button tests, degraded, and how these surveillances level alarm, and alarm relay tests are only initiated manually by the operator.
will be incorporated into the plant Performance checks are described in detail in the Vendor Operator's Manual, and the surveillance program. applicable information is planned to be contained in plant operating procedures.
to Letter 2.15.051 Page 9 of 27 RAI RAI Response Number Performance tests are planned to be performed periodically as recommended by the equipment vendor, for instance quarterly but no less often than the calibration interval of two years.
Loop functional tests per operations procedures with limits established in consideration of vendor equipment specifications are planned to be performed at appropriate frequencies established equivalent to or more frequently than existing spent fuel pool instrumentation.
Manual calibration tests are as described above in RAI-7a and b.
Manual calibration and operator performance checks are planned to be performed in a periodic scheduled fashion with additional maintenance on an as-needed basis when flagged by the system's automated diagnostic testing features.
Loop calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications are planned to be performed at frequencies established in consideration of vendor recommendations.
RAI-7. d A description of the preventative Periodic (e.g., quarterly or monthly) review of the system level history and log files and maintenance tasks required to be routine attention to any warning message on the system display is recommended by the performed during normal operation, and vendor. Formal calibration checks are recommended by the vendor on a two-year the planned maximum surveillance interval to demonstrate calibration to external NIST-traceable standards. Formal interval that is necessary to ensure that calibration check surveillance interval and timing would be established consistent with the channels are fully conditioned to applicable guidance [i.e., NEI 12-02 Section 4.3; on a refueling outage interval basis and accurately and reliably perform their within 60 days of a planned refueling outage]. Items such as system batteries are functions when needed. planned to be assessed under the Preventive Maintenance (PM) program for establishment of replacement frequency. Surveillance/PM timing/performance are planned to be controlled via tasks in the PM program.
RAI-8 Please provide a description of the Vendor recommended inspection, maintenance, and repair procedures for the liquid level standards, guidelines and/or criteria measurement system have been developed through the vendor's 30-year experience that will be utilized to develop developing and manufacturing liquid level measurement and cable testing
_____-procedures for inspection, instrumentation. These are for the most part specific to the system's proprietary to Letter 2.15.051 Page 10 of 27 RAI RAI Response Number maintenance, repair, operation, electronics, subject to relevant industry standards for electronics fabrication and abnormal response, and administrative inspection and vendor's quality management system.
controls associated with the Spent Fuel Pool level instrumentation, as well as storage and installation of portable Where relevant, standards for naval shipboard liquid level indicating equipment have instruments. been used to develop procedures for operation, abnormal response, and administrative controls.
Portable instrumentation is not utilized. Both primary and backup SEPI loops incorporate permanent hard-wired installation.
The specific procedures to be used to capture the required activities described in this RAI response have not yet been developed but are planned to be developed in accordance with the vendor recommendations and Entergy processes and procedures.
RAI-9. a Further information describing the See RAI-6, 7, and 8 responses above for related descriptions of associated maintenance maintenance and testing program the and testing program details. SFPI loop/equipment maintenance/preventative licensee will establish and implement to maintenance and testing program requirements to ensure design and system readiness ensure that regular testing and are planned to be established in accordance with Entergy's processes and procedures calibration is performed and verified by and in consideration of vendor recommendations to ensure that appropriate regular inspection and audit to demonstrate testing, loop checks, functional tests, periodic calibration, and maintenance is performed.
conformance with design and system Subject maintenance and testing program requirements are planned to be developed readiness requirements. Include a during the SFPI modification design process.
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.
-*1 RAI-9. b A description of how the guidance in Both primary and backup SFPI loops incorporate permanent installation (with no reliance NEI 12-02 section 4. 3 reciardincQ on portable, post-event installation) of relatively simple and robust augmented quality v v to Letter 2.15.051 Page 11 of 27 RIg, RA*I
Response
Number compensatory actions for one or both equipment. Permanent installation coupled with stocking of adequate spare parts non-functioning channels will be reasonably diminishes the likelihood that a single loop (and greatly diminishes the addressed. likelihood that both loops) is (are) out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:
Channe I(s) Compensatory Action Out-of- Required Restoration if Required Restoration Action not Service Action completed within Specified Time 1 Restore channel to Immediately initiate action in functional status within accordance with Note below.
90 days (or if channel restoration not expected within 90 days, then proceed to Compensatory Action).
2 Initiate action within 24 Immediately initiate action in hours to restore one accordance with Note below.
channel to functional status. Restore one channel to functional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Note: Present a report to the on-site safety review committee within the following 14 days. The report shall outline the planned alternate method of monitoring, the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.
RAI-9.c A description of what compensatory jThe requested information is provided in the RAI-9.b response.
to Letter 2.15.051 Page 12 of 27 RAI Response Number arepanndintevntha action actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.
to Letter 2.15.051 Page 13 of 27 PNPS Bridging Document between Vendor Technical Information and Licensee Use Based on NRC Staff Requests for Additional Information RA*,s) and NRC Vendor Audit
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results Design Specification SEPI References Evaluation of vendor information is within the Requirements 4-13, 17- scope of EC 45088 (Reference 36).
derived from 18, 37-38 References 1, 2,& 3 2 Test Strategy Per References The equipment testing performed for the SFPI Requirements 4, 6-13, 17- has been found to be acceptable based on the in References 18, 37-38 current design requirements 1,2,& 3 3 Environmental 60-11 0°F Reference 14-131 °F The SEPI sensor electronics are embedded in the Qualification for (References 4 SEPI Processor/Display in the Control Room.
Electronics 1, 2, & 29) Calculation M1382 (Reference 29) demonstrates Enclosure with that successful implementation of the FLEX Display strategy results in the Control Room temperature remaining below 1 10°F during an extended loss of AC power. This is acceptable as MOHR has tested its system electronics to operate in a nominal temperature range of 14°F to 131°F. The sensor electronics is capable of continuously performing its required function under the expected temperature conditions. Results of the vendor testing are available in proprietary MOHR Report 1-0410-1 Rev. 0, MOHR EFP-IL SEPI System Temperature and Humidity Report (Reference 4).
5-95% RH Reference 5-95% RH The SEPI vendor, MOHR, has successfully tested 4 its system electronics to operate in a humidity
__________ ________ _________ __________ range of 5% to 95% relative humidity. Results of to Letter 2.15.051 Page 14 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results the vendor testing are available in proprietary MOHR Report 1-0410-1, MOHR EFP-IL SEPI System Temperature and Humidity Report (Reference 4).
Humidity on the Control Building 37' elevation is normally regulated by the Control Building HVAC system. During an extended loss of AC power, the Control Building HVAC system is no longer available. In this situation the relative humidity is expected to drop, because the heat loads in the Control Building 37' elevation are dominated by the sensible heat of electrical equipment.
According to a psychometric chart, an increase in the dry bulb temperature (due to sensible heat gain) results in a decrease in relative humidity, given a constant mass of water per mass of air (humidity ratio). Because the FLEX strategy does not require outside air to be circulated into the Control Building 37' elevation level (Reference 41) the humidity is not expected to rise to levels that challenge the operation of the SEPI instrumentation. Therefore, the operational humidity range of 5% to 95% encompasses all expected conditions for the SFPI display location.
The sensor electronics is capable of continuously performing its required function under the expected humidity conditions.
No radiation N/A Acceptable, the Control Building is considered a effects mild environment with no expected radiation. No additional testing is required per NRC Audit to Letter 2.15.051 Page 15 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results Report for MOHR (Reference 40).
4 Environmental 60-212°F Reference RAD TID is 480°F long- The NRC Audit Report for MOHR (Reference 40)
Testing for Level (References 5 the total 40 term for concludes that the SFP-1 probe is suitable for Sensor Components 1, 2, & 14) yr dose plus PEEK operation in the SEP environment.
in SFP Area- the 7 day Insulators Submerged Portion Submerged Reference worst case PEEK The SEP is expected to remain at or above the of Probe Body Component 5 accident Insulators minimum ambient temperature (60 0 F) as called (References 1 dose at the capable of out in UFSAR (Reference 14) Table 10.9-1.
& 2) lowest long term Maximum accident condition of the spent fuel pool spacer submergence is taken to be 212°F boiling water/steam at location on atmospheric pressure. Based on the vendor the Probe analysis results, the sensitive materials in the body probe body will not be challenged under the required conditions 1, 2, and 14 and are acceptable.
1 .05E8 rad Reference 10 Grad for The NRC Audit Report for MOHR (Reference 40)
TID 5 PEEK concludes that the SEP-i probe is suitable for (References Insulators operation in the SEP environment.
1,2, & 16)
Calculation S&SA202 (Reference 16) defines a worst case dose of approximately 1 .05E8 rad to the probe via the applicable requirements of References 1 and 2. As such, the PEEK spacers are suitable for the application.
5 Environmental 60-212°F Reference Rad TID is PEEK: 480°E The NRC Audit Report for MOHR (Reference 40)
Testing for Level (References 5 the total 40 EPDM: 194 0 E concludes that the SEP-i probe is suitable for Sensor Electronics 1, 2, & 14) yr dose plus long-term, 12 operation in the SEP environment.
Housing-Probe the 7day day @311°F Head located Above worst case Sylgard 170: The SEP area is expected to remain at or above
___the SEP accident 392°E long- the minimum ambient temperature (60°F) as to Letter 2.15.051 Page 16 of 27
- Topic Parameter Vendor ~Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results dose at the term called out in the UFSAR (Reference 14) Table location 10.9-1. Maximum accident condition temperature and humidity directly above the spent fuel pool is taken to be a condensing steam environment which conservatively will be no greater than 212 0 F, the temperature of boiling water at atmospheric pressure. Based on the vendor analysis results the sensitive materials in the probe head will not be challenged under the required conditions of Reference 1, 2, and 14, and are acceptable.
For coaxial transmission cable beyond the Probe Head, MOHR uses Class 1 E Nuclear Safety Related RSCC Wire & Cable RSS-6-1 10A/LE which meets the requirements of Institute of Electrical and Electronic Engineers (IEEE) 383-1974, "IEEE Standard for Type Test of Class 1 E Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations" and is acceptable (Reference 40).
0-100% RH Reference 0-100% RH The NRC Audit Report for MOHR (Reference 40)
Condensing 5 for PEEK, concludes that the SFP-1 probe is suitable for (References 1 EPDM and operation in the SFP environment.
&2) Sylgard 170 100% non-condensing RH is a conservative humidity range for normal operating conditions.
Based on the vendor analysis results, the sensitive materials in the probe head will not be challenged under the required conditions of References 1 and 2, and are acceptable.
to Letter 2.15.051 Page 17 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results 8.42E5 rad Reference PEEK: 10 The NRC Audit Report for MOHR (Reference 40)
TID 5 Grad concludes that the SFP-1 probe is suitable for (Reference EPDM: 2 operation in the SEP environment.
- 16) Grad Sylgard 170: S&SA202 (Reference 16) defines a worst case 200 Mrad dose of approximately 8.42E5 rad. Based on the vendor analysis results, the sensitive materials in the probe head will not be challenged under the required conditions of Reference 1, 2, and 16, and are acceptable.
6 Thermal & Radiation See Topics #4 Reference See above Acceptable, vendor test/analysis bound licensee Aging-Organic & 5 above 5 Topics #4 and parameters, see discussion above in Topics #4 Components in SFP 5 and 5.
Area 7 Basis for Dose References 1 N/A Entergy Calculation Procedure EN-DC-126 Requirement &2 (Reference 15) was used to develop S&SA202 (Reference 16) based on the requirements of NEI 12-02 (Reference 2) and EA-12-051 (Reference 1). The calculation determines the dose for various locations and SEP water levels for both a 7 day accident scenario and 40 year TID.
8 Seismic Seismic Class Reference Seismic Class Acceptable, MOHR has prepared a series of Qualification I (References 9 & 12 1 seismic qualification reports for the SEP level 1, 2,3. & 14) instrument. The qualification reports envelop all components of the new SEP level instrumentation required to be operational during a BDBEE and post-event. These documents are MOHR Reports 1-0410-6 (Reference 9) and 1-0410-9 (Reference 12).
_____________________________________________Calculation C1 5.0.3625 (Reference 30) was to Letter 2.15.051 Page 18 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results prepared in accordance with EN-DC-126 (Reference 15) and accounts for seismic loads. It shows that the SFPI Probe Mounting Bracket is structuraiiy adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0).
9 Sloshing Water References See Topic #8 Acceptable, the MOHR seismic qualification induced 12, 17, & reports (References 9 & 12) in combination with motion from 18 NAI Report # NA1-1725-003 (Reference 17), NAI seismic event Report # NAI-1 725-004 (Reference 18) and NAI-does not 1725-003 (Reference 17) adequately bound for cause the hydrodynamic loads associated with sloshing equipment for PNPS.
structural failure Calculation 015.0.3625 (Reference 30) was prepared in accordance with EN-DC-126 (Reference 15) and accounts for hydrodynamic loads and sloshing loads. It shows that the SEPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0). The NAI document (References 18) is used as input to the bracket design.
Reference 30 will be available on e-portal for review.
10 Spent Fuel Pool System must References The system features on board electrical Instrumentation allow for 25, 26, & diagnostics. SEPI loop/equipment System routine, in situ 27 maintenance/preventative maintenance and Functionality functionality testing program requirements to ensure design and system readiness will be established in
____ accordance with Entergy's processes and to Letter 2.15.051 Page 19 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results procedures and in consideration of vendor recommendations to ensure that appropriate regular testing, loop checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit). The instrument automatically monitors the integrity of its level measurement system using in-situ capability. Technical manuals have been provided by the vendor (References 26 & 27) for use, although it is possible these could be amended in the future based on installation experience.
+ + 4 11 Boron Build-Up Buildup Reference Boron buildup Acceptable, MOHR Report 1-0410-8 (Reference cannot 11 can produce a 11 ) concludes that the presence of borated water produce error maximum and/or boric acid deposits will not significantly greater than error of 2.5 impair the ability of the MOHR EFP-IL SFPI 1' including all inches system to accurately measure water level in the other error SFP environment. Regardless of these findings, source terms PNPS is a BWR and does not use borated water (References 1 in their SEP.
& 2)
Previous Topic #10 already discusses maintenance / preventative maintenance requirements being established in consideration of vendor recommendations (which includes and bounds those associated with boron build-up).
Similarly, Topic #20 below discusses overall calibration or loop functional testing methodology expected to be based on vendor stated accuracy along with comparison of SFPI loops to actual pool level (which would also bound boron build-up to Letter 2.15.051 Page 20 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results effects specified in Reference 40). Visual inspection and/or wash dlown of the probe assembly could be initiated by accuracy requirements or routine inspection. The probe head assembly includes a connection mechanism for flushing water to remove boron build-up as may be necessary. Alternatively, the SEP water level can be raised until it covers and dissolves the boric acid deposit (Reference 27)..
12 Pool-side Bracket Seismic Class Reference See Topic #8 Seismic Class Calculation C1 5.0.3625 (Reference 30) was Seismic Analysis I (References 12 Iprepared in accordance with EN-DC-126 (References 1, 2, & 1, 2, & 14) (Reference 15) and accounts for seismic
- 15) accelerations. It shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0).
Reference 30 will be available on e-portal for review.
13 Additional Brackets Seismic Class Reference See Topic #8 Seismic Class Calculations C1 5.0.3625, C1 5.0.3626, (Sensor Electronics I (References 9 IC1 5.0.3627, Cl15.0.3628, C1 5.0.3639, and and Electronics 1, 2, 3, & 14) C1 5.0.3640 (References 30, 31, 32, 33, 34, & 35)
Enclosure) were prepared in accordance with EN-DC-126 (Reference 15) and account for seismic accelerations. The calculations conclude that the mounting configurations for electronics, enclosures, and display panels meet the seismic design criteria. In addition, the safety related block walls are adequate for the additional loads from the new equipment.
References 30, 31, 32, 33, 34, & 35 will be available on e-portal for review.
to Letter 2.15.051 Page 21 of 27
- Topic Parameter Summary 1Reference Vendor Document Additional Comment
_Results___
Test or Analysis Licensee Evaluation 14 Shock & Vibration (References References lEC 60068 The NRC Audit Report for MOHR (Reference 40) 1,2,3) 8, 12, & 38 27 (2008-02) concludes that the shock and vibration test results (Reference were satisfactory. The report also acknowledges MIL-STD-1 67- 19) that the testing performed in MOHR Report 1-1 (Reference lEC 60068 041 0-16 (Reference 38) is sufficient to close the
- 23) for 6 (2007-12) open item identified during the MOHR audit.
vibration and (Reference MI L-STD- 20) Acceptable, the vendor testing provided 901 D adequately addresses the requirements for (Reference general robustness of the enclosures. The probe
- 24) for shock and repairable head are essentially a coax cable system that is considered inherently resistant to shock and vibration. The probes and repairable head are evaluated to be adequately designed for resilience against shock and vibration (Reference 38).
The new probe mounting components and fasteners are seismically qualified and designed as rigid components inherently resistant to vibration effects. The probes will be affixed to the bracket using a machine screw connection designed with proper thread engagement and lock washers.
The indicator and battery enclosures will be mounted in the control room. The equipment is not affixed or adjacent to any rotating machinery that would cause vibration effects in the area of installation. The new instrument mounting components and fasteners are seismically to Letter 2.15.051 Page 22 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results qualified and designed as rigid components inherently resistant to vibration effects. Similarly, the effects of shock on the supporting fixtures for the control room instruments are not a credible threat; all equipment in the control room is qualified seismically such that there are no expected impacts from adjacent objects during the BDBEE or desigrn basis earthquake requirements imposed by NEI 12-02. Even though shock and vibration is not credible for control room equipment, it is adequately addressed by vendor test reports.
15 Requirements Software Reference The instrument software Verification and Traceability Matrix Traceability 28 Validation was performed by MOHR per Revision Matrix 2 of MOHR Report 1-0410-11 (Reference 28).
Required for Software Evaluation of Equipment 16 Factory Acceptance Must MOHR Acceptable loop factory acceptance tests have Test demonstrate FAT been completed successfully.
functionality of Procedure full EFP-IL and SEP-i 17 Channel Accuracy +- 1 foot References 3.0 in max, Appendix A of Reference 25 states that the (Reference 2) 25 & 37 not including absolute accuracy is 76.2 mm or 3.0 in, not boric acid including boric acid deposition effects. This error deposition or complies with the limit of +/-1 foot set by NEI 12-02 boiling effects (Reference 2). See Topic # 11 for boric acid deposition effects. Additionally, the probe is
__________________________________________________designed to produce accurate level indication in to Letter 2.15.051 Page 23 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results boiling and frothing (multiphase) environments according to MOHR Report 1-0410-15 (Reference 37).
18 Power Consumption 120 VAC, 60 References85-264 VAC The NRC Audit Report for MOHR (Reference 40)
Hz 10 & 13 47-63 HZ concludes that no deficits were identified with (Reference 11.48 W respect to function reliability, accuracy, or
- 14) (average) calibration as a result of power interruption.
18.83 W (maximum) Acceptable, the power requirements for the instrument are met by the distribution panels that will provide normal AC power to the units.
Additionally, the SEP level instrumentation also comes with a battery backup in a separate enclosure. MOHR Report 1-0410-10 (Reference
- 13) concludes that the accuracy is not affected by
_________an interruption in power.
7 day battery Reference 7 day battery The NRC Audit Report for MOHR (Reference 40) life required 10 life @ 15 concludes that battery life capability is samples per satisfactory.
hour rate Acceptable, the instrument testing demonstrates the battery capacity is sufficient for the maximum duration required by References 1 & 2.
19 Technical Manual N/A References Technical manuals have been submitted by the 26 & 27 vendor (References 26 & 27) for use, although it is possible these could be amended in the future based on installation experience.
20 Calibration Must allow for References System is Technical manuals have been submitted by the in-situ 25, 26, & calibrated vendor (References 25, 26, & 27) for use, calibration 27 using CT- although it is possible these could be amended in 100 device the future based on installation experience.
to Letter 2.15.051 Page 24 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results and Previous Topic #10 already discusses processing maintenance / preventative maintenance of scan files requirements being established in consideration by vendor, of vendor recommendations.
Dry scan from original Overall calibration or loop functional testing installation methodology is expected to be based on vendor must be stated accuracy and to incorporate a comparison maintained, of SFPI loops to actual pool level as well as a SEPI cross loop comparison.
21 Failure Modes and System Reference SFPI system Acceptable, the FMEA provided adequately Effects Analysis provides 39 will meet addresses failure modes and effects for the full (FMEA) reliable requirements instrument loop with credit taken for the use of indication of of References two redundant loops provided the installation fuel pool level, 1 & 2 when meets all requirements stipulated in References 1 consistent installed as & 2.
with the req u ired requirements of References
___ 1 &2 22 Emissions Testing EPRI TR- References EPRI TR- Acceptable, MOHR Reports 1-0410-4 (Reference 102323, Rev 6 &7 102323, Rev 6) 1-0410-4-Si (Reference 7) demonstrate the 3 (Reference 3 (Reference new SFPI satisfies the EMI/RFI compliance
- 22) 22) guidelines of Revision 3 of EPRI TR-1 02323 (Reference 22) in accordance with Entergy Engineering Standard EN-IC-S-004-MULTI (Reference 21).As demonstrated in the MOHR System EMC Test Report and Supplemental Information (References 6 7), the SFPI system passed the High Frequency Radiated and
_________________________________________________Conducted Emissions testing.
to Letter 2.15.051 Page 25 of 27
- Topic Parameter Vendor Additional Test or Licensee Evaluation Summary Reference Comment Analysis Document Results FLEX Strategy Guidelines (FSG) governing the use of the SFPI is expected to include a cautionary statement to preclude radio usage within close proximity to the displays.
to Letter 2.15.051 Page 26 of 27 Spent Fuel Pool Instrumentation Order (EA-12-051)
Bridging Document between Vendor Technical Information and Licensee Use Based on NRC Staff Requests for Additional Information (RAIs) and NRC Vendor Audit
References:
- 1. ML12054A679, NRC Order EA-1 2-051, "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-1 2-051, "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. 1-0410-1 "MOHR EFP-IL SFPI System Temperature and Humidity Test Report"
- 5. 1-0410-2 "MOHR SFP-1 Level Probe Assembly Materials Qualification Report"
- 7. 1-0410-4-$1 "MOHR EFP-IL SFPI System Supplemental EMO Information"
- 8. 1-0410-5 "MOHR EFP-IL SFPI System Shock and Vibration Test Report"
- 9. 1-0410-6 "MOHR EFP-IL SFPI System Seismic Test Report" 10.1-0410-7 "MOHR EFP-IL SFPI System Battery Life Report" 11.1-0410-8 "MOHR EFP-IL SFPI System Boric Acid Deposition Report" 12.1-0410-9 "MOHR SFP-1 Level Probe Assembly Seismic Analysis Report" 13.1-0410-10 "MOHR EFP-IL SFPI System Power Interruption Report"
- 14. UFSAR, Rev 21 "Pilgrim Update Final Safety Analysis Report"
- 15. EN-DC-126, Rev 5, "Engineering Calculation Process"
- 16. S&SA202, Rev 0, "Spent Fuel Pool Instrumentation Shielding Calculation"
- 17. NA1-1 725-003, Rev 0 "GOTHIC Verification and Sensitivity Studies for Predicting Hydrodynamic Response to Acceleration in Rectangular Shaped Pools"
- 18. NA1-1 725-004, Rev 3 "Seismic Induced Hydraulic Response in the OGS Spent Fuel Pool"
- 19. IEC 60068-2-27 (2008-02), "Environmental Testing-Part 2-27: Tests-Test EA and Guidance: Shock"
- 20. lEC 60068-2-6 (2007-12), "Environmental Testing-Part 2-6: Tests-Test Fc: Vibration (sinusoidal)"
- 21. EN-IC-S-004-MULTI, Rev 1, "EMI/RFI Design Considerations"
- 22. EPRI TR-1 02323, Rev 3, "Guidelines for Electromagnetic Interference of Power Plant Equipment" to Letter 2.15.051 Page 27 of 27
- 23. MIL-STD-167-1, "Mechanical Vibrations of Shipboard Equipment (Type 1-Environmentally and Type IlI-nternally Excited)", May 1, 1974
- 24. MIL-S-901 D, "Shock Tests H.l.(High Impact) shipboard Machinery, Equipment, and Systems, Requirements for" 25.1-0410-12 "EFP-IL Signal Processor Operator's Manual "
26.1-0410-13 "EFP-IL Signal Processor Technical Manual" 27.1-0410-14 "SEP-I Level Probe Assembly Technical Manual" 28.1-0410-11 "MOHR EFP-IL SFPI System Software Verification and Validation"
- 30. 01 5.0.3625, Rev 0, "Probe Mounting in SFP" 31.0C15.0.3626, Rev 0, "J-Box Mounting" 32.0C5.0.3627, Rev 0, "Mounting to the Control Room Wall" 33.0C15.0.3628, Rev 0, "Reevaluation of Blockwal1 195.14" 34.0C5.0.3639, Rev 0, "Reevaluation of Blockwall 65.10" 35.0C15.0.3640, Rev 0, "Reevaluation of Blockwall 65.21"
- 36. EC45088, Rev 0, "Fukushima - spent Fuel Pool Level Instrumentation"
- 37. 1-0410-15 "MOHR EFP-IL SFPI System Uncertainty Analysis" 38.1-0410-16, "MOHR SEP-I Level Probe Assembly Shock and Vibration Test Report
- 39. EVAL-194-4812-01 "MOHR EFP-IL Liquid Level Measurement System Failure Modes and Effects Analysis (FMEA)"
- 40. Donald C. Cook Nuclear Plant, Units 1 and 2 - Report for the Onsite Audit of MOHR Regarding Implementation of Reliable Spent Fuel Pool Instrumentation Related to Order EA-12-051 (TAO NOS. MF0761 and MF0762) dated August 27, 2014 (ADAMS Accession No ML14216A362)
- 41. M1 382, Rev. 0, "Pilgrim Nuclear Power Station MCR Heatup for Extended Loss of AC Power (FLEX) to Letter 2.15.051 Attachment 3 to Letter 2.15.051 NRC Audit Questions and Status to Letter 2.15.051 Page 1 of 7 Audit Original Item Status item no. Document Reference
- 0. Order 051-SFPI ISE RAIs 1-D SFPLI RAI 1 Provide plan view of SEP area showing SEP inside CLOSED dimensions, planned locations/placement of primary Attachment 4 provides a plan view of the proposed and backup SEP level sensor, and proposed routing locations of the probes.
of cables that will extend from these sensors toward The SFPI conduit is routed to exit the Refuel Floor, location of display device. elevation 117 ft. as soon as possible to minimize the possibility of physical damage to both loops from damage due to potential debris during a beyond design basis external event. The Channel A conduit will be installed on or very close to the floor at the west wall until it exits the refueling floor. The Channel B conduit will be installed at a higher elevation above the refueling floor in the southeast corner until it exits the refueling floor.
NRC Staff performed tour of site on October 2014 and verified there is adequate separation between the cables and the cables are protected against internal missiles.
See Attachment 5 to this letter for a drawing showing the layout.
2-D SEPLI RAI 2 Provide the analysis verifying the seismic testing of CLOSED the level probes, the mounting brackets, and the Calculation C1 5.0.3626, Revision 0, " Junction Box electronic units, and analysis of combined maximum Mounting Evaluation", C1 5.0.3627 "LI-4816A and B seismic and hydrodynamic forces on the cantilevered Mounting Evaluation", and C1 5.0.3625 "LE-4816A portion of the assembly exposed to sloshing effects. and B Mounting bracket Evaluation" provide Show the SEP instrument design configuration will be documentation of the seismic evaluations of the maintained during and following the maximum equipment mounting.
seismic ground motion considered in design of SEP Document 1-0410-6, Revision 1, "MOHR EFP-IL structure. SFPI System Seismic Test report," and 1-0410-9,
____________________Revision 1, "MOHR SEP-i Level Probe Assembly to Letter 2.15.051 Page 2 of 7 Audit Original Item Status item no. Document Reference Seismic Analysis Report," provides seismic analysis of the probes.
3-D SFPLI RAt 3 For each of the mounting attachment required to CLOSED attach SEP level equipment to plant structures, Calculation 015.0.3626, Revision 0, " Junction Box describe the design inputs and methodology that was Mounting Evaluation", C1 5.0.3627 "LI-4816A and B used to qualify the structural integrity of the affected Mounting Evaluation", and Cl15.0.3625 "LE-4816A equipment and structures. and B Mounting bracket Evaluation" provide documentation of the seismic evaluations of the equipment mounting.
Document 1-0410-6, Revision 1, "MOHR EFP-IL SFPI System Seismic Test report," and 1-0410-9, Revision 1, "MOHR SEP-i Level Probe Assembly Seismic Analysis Report," provides seismic analysis of the probes.
4-D SFPLI RAt 4 Provide analysis of the maximum expected CLOSED radiological conditions, dose rate and total integrated By letter dated Eebruary 28, 2014, Entergy provided dose, to which the sensor electronics will be its six month status report for Order EA-1 2-051. In exposed. Provide documentation indicating what is this response, Entergy stated that Channel A and B the maximum total integrated dose the sensor displays containing the system electronics, will be electronics can withstand and how it was determined, located in the Control Room. Radiation levels are not Discuss the time period over which the analyzed total impacted by a reduction in SEP water level. No integrated dose was applied, analysis is necessary to evaluate the system electronics for radiation exposure.
to Letter 2.15.051 Page 3 of 7 Audit Original Item Status item no. Document Reference 5-D SFPLI RAI 5 Provide information indicating what will be the CLOSED maximum expected ambient temperature in the room The entire PNPS SFP instrument loop (equipment in which the sensor electronics will be located under from the SEP to the Control Room) is designed and beyond design basis conditions in which there is no qualified to PNPS environmental extremes applicable AC power available to run HVAC systems, and for the area of interest (e.g., SEP, Control Room).
whether the sensor electronics are capable of The SEP area environmental extremes are in continuously performing required functions under this accordance with NEI 12-02 Revision 1 SEP example expected temperature condition. conditions. The SEP instrumentation loops have been designated as Augmented Quality per Entergy processes covering procurement, design, and installation. As such, the SEP instrument loops have demonstrated reliability through establishment of Augmented Quality processes at applicable environmental extremes 6-D SEPLI RAI 6 Provide information indicating the maximum CLOSED expected relative humidity in the room in which the sensor electronics will be located under beyond The entire PNPS SEP instrument loop (equipment design basis conditions in which there is no AC from the SEP to the Control Room) is designed and power available to run HVAC systems, and whether qualified to PNPS environmental extremes applicable the sensor electronics are capable of continuously for the area of interest (e.g., SFP, Control Room).
performing required functions under this expected The SEP area environmental extremes are in humidity condition. accordance with NEI 12-02 Revision 1 SEP example conditions. The SEP instrumentation loops have been designated as Augmented Quality per Entergy processes covering procurement, design, and installation. As such, the SEP instrument loops have demonstrated reliability through establishment of Augmented Quality processes at applicable
_________ ______________________________________________environmental extremes.
to Letter 2.15.051 Page 4 of 7 Audit Original Item Status item no. Document Reference 7-D SFPLI RAI 7 Provide a description of the specific method or CLOSED combination of methods you intend to apply to The NRC Audit Report for MOHR concludes that the demonstrate the reliability of the permanently shock and vibration test results were satisfactory.
installed equipment under beyond design basis The report also acknowledges that the testing shock and vibration conditions. Identify the specific performed in MOHR Report 1-0410-16 is sufficient to commercial and/or military standards that will be close the open item identified during the MOHR used to establish the testing requirements and the audit.
specific acceleration levels and frequencies that will be simulated. The vendor testing provided adequately addresses the requirements for general robustness of the enclosures. The probe and repairable head are essentially a coax cable system that is considered inherently resistant to shock and vibration. The probes and repairable head are evaluated to be adequately designed for resilience against shock and vibration.
The new probe mounting components and fasteners are seismically qualified and designed as rigid components inherently resistant to vibration effects.
The probes will be affixed to the bracket using a machine screw connection designed with proper thread engagement and lock washers.
lEC 60068-2-27 (2008-02) and lEC 60068-2-6 (2007-12) 8-D SEPLI RAI 8 Regarding RAI Number 7 above, provide the results CLOSED for the selected methods, tests, and analysis used to See answer to 7-0 and the following documents.
demonstrate the qualification and reliability of the installed equipment in accordance with the Order 1-0410-9 "MOHR SFP-1 Level Probe Assembly
_____________requirements. Seismic Analysis Report" to Letter 2.15.051 Page 5 of 7 Audit Original Item Status item no. Document Reference 1-0410-1 6, "MOHR SEP-i Level Probe Assembly Shock and Vibration Test Report 9-D SFPLI RAI 9 Provide analysis of the vendor analysis and seismic Acceptable, MOHR has prepared a series of seismic testing results and show that the instrument qualification reports for the SEP level instrument. The performance reliability, following exposure to qualification reports envelop all components of the simulated seismic conditions representative of the new SEP level instrumentation required to be environment anticipated for the SEP structures at operational during a BDBEE and post-event. These Pilgrim, has been adequately demonstrated. documents are MOHR Reports 1-0410-6 and 1-0410-9.
Calculation C1 5.0.3625 was prepared in accordance with EN-DC-i126 and accounts for seismic loads. It shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0).
Acceptable, the MOHR seismic qualification reports in combination with NAI Report # NA1-1 725-003 NAI Report # NA1-1725-004 and NA1-1725-003 adequately bound for the hydrodynamic loads associated with sloshing for PNPS.
Calculation C1 5.0.3625 was prepared in accordance with EN-DC-126 and accounts for hydrodynamic loads and sloshing loads. It shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0). The NAI document is used as input to the bracket desian.
to Letter 2.15.051 Page 6 of 7 Audit Original Item Status item no. Document Reference 1 0-D SFPLI RAI 10 Provide the NRC staff with the final configuration of CLOSED the power supply source for each channel so that the See Attachment 1 Item # 1 .f to this letter.
staff may conclude that the two channels are independent from a power supply assignment perspective.
1 1-D SFPLI RAI 11 Provide the results of the calculation depicting the CLOSED battery backup duty cycle requirements and The NRC closed this item based on information compatibility with the duration required for the plant reviewed during their audit of MOHR.
mitigating strategy for assuring SEP level filling/cooling.
12-D SFPLI RAI 12 Provide the analysis verifying that the proposed CLOSED instrument performance is consistent with these The NRC closed this item based on information estimated accuracy is normal and beyond design reviewed during their audit of MOHR.
bases values. Please demonstrate that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.
13-D SFPLI RAI 13 Provide a description of the methodology that will be CLOSED used for determining the maximum allowed deviation The NRC closed this item based on information from the instrument channel design accuracy that will reviewed during their audit of MOHR.
be employed under normal operating conditions as an acceptable criterion for a calibration procedure to flag operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
14-D SFPLI RAI 14 Provide a description of the in situ calibration process CLOSED at the SFP location that will result in the channel The NRC closed this item based on information calibration being maintained at its design accuracy. reviewed during their audit of MOHR.
to Letter 2.15.051 Page 7 of 7 Audit Original Item Status item no. Document Reference 15-D SEPLI RAI 15 Provide a list of the procedure addressing operation CLOSED (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that Document 1-0410-7, "MOHR EFP-IL SFPI System will be developed for use of the SEP instrumentation. Battery Life Report," contains battery testing and The licensee is requested to include a brief calibration.
description of the specific technical objectives to be
____________achieved within each procedure.
16-D SFPLI RAI 16 Provide further information describing the CLOSED maintenance and testing program the licensee will SFPI channel/equipment maintenance/preventative establish and implement to ensure that regular maintenance and testing program requirements to testing and calibration is performed and verified by ensure design and system readiness will be inspection and audit to demonstrate conformance established in accordance with Entergy's processes with design and system readiness requirements. and procedures and vendor recommendations. This Include a description of your plans for ensuring that will ensure that appropriate regular testing, channel necessary channel checks, functional tests, periodic checks, functional tests, periodic calibration, and calibration, and maintenance will be conducted for maintenance is performed (and available for the level measurement system and its supporting inspection and audit).
equipment.
E. Combined SE Template technical review gaps 5-E RAI SE No. 1 Electromagnetic compatibility. RAI as a result of CLOSED vendor audit. Pilgrim Nuclear Power Station Procedure 2.2.85, "Fuel Pool Cooling and Filtering System," Attachment 13 prohibits the use of cell phones or radio transmissions within the area of the spent fuel pool display units in the Control Room.
to Letter 2.15.051 Drawing C2900
REFERENCES ELEVATION M263 SN 1996, REV. 1, INSTALLATION.- SPENT FUELSTORAGE POOL LEVELSWITCHES C175, REV.2 REACTOR BUILDINGSPENT FUEL STORAGE POOL WALLELEVATIONS & DETAILS 117'-4" C177, REV. 5, REACTOR BUILDINGREACTOR WELL PLAN& SECTION & DETAILS 116'-7.75" (sw) 116'-7.875" (NW)
~117'-0" M-39,REV. 1 REACTOR BUILDING-AREA 1 & 3 - PLAN ABOVE EL. 117'-0" C-109, REV.4 SPENT FUEL POOL WELL, DRYER, ANDSTORAGE SEPARATOR POOLS SECTIONS 116'-8.25" (SW), 116'-8.375" (NW)
TOP OF WORKING RANGE 116'-0" M23, REV.8 EQUIPMENT LOCATIONS C179, RE'V.4 -SPENT FUELPOOL SECTIONS & DETAILS SFPI LEVEL 1 -. ...
FUEL POOL OVERFLOW IS ATTHE WEIR PLATES EL. 115'-7.625" (C179, REV. 4 AND 11 b'-I:l" CALCULATION C15.0.2594 REV. 0).
115'-3" 1" ABOVE MININUM ANALYTICAL LEVEL(V2191 MOHRDRAWING 1-0430-19.20A/B) 115'-0" M263 SN. 199A, REV. 2 (28" BELOW 11T"-4")
SFPI LEVEL 2 111'-3" TS 3/4.10.C WATER LEVEL- SPENT FUEL POOL (NEI112-02LEVEL2)
(SE-2818)
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lii 108'-0" TOP OF BLADES
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(FRN94-26-02)
FPCP TRIP IS ON LOW-LOW LEVEL INTHE SKIMMER SURGE TANK AT EL.102-'.5" 102'-5" (19.5 INCHES DECREASING FROM SKIMMER SURGE TANKBOTTOM - M22-5-7BC, REV.4 AND SM422, SH. I REV.7) 94'-0" BOTTOM OF BLADES (NOMINAL) 93-4.26" (sw) SFPI LEVEL 3 93'-10" 93'-4.375" (NW) 93'-3.75" BOTTOM OF C180, REV.4 REACTOR BUILDING - SPENT FUEL POOL WORKING RANGE 92'-10" C1398, REV.0. RACK CONSTRUCTION - SPENT FUELSTORAGE RACK C1400, REV.0, SUPPORT DETAILSPENT FUEL STORAGE RACKS N3ANDN4 78-3"C173, REV.9 -REACTOR BUILDING-SPENT FUEL POOL GENERAL ARRANGEMENT to Letter 2.15.051 Drawing E304 (partial)
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Icontinues to Main Control Room - LI-4816A and LI-4816B
Reference:
E304 (EC45088)
(Ref.: E298, E301, E303, and E313)