JAFP-15-0105, Fifth 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)

Fifth 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)

ML15240A377
Person / Time
Site:	FitzPatrick
Issue date:	08/28/2015
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, JAFP-15-0105
Download: ML15240A377 (21)

Text

JAFP-15-0105 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Fifth 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)

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1.

NRC Order Number, EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, ML12056A044, dated March 12, 2012

2.

NRC Interim Staff Guidance, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, JLD-ISG-2012-03, dated August 29, 2012

3.

Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, NEI 12-02, Revision 1, dated August 24, 2012

4.

Entergy to NRC, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

JAFP-12-0125, dated October 29, 2012

5.

Entergy to NRC, James A. FitzPatrick Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), JAFP-13-0023, dated February 28, 2013

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued an order [Reference 1] to James A. FitzPatrick Nuclear Power Plant (JAF). Reference 1 was immediately effective and directed JAF to install reliable spent fuel pool level instrumentation.

Specific requirements are outlined in Attachment 2 of Reference 1.

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF

JAFP-15-0105 Page 2 of 2 Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C.2. Reference 2 endorsed industry guidance document NEI 12-02 Revision 1

[Reference 3] with clarifications and exceptions identified in Reference 2. Reference 4 provided the JAF initial status report regarding spent fuel pool instrumentation. Reference 5 provided the JAF overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1 that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 281h day of August, 2015.

Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/mh

Attachment:

James A. FitzPatrick Nuclear Power Plant's (JAF's) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator NRC Resident Inspector Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Douglas Pickett, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. John B. Rhodes., President NYSERDA

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (18 Pages)

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 1 of 18

1. Introduction James A. FitzPatrick Nuclear Power Plant (JAF) developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable spend fuel pool level instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2. Milestone Accomplishments The following milestone(s) have been completed since January 31, 2015, and are current as of July 31, 2015:

Modifications Evaluation - The Modifications Evaluation milestone target completion date has been changed to September 2015. This new milestone target completion date does not impact the Order Implementation date.

Design Engineering - The Design Engineering milestone target completion date has been changed to September 2015. This new milestone target completion date does not impact the Order Implementation date.

Respond to ISE RAIs received December 12, 2013 - Complete per this submittal

3. Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

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

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Not Started Update 7 August 2016 Not Started

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 2 of 18 Milestone Target Completion Date Activity Status Revised Target Completion Date Modifications:

Modifications Evaluation April 2015 In Progress September 2015 Design Engineering April 2015 In Progress September 2015 Implementation Outage Fall of 2016 Not Started Procedures:

Create Procedures Fall of 2016 In Progress Training:

Develop Training Plan Fall of 2016 Not Started Training Complete Fall of 2016 Not Started SFP LI Implementation Fall of 2016 Not Started Full Site SFPI Implementation Fall of 2016 Not Started Submit Completion Report December 2016 Not Started Respond to ISE RAIs received December 12, 2013 (Reference 3)

March 31, 2016 Complete Respond to RAIs received August 29, 2013 October 3, 2013 Complete

• Target Completion Date is the last submitted date from either the overall integrated plan or previous six-month update

4. Changes to Compliance Method There are no additional changes to the compliance method.

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation JAF expects to comply with the order implementation date and no relief/relaxation is required at this time.

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 3 of 18

6. Open Items from Overall Integrated Plan and Interim Staff Evaluation FitzPatrick has received an Interim Staff Evaluation that includes 18 RAIs. Responses to the RAIs are due by March 31, 2016. The following table provides a status of the RAIs.

RAI #

Response Status 1

Submitted in Reference 7 2

See Section 9 3

See Section 9 4

See Section 9 5

Submitted in Reference 7 6

Submitted in Reference 7 7

Submitted in Reference 7 8

Submitted in Reference 7 9

Submitted in Reference 7 10 See Section 9 11 Submitted in Reference 7 12 Submitted in Reference 7 13 Submitted in Reference 7 14 Submitted in Reference 7 15 Submitted in Reference 7 16 Submitted in Reference 7 17 Submitted in Reference 7 18 Submitted in Reference 7

7. Potential Interim Staff Evaluation Impacts There are no impacts to the ISE identified at this time except for those identified in Section 6.

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 4 of 18

8. References The following references support the updates to the Overall Integrated Plan described in this attachment.

1. James A. FitzPatrick Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), JAFP-13-0023, dated February 28, 2013 (ML13063A267).

2. Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, EA-12-051, dated March 12, 2012 (ML12056A044).

3. James A. FitzPatrick Nuclear Power Plant - Interim Staff Evaluation and Request for Additional Information, Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF1076), dated December 12, 2013 (ML13338A645).

4. Summary of the November 26, 2013, Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation, dated December 26, 2013 (ML13347B030).

5. James A. FitzPatrick Nuclear Power Plant - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) (TAC No. MF1076), dated August 29, 2013 (ML13226A534).

6. Response to Request for Additional Information for the Overall Integrated Plan for the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, JAFP-13-0132, dated October 3, 2013.

7. 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), JAFP-15-0027, dated February 27, 2015 (ML15058A607).

8. Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, NEI 12-02, Revision 1, dated August 24, 2012 (ML12240A307)

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 5 of 18

9. Responses to the Interim Staff Evaluation Requests for Additional Information RAI #2 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

See bridging document Topic #8, 9, 12, & 13 (Section 10).

RAI #3 For each of the mounting attachments required to fasten SFP Level equipment to plant structures, please describe the design inputs and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

See bridging document Topic #8, 9, 12 & 13 (Section 10).

RAI #4 Please provide further information to describe how other material stored in the SFP will not create adverse interaction with the fixed instrument location(s).

The Spent Fuel Pool is designed seismic Class I in order to withstand Design Basis Event (DBE) earthquake loads. As a part of the Engineering Change (EC) process for JAF, interferences (i.e. Refueling Group equipment, tools, control blades, etc.) in the pool shall be removed or relocated to make room for the new instruments. Additionally, this EC marks a 3.5ft exclusion zone surrounding the probes to ensure no adverse radiological, personnel, EMI/RFI (electromagnetic interference) or seismic II/I interactions with the probe instrument.

RAI #10 Please provide the vendor analysis and seismic testing results and show the SFP level instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at JAF, has been adequately demonstrated.

See bridging document Topics # 8, 9, 12, & 13 (Section 10).

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10. JAF Bridging Document Between Vendor Technical Information and Licensee Use Based on NRC Staff Requests for Additional Information (RAIs) and NRC Vendor Audit. The following updates the Section 10 responses previously submitted in the 4th Six-Month Update Report. Note: The references noted in this section are listed at the end of the section.

Topic Parameter Summary Vendor Reference Document #

Additional Comment Test or Analysis Results Licensee Evaluation 1

Design Specification SFPI Requirements derived from References 1, 2, and 3 References 4-12, 25, 27, 28, 29, and 30 Evaluation of vendor information is within the scope of EC 52728 (Reference 33).

2 Test Strategy Per Requirements in References 1, 2, and 3 References 4, 6-12, 25, 28, 29, 27, and 30 The equipment testing performed for the SFPI has been found to be acceptable based on the current design requirements.

3 Environmental Qualification for electronics enclosure with Display 75-112.5°F (References 13

& 36)

Reference 4 14-131°F The display/processors will be located in the Relay Room, within the Control Room Boundary. Calculation JAF-CALC-MISC-04509 (Reference 36) determines that the maximum temperature in the Relay Room, for a configuration in which no ventilation is provided and the equipment inside is powered, will be 110°F after 93 hours0.00108 days <br />0.0258 hours <br />1.537698e-4 weeks <br />3.53865e-5 months <br /> and 112.5°F after 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />.

The normal operating temperature of the Relay Room is 75°F (Reference 13, Table 9.9-1). The SFPI vendor, MOHR, has successfully tested its system electronics to 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 (Reference 4), MOHR EFP-IL SFPI System Temperature and Humidity Report.

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Additional Comment Test or Analysis Results Licensee Evaluation 5-95% RH Reference 4 5-95% RH The SFPI vendor, MOHR, has successfully tested its system electronics to operate in a humidity range of 5%

to 95% relative humidity. Results of the vendor testing are available in proprietary MOHR Report 1-0410-1 Rev. 0, MOHR EFP-IL SFPI System Temperature and Humidity Report (Reference 4).

Humidity in the Relay Room is normally regulated by the Relay Room Ventilation and Cooling (RRHV) system at 40-50% (Reference 34). During an extended loss of AC power, the HVAC system is no longer available. Assuming the Relay Room is isolated from outside air, the temperature is expected to increase and the relative humidity is expected to decrease because the heat loads are dominated by the sensible heat of electrical equipment. Therefore, the maximum temperature of 112.5°F and humidity of 50% is still bounded by the 47 °C (116.6 °F) and 71 percent RH test case presented in MOHR Report 1-0410-1 (Reference 4) which was endorsed by the NRC Audit Report for MOHR (Reference 32).

In the event outside air is introduced to the Relay room, due to open doors or HVAC system connections to other rooms, ASHRAE (Reference 35, Chapter 14 Appendix: Design Conditions for Selected Locations) defines the 0.4% dehumidification condition to be 80.5

°F db, 72.4 °F dew point, and ~67% RH for Syracuse, New York (Reference 35). Similarly, 84.8 °F db, 75.4

°F wb, and ~65% RH is defined for a 0.4% evaporation conditions. These conditions are bounded by the 32°C (89.6°F) and 96 percent RH test case presented in MOHR Report # 1-0410-1 (Reference 4).

Hence, the operational humidity range of 5-95 percent RH encompasses all expected conditions for the Relay

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Additional Comment Test or Analysis Results Licensee Evaluation Room and the sensor electronics are capable of continuously performing their required function under the expected humidity conditions.

No radiation effects N/A Acceptable, the JAF Relay Room is within the Control Room boundary and considered a mild environment.

No additional testing is required per NRC Audit Report for MOHR (Reference 32).

4 Environmental Testing for Level Sensor components in SFP area-Submerged Portion of Probe Body 40-212°F (References 1, 2, and 13)

Reference 5 RAD TID is the total 40 yr dose plus the 7 day worst case accident dose at the lowest spacer location on the Probe body 480°F long-term for PEEK Insulators The NRC Audit Report for MOHR (Reference 32) concludes that the SFP-1 probe is suitable for operation in the SFP environment.

The SFP is expected to remain at or above the minimum ambient temperature of the Reactor Building (40°F) as called out in the UFSAR (Reference 13).

Maximum accident condition of the spent fuel pool is taken to be 212°F boiling water/steam at atmospheric pressure. Based on the vendor analysis results, the sensitive materials in the probe body will not be challenged under the required conditions of References 1, 2, and 13, and are acceptable.

Submerged Component (References 1 and 2)

Reference 5 PEEK Insulators capable of long term submergence 2.04E+08 rad TID (References 1, 2, & 38)

Reference 5 10 Grad for PEEK Insulators The NRC Audit Report for MOHR (Reference 32) concludes that the SFP-1 probe is suitable for operation in the SFP environment.

Calculation JAF-CALC-14-00025 (Reference 38) defines a worst case dose of 2.04E+08 rad to the probe via the applicable requirements of References 1 and 2. As such, the PEEK spacers are suitable for the application.

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Additional Comment Test or Analysis Results Licensee Evaluation 5

Environmental Testing for Level Sensor Electronics Housing-Probe Head located Above the SFP 40-212°F (References 1, 2, and 13)

Reference 5 Rad TID is the total 40 yr dose plus the 7 day worst case accident dose at the location PEEK: 480°F EPDM: 194°F long-term, 12 day @ 311°F Sylgard 170:

392°F long-term The NRC Audit Report for MOHR (Reference 32) concludes that the SFP-1 probe is suitable for operation in the SFP environment.

The SFP area is expected to remain at or above the minimum ambient temperature of the Reactor Building (40°F) as called out in the UFSAR (Reference 13).

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°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 References 1, 2, and 13, and are acceptable.

For coaxial transmission cable beyond the Probe Head, MOHR uses Class 1E Nuclear Safety Related RSCC Wire & Cable RSS-6-110A/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 32).

0-100% RH Condensing (References 1 and 2)

Reference 5 0-100% RH for PEEK, EPDM and Sylgard 170 The NRC Audit Report for MOHR (Reference 32) concludes that the SFP-1 probe is suitable for operation in the SFP environment.

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.

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Additional Comment Test or Analysis Results Licensee Evaluation 2.13E+07 rad TID (References 1, 2, and 38)

Reference 5 PEEK: 10 Grad EPDM: 2 Grad Sylgard 170:

200 Mrad The NRC Audit Report for MOHR (Reference 32) concludes that the SFP-1 probe is suitable for operation in the SFP environment.

Calculation JAF-CALC-14-00025 (Reference 38) defines a worst case dose of approximately 2.13E+07 rad to the area above the SFP. Based on the vendor analysis results, the sensitive materials in the probe head will not be challenged under the required conditions of References 1, 2, and 38 and are acceptable.

6 Thermal &

Radiation Aging-organic components in SFP area See Topics #4 and 5 above Reference 5 See above Topics #4 and 5

Acceptable, vendor test/analysis bound licensee parameters, see discussion above in Topics #4 and 5.

7 Basis for Dose Requirement References 1 and 2 N/A Entergy Calculation Procedure EN-DC-126 (Reference

14) was used to develop calculations JAF-CALC 00024 (Reference 37) and JAF-CALC-14-00025 (Reference 38) based on the requirements of NEI 12-02 (Reference 2) and EA-12-051 (Reference 1). The calculations determine conservative source terms and dose rates at key instrument locations for both a 7 day accident scenario and 40 year TID.

8 Seismic Qualification Seismic Class I (References 1, 2, 3, 13)

References 8 and 11 Seismic Class 1

Acceptable, MOHR has prepared a series of generic seismic qualification reports for the SFP level instrument which bound JAFs seismic criteria. The qualification reports envelop all components of the new SFP level instrumentation required to be operational following a BDBEE and post-event. These documents are MOHR Reports 1-0410-6 (Reference 8) and 1-0410-9 (Reference 11).

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Additional Comment Test or Analysis Results Licensee Evaluation Calculation JAF-CALC-15-00005 (Reference 39) accounts for seismic loads and shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified because all Interaction Ratios (IR) are less than one (1.0).

Reference Topic #9 for discussion of induced sloshing.

9 Sloshing Water induced motion from seismic event does not cause equipment structural failure References 8, 11, 28 and 29 See Topic #8 Acceptable. The MOHR generic seismic qualification reports (References 8 and 11) in combination with NAI Reports NAI-1725-003 and NAI-1725-004 (References 28 and 29) adequately bound the hydrodynamic loads associated with sloshing for JAF.

Calculation JAF-CALC-15-00005 (Reference 39) accounts for sloshing and shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0).

10 Spent Fuel Pool Instrumentation System Functionality System must allow for routine, in situ functionality References 20, 21, and 22 The system features on board electrical diagnostics.

SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness will be established in accordance with Entergys processes and procedures and in consideration of vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance are performed (and available for inspection and audit). The instrument automatically monitors the integrity of its level measurement system using in-situ capability. Revision 0 of the manuals have been provided by the vendor (References 20, 21, and 22) for use, although it is possible these could be amended by the vendor in the future based on installation experience.

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Additional Comment Test or Analysis Results Licensee Evaluation 11 Boron Build-Up Buildup cannot produce error greater than 1 including all other error source terms (References 1 and 2)

Reference 10 Boron buildup can produce a maximum error of 2.5 inches Acceptable, MOHR Report 1-0410-8 (Reference 10) concludes that the presence of borated water and/or boric acid deposits will not significantly impair the ability of the MOHR EFP-IL SFPI system to accurately measure water level in the SFP environment.

Regardless of these findings, JAF is a BWR and does not use borated water in their SFP.

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 channel functional testing methodology expected to be based on vendor stated accuracy along with comparison of SFPI channels to actual pool level (which would also bound boron build-up effects specified in Reference 32). Visual inspection and/or wash down 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 SFP water level can be raised until it covers and dissolves the boric acid deposit (Reference 22).

12 Pool-side Bracket Seismic Analysis (References 1, 2, and 13)

Seismic Class I (References 1, 2, and 13)

Reference 11 See Topic #8 Seismic Class I Calculation JAF-CALC-15-00005 (Reference 39) shows that the SFPI Probe Mounting Bracket is structurally adequate and seismically qualified as all Interaction Ratios (IR) are less than one (1.0).

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Additional Comment Test or Analysis Results Licensee Evaluation 13 Additional Brackets (Sensor Electronics and Electronics Enclosure)

Seismic Class I (References 1, 2, 3, and 13)

Reference 8 See Topic #8 Seismic Class I Equipment installed in the Relay Room at EL. 284-8 shall be installed as Seismic Class I. EC52728 (Reference 33) accounts for seismic accelerations and shows that the additional brackets can withstand the maximum loads imposed onto them without requiring further calculations.

14 Shock & Vibration (References 1, 2, 3)

MIL-STD-167-1 for vibration and MIL-STD-901D (Reference 19) for shock References 7, 11, and 30 IEC 60068 27 (2008-02)

(Reference 15)

IEC 60068-2-6 (2007-12)

(Reference 16)

The NRC Audit Report for MOHR (Reference 32) concludes that the shock and vibration test results were satisfactory. The report also acknowledges that the testing performed in MOHR Report 1-0410-16 (Reference 30) is sufficient to close the open item identified during the MOHR audit.

Acceptable, 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 (Reference 30).

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 Relay Room (Reference 33), which is within the Control Room Boundary. 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

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Additional Comment Test or Analysis Results Licensee Evaluation seismically qualified and designed as rigid components inherently resistant to vibration effects. There are no expected impacts from adjacent objects during the BDBEE or design basis earthquake requirements imposed by NEI 12-02.

15 Requirements Traceability Matrix Software Traceability Matrix Required for Software Evaluation of Equipment Reference 23 The instrument software Verification and Validation was performed by MOHR per Revision 2 of MOHR Report 1-0410-11 (Reference 23).

16 Factory Acceptance Test Must demonstrate functionality of full EFP-IL and SFP-1 MOHR FAT Procedure Acceptable channel factory acceptance tests have been completed successfully.

17 Channel Accuracy

+/- 1 foot (Reference 2)

References 20 & 27 3.0 in max, not including boric acid deposition or boiling effects Appendix A of Reference 20 states that the absolute accuracy is 76.2 mm or 3.0 in, not including boric acid deposition effects. This error complies with the limit of

+/-1 foot set by NEI 12-02 (Reference 2). See line 11 for boric acid deposition effects.

Additionally, the probe is designed to produce accurate level indication in boiling and frothing (multiphase) environments (Reference 27).

18 Power Consumption 120 VAC, 60 Hz (References 13 and 26)

References 9, 12, and 26 85-264 VAC 47-63 HZ Maximum 18.83 W, average 11.48 W

The NRC Audit Report for MOHR (Reference 32) concludes that no deficits were identified with respect to function reliability, accuracy, or calibration as a result of power interruption.

Acceptable, the power requirements for the instrument are met by the power supply that will provide normal

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Additional Comment Test or Analysis Results Licensee Evaluation AC power to the units.

MOHR Report 1-0410-10 (Reference 12) concludes that the accuracy is not affected by an interruption in power.

7 day battery life required Reference 9 7 day battery life @ 15 samples per hour rate The NRC Audit Report for MOHR (Reference 32) concludes that battery life capability is satisfactory.

Acceptable, the instrument testing demonstrates the battery capacity is sufficient for the maximum duration required by References 1 and 2.

19 Technical Manual N/A References 21 and 22 Revision 0 of the manuals have been provided by the vendor (References 21 and 22) for use, although it is possible these could be amended by the vendor in the future based on installation experience.

20 Calibration Must allow for in-situ calibration References 20, 21, and 22 System is calibrated using CT-100 device and processing of scan files by vendor. Dry scan from original installation must be maintained Revision 0 of the manuals have been provided by the vendor (References 20, 21, and 22) for use, although it is possible these could be amended by the vendor in the future based on installation experience. Previous Topic #10 already discusses maintenance /

preventative maintenance requirements being established in consideration of vendor recommendations.

Overall calibration or channel functional testing methodology is expected to be based on vendor stated accuracy and to incorporate a comparison of SFPI channels to actual pool level as well as a SFPI cross channel comparison.

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 16 of 18 Topic Parameter Summary Vendor Reference Document #

Additional Comment Test or Analysis Results Licensee Evaluation 21 Failure Modes and Effects Analysis (FMEA)

System provides reliable indication of fuel pool level, consistent with the requirements of References 1 &

2.

Reference 31 SFPI system will meet requirements of References 1 and 2 when installed as required Acceptable, the FMEA provided adequately addresses failure modes and effects for the full instrument channel with credit taken for the use of two redundant channels provided the installation meets all requirements stipulated in References 1 & 2.

22 Emissions Testing EPRI TR-102323, Rev. 3 (Reference 17)

References 6 and 25 EPRI TR-102323, Rev. 3 (Reference 17)

Acceptable, MOHR reports 1-0410-4 (Reference 6) and 1-0410-4-S1 (Reference 25) demonstrate the new SFPI satisfies the EMI/RFI compliance guidelines of Revision 3 of EPRI TR-102323 (Reference 17) in accordance with Entergy Engineering Standard EN-IC-S-004-MULTI (Reference 24). As demonstrated in the MOHR System EMC Test Report and Supplemental Information (References 6 and 25), the SFPI system passed the High Frequency Radiated and Conducted Emissions testing.

FLEX Support Guidelines (FSG) governing the use of the SFPI will include a cautionary statement to preclude radio usage within close proximity to the displays.

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 17 of 18 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 for Section 10:

1. ML12054A679, NRC Order EA-12-051, ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION, Nuclear Regulatory Commission, March 12, 2012

2. ML12240A307, NEI 12-02 Rev. 1, Industry Guidance for compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation August, 2012.

3. ML12221A339, Rev. 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

6. 1-0410-4 MOHR EFP-IL SFPI System EMC Test Report

7. 1-0410-5 MOHR EFP-IL SFPI System Shock and Vibration Test Report

8. 1-0410-6 MOHR EFP-IL SFPI System Seismic Test Report

9. 1-0410-7 MOHR EFP-IL SFPI System Battery Life Report

10. 1-0410-8 MOHR EFP-IL SFPI System Boric Acid Deposition Report

11. 1-0410-9 MOHR SFP-1 Level Probe Assembly Seismic Analysis Report

12. 1-0410-10 MOHR EFP-IL SFPI System Power Interruption Report

13. UFSAR, Rev. 4, James A. FitzPatrick Updated Safety Analysis Report

14. EN-DC-126, Rev 5, Engineering Calculation Process

15. IEC 60068-2-27 (2008-02) Environmental Testing-Part 2-27: Tests-Test Ea and Guidance: Shock

16. IEC 60068-2-6 (2007-12) Environmental Testing-Part 2-6: Tests-Test Fc: Vibration (sinusoidal)

17. EPRI TR-102323, Rev. 3, Guidelines for Electromagnetic Interference of Power Plant Equipment

18. MIL-STD-167-1 Mechanical Vibrations of Shipboard Equipment (Type 1-Environmentally and Type II-Internally Excited)

19. MIL-S-901D Shock Tests H.I.(High Impact) shipboard Machinery, Equipment, and Systems, Requirements for

20. 1-0410-12 EFP-IL Signal Processor Operators Manual

21. 1-0410-13 EFP-IL Signal Processor Technical Manual

22. 1-0410-14 SFP-1 Level Probe Assembly Technical Manual

23. 1-0410-11 MOHR EFP-IL SFPI System Software Verification and Validation

JAFP-15-0105 Attachment James A. FitzPatrick Nuclear Power Plants (JAFs) Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation Page 18 of 18

24. EN-IC-S-004-MULTI, Rev. 001, EMI/RFI Design Considerations

25. 1-0410-4-S1 MOHR EFP-IL SFPI Supplemental EMC Information

26. MOHR Drawing 1-0430-20 EFP-IL System Electrical Diagram

27. 1-0410-15 MOHR EFP-IL SFPI System Uncertainty Analysis

28. NAI-1725-003, Rev. 0 GOTHIC Verification and Sensitivity Studies for Predicting Hydrodynamic Response to Acceleration in Rectangular Shaped Pools

29. NAI-1725-004, Rev. 3 Seismic Induced Hydraulic Response in the CGS Spent Fuel Pool

30. 1-0410-16, MOHR SFP-1 Level Probe Assembly Shock and Vibration Test Report

31. EVAL-194-4812-01 MOHR EFP-IL Liquid Level Measurement System Failure Modes and Effects Analysis (FMEA)

32. 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 (TAC NOS. MF0761 and MF0762) dated August 27, 2014 (ADAMS Accession No ML14216A362)

33. EC52728, Rev 0, FUKUSHIMA - SPENT FUEL POOL LEVEL INSTRUMENTATION

34. DBD-070, Rev. 14, Entergy Nuclear Northeast James. A. FitzPatrick Nuclear Power Plant Design Basis Document for the Control Room Relay Room Ventilation and Cooling Systems

35. 2009 ASHRAE Handbook Fundamentals, I-P Edition

36. JAF-CALC-MISC-04509, Rev. 0, Main Control Room Heat-Up During Extended Loss of Offsite Power

37. JAF-CALC-14-00024, Rev. 0, Spent Fuel Pool Instrumentation Source Term Calculation

38. JAF-CALC-14-00025, Rev. 0, Spent Fuel Pool Instrumentation Shielding Calculation

39. JAF-CALC-15-00005, Rev. 0, Spent Fuel Pool Level Probe Mounting Bracket