ML16054A842

Sixth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ML16054A842
Person / Time
Site:	Callaway
Issue date:	02/23/2016
From:	Ameren Missouri, Union Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16054A840	List: ML16054A842 ULNRC-06283, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
References
EA-12-051, ULNRC-06283
Download: ML16054A842 (10)

Text

Enclosure to ULNRC-06283 Page 1 of 10 Ameren Missouris Sixth Six-Month Status Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8 of this report) for the Callaway Plant, documenting the requirements to install reliable Spent Fuel Pool Instrumentation System (SFPIS), in response to NRC Order EA-12-051 (Reference 2). This enclosure provides an update of milestone accomplishments since the last update submittal of the OIP (Reference 15), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. Refer to Section 8 of this enclosure for a list of References.

2 Milestone Accomplishments The following milestones have been completed since development of the SFPIS OIP (Reference 1), and are current as of January 31, 2016.

Submittal of the sixth six-month status report for implementation of Order EA-12-051 (this document).

3 Milestone Schedule Status The following table provides an update of the milestone schedule provided in the SFPIS OIP to the NRC.

The table provides the activity status of each item and the expected completion date (with any changes noted). The dates are planning dates subject to change as design and implementation details are developed. The milestone completion dates have been revised based on approval of the relaxation request discussed in Section 5.

The revised milestone target completion dates do not impact the order implementation outage. Italicized text denotes that a Milestone was updated since the fifth six-month status update.

Enclosure to ULNRC-06283 Page 2 of 10 Milestone Target Completion Date Activity Status Revised Target Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete Update 6 Feb 2016 Complete Modifications:

Modifications Evaluation Feb 2013 Complete Commence Engineering and Design Mar 2013 Complete Complete Design Dec 2013 Complete Receipt of SFP Instruments Apr 2014 Complete Procedures:

Create Procedures (Note 1)

Sep 2014 Complete Training:

Develop Training Plan Aug 2014 Complete Complete SFP Instrumentation Procedures & Training Sep 2014 Complete RAI Response:

RAI Response (Note 2)

Jun 2013 Complete ISE RAI Response (Note 3)

Mar 2014 Complete SFP Instruments Operational (Note 4)

Nov 2014 Complete Submit Completion Report Dec 2014 Not Started Jul 2016 Note 1: Includes Maintenance Procedures Note 2: The RAI referred to here is the NRCs RAI concerning the Overall Integrated Plan in response to Order EA-12-051 (Reference 2). Reference 4 provided Ameren Missouris response to the RAI.

Note 3: The RAIs referred to here are the NRC Interim Staff Evaluation (ISE) and RAI concerning Overall Integrated Plan in response to Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Reference 6).

Enclosure to ULNRC-06283 Page 3 of 10 Note 4: Prior to the completion of Refuel 20, the SFPIS was installed and in operation with a battery supply that can last 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if site power is lost. Callaway requested relaxation (References 10 and 11) for the requirement described in NRC Order EA-12-051, Appendix 2, Section 1.6. The relaxation request was approved as documented in ML14154A400 (Reference 12). Upon implementation of Callaways FLEX Strategies per NRC Order EA-12-049, full compliance with NRC Order EA-12-051 will be achieved.

4 Changes to Compliance Method There are no changes to the compliance method documented in the Overall Integrated Plan (Reference 1) since submittal of the fifth six-month status report (Reference 15) in August 2015.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter ULNRC-06036 (Reference 7), Ameren Missouri requested schedular relaxation of FLEX implementation for Order EA-12-049 such that the order implementation date would be extended to completion of Refuel 21 (Spring 2016). The request was approved by NRC letter (ML13319A668) dated December 11, 2013 (Reference 8). FLEX implementation is required to comply with the power supply requirement described in NRC Order EA-12-051, Attachment 2, Section 1.6. Based on the approval of the relaxation request, Ameren Missouri submitted ULNRC-06113 (Reference 10) and ULNRC-06119 (Reference 11) to request relaxation of the power supply requirement described in NRC Order EA 051, Attachment 2, Section 1.6. This relaxation was approved by the NRC per ML14154A400 (Reference 12).

6 Open Items from Overall Integrated Plan and Interim Safety Evaluation There are no open items from the Overall Integrated Plan. All requested information for the RAIs from the Interim Staff Evaluation was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6, as documented in the third six-month status report (Reference 13) submitted in August 2014.

The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status None Interim Staff Evaluation Open Items (Note 1)

Status RAI No.1 Please provide the results of the calculation used to determine the water elevation that is sufficient for the pump's required NPSH so the NRC staff may confirm that Level 1 has been adequately identified.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 4 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.2 Please clarify whether this wireless communications system will be used as two separate point-to-point wireless communications systems (i.e., one system between the sending unit and receiver for the primary level channel and a second system between the sending unit and receiver for the back-up level channel), or whether there will be shared communications channels over which both the primary and the backup channels can communicate simultaneously.

Also, please verify whether there are other wireless communication devices within the plant that will be allowed to share this wireless communications system.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.3 Please provide a plant-specific evaluation of the interaction of the proposed wireless technology with other plant systems, in particular, interactions and any malfunctions that could result from potential failure modes of one channel, or due to BOB conditions.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.4 Please provide additional information describing how the proposed arrangement and routing of the cables meet the Order requirement to arrange the SFP level instrument channels 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.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.5 Please clarify if a stilling well is part of the instrument design and, if so, how its weight is accounted for and how it will be mounted and analyzed.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.6 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.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 5 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.7 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs and the methodology that will be used to qualify the structural integrity of the affected structures/equipment.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.8 Please describe the quality assurance process to be used to meet the augmented quality requirements identified in the Order.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.9 Please provide an analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the transmitter electronics will be exposed.

Provide documentation indicating the cumulative (total integrated) radiological dose the electronics for this equipment are capable of withstanding. Discuss the time period over which the analyzed total integrated dose was applied.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 10 Please provide information indicating a) the temperature ratings for all system electronics (including sensor electronics, system electronics, transmitter, receiver and display) and whether the ratings are continuous duty ratings; and, b) the maximum expected temperature in the room(s) in which the sensor electronics will be located under BOB conditions, with no ac power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 11 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BOB conditions, with no ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 6 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No. 12 Please provide the following:

Information describing the evaluation of the sensor electronics design, the shock test method, test results, and forces applied to the sensor electronics applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of severe shock.

Information describing the evaluation of the sensor electronics design, the vibration test method, test results, forces and their frequency ranges, and directions applied to the sensor applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of high vibration.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 13 Please provide analysis of the seismic testing results and show that the instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Callaway, has been adequately demonstrated. Include information describing the design inputs and methodology used in any analyses of the mounting of electronic equipment onto plant structures, as requested in RAI No. 7 above.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 14 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.15 Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 7 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.16 Please provide the following:

An estimate of the expected instrument channel accuracy performance (e.g., in percent of span) under both a) normal SFP level conditions (approximately Level 1 or higher) and b) at the BOB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

A description of the methodology used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions, which would be used as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.17 Please provide the following:

A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

A description of the way such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently installed SFP level instrumentation.

A description of the functional checks to be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Discuss how these surveillances will be incorporated into the plant surveillance program.

A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 8 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No. 18 Please provide a list of the procedures addressing operation

{both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.19 Please provide the following:

Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure that necessary channel

checks, functional

tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

A description of the compensatory actions to be taken in the event that one or both channels are non-functioning, as described in the guidance in NEI 12-02 section 4.3.

A description of the planned compensatory actions to be taken when one of the instrument channels cannot be restored to functional status within 90 days.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 20 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Note 1: An Interim Staff Evaluation has been received from the NRC (Reference 6).

7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation identified at this time.

Enclosure to ULNRC-06283 Page 9 of 10 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. ULNRC-05960,Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013.

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

3. Letter dated June 7, 2013 from C. F. Lyon, USNRC to A. C. Heflin, Union Electric Company, Callaway Plant, Unit 1 - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0773)

(ADAMS Accession No. ML13121A187)

4. ULNRC-06008, Response to Request for Additional Information with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated July 3, 2013

5. ULNRC-06026, "First 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 29, 2013

6. ML13323A111, "Callaway Plant, Unit 1 - Interim Staff Evaluation and Request for Additional Information Re: Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0773)," dated November 25, 2013

7. ULNRC-06036, "Request for Relaxation From NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,'"

dated October 09, 2013

8. ML13319A668, "Callaway Plant, Unit 1-Relaxation of The Schedular Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated December 11, 2013

9. ULNRC-06088, "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 26, 2014

10. ULNRC-06113, "Request for Relaxation From NRC Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" dated April 17, 2014

11. ULNRC-06119, "Supplement to Request for Relaxation From NRC Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" dated May 8, 2014

12. ML14154A400, "Callaway Plant, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'"

dated June 26, 2014

13. ULNRC-06136, "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

Enclosure to ULNRC-06283 Page 10 of 10

14. ULNRC-06185, "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 26, 2015

15. ULNRC-06241, "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)," dated August 27, 2015

Enclosure to ULNRC-06283 Page 1 of 10 Ameren Missouris Sixth Six-Month Status Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" 1 Introduction Ameren Missouri developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8 of this report) for the Callaway Plant, documenting the requirements to install reliable Spent Fuel Pool Instrumentation System (SFPIS), in response to NRC Order EA-12-051 (Reference 2). This enclosure provides an update of milestone accomplishments since the last update submittal of the OIP (Reference 15), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. Refer to Section 8 of this enclosure for a list of References.

2 Milestone Accomplishments The following milestones have been completed since development of the SFPIS OIP (Reference 1), and are current as of January 31, 2016.

Submittal of the sixth six-month status report for implementation of Order EA-12-051 (this document).

3 Milestone Schedule Status The following table provides an update of the milestone schedule provided in the SFPIS OIP to the NRC.

The table provides the activity status of each item and the expected completion date (with any changes noted). The dates are planning dates subject to change as design and implementation details are developed. The milestone completion dates have been revised based on approval of the relaxation request discussed in Section 5.

The revised milestone target completion dates do not impact the order implementation outage. Italicized text denotes that a Milestone was updated since the fifth six-month status update.

Enclosure to ULNRC-06283 Page 2 of 10 Milestone Target Completion Date Activity Status Revised Target Completion Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Update 4 Feb 2015 Complete Update 5 Aug 2015 Complete Update 6 Feb 2016 Complete Modifications:

Modifications Evaluation Feb 2013 Complete Commence Engineering and Design Mar 2013 Complete Complete Design Dec 2013 Complete Receipt of SFP Instruments Apr 2014 Complete Procedures:

Create Procedures (Note 1)

Sep 2014 Complete Training:

Develop Training Plan Aug 2014 Complete Complete SFP Instrumentation Procedures & Training Sep 2014 Complete RAI Response:

RAI Response (Note 2)

Jun 2013 Complete ISE RAI Response (Note 3)

Mar 2014 Complete SFP Instruments Operational (Note 4)

Nov 2014 Complete Submit Completion Report Dec 2014 Not Started Jul 2016 Note 1: Includes Maintenance Procedures Note 2: The RAI referred to here is the NRCs RAI concerning the Overall Integrated Plan in response to Order EA-12-051 (Reference 2). Reference 4 provided Ameren Missouris response to the RAI.

Note 3: The RAIs referred to here are the NRC Interim Staff Evaluation (ISE) and RAI concerning Overall Integrated Plan in response to Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Reference 6).

Enclosure to ULNRC-06283 Page 3 of 10 Note 4: Prior to the completion of Refuel 20, the SFPIS was installed and in operation with a battery supply that can last 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if site power is lost. Callaway requested relaxation (References 10 and 11) for the requirement described in NRC Order EA-12-051, Appendix 2, Section 1.6. The relaxation request was approved as documented in ML14154A400 (Reference 12). Upon implementation of Callaways FLEX Strategies per NRC Order EA-12-049, full compliance with NRC Order EA-12-051 will be achieved.

4 Changes to Compliance Method There are no changes to the compliance method documented in the Overall Integrated Plan (Reference 1) since submittal of the fifth six-month status report (Reference 15) in August 2015.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter ULNRC-06036 (Reference 7), Ameren Missouri requested schedular relaxation of FLEX implementation for Order EA-12-049 such that the order implementation date would be extended to completion of Refuel 21 (Spring 2016). The request was approved by NRC letter (ML13319A668) dated December 11, 2013 (Reference 8). FLEX implementation is required to comply with the power supply requirement described in NRC Order EA-12-051, Attachment 2, Section 1.6. Based on the approval of the relaxation request, Ameren Missouri submitted ULNRC-06113 (Reference 10) and ULNRC-06119 (Reference 11) to request relaxation of the power supply requirement described in NRC Order EA 051, Attachment 2, Section 1.6. This relaxation was approved by the NRC per ML14154A400 (Reference 12).

6 Open Items from Overall Integrated Plan and Interim Safety Evaluation There are no open items from the Overall Integrated Plan. All requested information for the RAIs from the Interim Staff Evaluation was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6, as documented in the third six-month status report (Reference 13) submitted in August 2014.

The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item Status None Interim Staff Evaluation Open Items (Note 1)

Status RAI No.1 Please provide the results of the calculation used to determine the water elevation that is sufficient for the pump's required NPSH so the NRC staff may confirm that Level 1 has been adequately identified.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 4 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.2 Please clarify whether this wireless communications system will be used as two separate point-to-point wireless communications systems (i.e., one system between the sending unit and receiver for the primary level channel and a second system between the sending unit and receiver for the back-up level channel), or whether there will be shared communications channels over which both the primary and the backup channels can communicate simultaneously.

Also, please verify whether there are other wireless communication devices within the plant that will be allowed to share this wireless communications system.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.3 Please provide a plant-specific evaluation of the interaction of the proposed wireless technology with other plant systems, in particular, interactions and any malfunctions that could result from potential failure modes of one channel, or due to BOB conditions.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.4 Please provide additional information describing how the proposed arrangement and routing of the cables meet the Order requirement to arrange the SFP level instrument channels 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.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.5 Please clarify if a stilling well is part of the instrument design and, if so, how its weight is accounted for and how it will be mounted and analyzed.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.6 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.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 5 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.7 For each of the mounting attachments required to fasten SFP level equipment to plant structures, please describe the design inputs and the methodology that will be used to qualify the structural integrity of the affected structures/equipment.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.8 Please describe the quality assurance process to be used to meet the augmented quality requirements identified in the Order.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.9 Please provide an analysis of the maximum expected radiological conditions (dose rate and total integrated dose) to which the transmitter electronics will be exposed.

Provide documentation indicating the cumulative (total integrated) radiological dose the electronics for this equipment are capable of withstanding. Discuss the time period over which the analyzed total integrated dose was applied.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 10 Please provide information indicating a) the temperature ratings for all system electronics (including sensor electronics, system electronics, transmitter, receiver and display) and whether the ratings are continuous duty ratings; and, b) the maximum expected temperature in the room(s) in which the sensor electronics will be located under BOB conditions, with no ac power available to run Heating, Ventilation, and Air Conditioning (HVAC) systems.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 11 Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BOB conditions, with no ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing required functions under this expected humidity condition.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 6 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No. 12 Please provide the following:

Information describing the evaluation of the sensor electronics design, the shock test method, test results, and forces applied to the sensor electronics applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of severe shock.

Information describing the evaluation of the sensor electronics design, the vibration test method, test results, forces and their frequency ranges, and directions applied to the sensor applicable to successful tests demonstrating the testing provides an appropriate means to demonstrate reliability of the sensor electronics under the effects of high vibration.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 13 Please provide analysis of the seismic testing results and show that the instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Callaway, has been adequately demonstrated. Include information describing the design inputs and methodology used in any analyses of the mounting of electronic equipment onto plant structures, as requested in RAI No. 7 above.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 14 Please provide the NRC staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.15 Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 7 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No.16 Please provide the following:

An estimate of the expected instrument channel accuracy performance (e.g., in percent of span) under both a) normal SFP level conditions (approximately Level 1 or higher) and b) at the BOB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

A description of the methodology used for determining the maximum allowed deviation from the instrument channel design accuracy under normal operating conditions, which would be used as an acceptance criterion for a calibration procedure to alert operators and technicians that the channel requires adjustment to within normal design accuracy.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.17 Please provide the following:

A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.

A description of the way such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently installed SFP level instrumentation.

A description of the functional checks to be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Discuss how these surveillances will be incorporated into the plant surveillance program.

A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Enclosure to ULNRC-06283 Page 8 of 10 Interim Staff Evaluation Open Items (Note 1)

Status RAI No. 18 Please provide a list of the procedures addressing operation

{both normal and abnormal response), calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No.19 Please provide the following:

Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of plans to ensure that necessary channel

checks, functional

tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

A description of the compensatory actions to be taken in the event that one or both channels are non-functioning, as described in the guidance in NEI 12-02 section 4.3.

A description of the planned compensatory actions to be taken when one of the instrument channels cannot be restored to functional status within 90 days.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

RAI No. 20 Please provide a description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.

Requested information was submitted on the STARS e-Portal by March 31, 2014, as required by Reference 6.

Note 1: An Interim Staff Evaluation has been received from the NRC (Reference 6).

7 Potential Interim Safety Evaluation Impacts There are no potential impacts to the Interim Safety Evaluation identified at this time.

Enclosure to ULNRC-06283 Page 9 of 10 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. ULNRC-05960,Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013.

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

3. Letter dated June 7, 2013 from C. F. Lyon, USNRC to A. C. Heflin, Union Electric Company, Callaway Plant, Unit 1 - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0773)

(ADAMS Accession No. ML13121A187)

4. ULNRC-06008, Response to Request for Additional Information with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated July 3, 2013

5. ULNRC-06026, "First 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 29, 2013

6. ML13323A111, "Callaway Plant, Unit 1 - Interim Staff Evaluation and Request for Additional Information Re: Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC NO. MF0773)," dated November 25, 2013

7. ULNRC-06036, "Request for Relaxation From NRC Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,'"

dated October 09, 2013

8. ML13319A668, "Callaway Plant, Unit 1-Relaxation of The Schedular Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events,'" dated December 11, 2013

9. ULNRC-06088, "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 26, 2014

10. ULNRC-06113, "Request for Relaxation From NRC Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" dated April 17, 2014

11. ULNRC-06119, "Supplement to Request for Relaxation From NRC Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'" dated May 8, 2014

12. ML14154A400, "Callaway Plant, Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-051, 'Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,'"

dated June 26, 2014

13. ULNRC-06136, "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

Enclosure to ULNRC-06283 Page 10 of 10

14. ULNRC-06185, "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 26, 2015

15. ULNRC-06241, "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)," dated August 27, 2015