NL-15-0240, Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

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Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)
ML15057A273
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 02/26/2015
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NL-15-0240
Download: ML15057A273 (31)
v • d • e


Text

Charles R. Pierce Southern Nuclear Regulatory AHairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham , AL 35201 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY FEB 2 6 2015 Docket Nos.: 50-321 NL-15-0240 50-366 U. S. Nuclear Regulatory Comm ission ATTN : Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

References:

1. NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012.
2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051 , Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012.
3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051 , To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 1, dated August 2012.
4. Edwin I. Hatch Nuclear Plant- Units 1 and 2 Initial Status Report in Response to Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation

( EA-12-51), dated October 23, 2012.

5. Edwin I. Hatch Nuclear Plant- Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051), dated February 27, 2013.
6. Interim Staff Evaluation and Request for Additional Information- Hatch Nuclear Plant, Units 1 and 2 (HNP) Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0721 and MF0722), dated October 28, 2013.

Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Southern Nuclear Operating Company. Reference 1 was immediately effective and directs the Edwin I. Hatch Nuclear Plant- Units 1 and 2 (HNP) to install reliable spent fuel pool instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

U. S. Nuclear Regulatory Commission NL-15-0240 Page2 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.1.a of Reference 1. Reference 2 endorses industry guidance document NEI 12-02, Revision 1, (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the HNP initial status report regarding spent fuel pool instrumentation strategies. Reference 5 provided the HNP original 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. of this report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. of this report includes the supplemental response to the NRC Interim Staff Evaluation and Request for Additional Information regarding the HNP Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation in accordance with Order Number EA-12-051 requested by Reference 6.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, , ..

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C. R. Pierce Regulatory Affairs Director CRP/JMG/GLS Sworn to and subscribed before me this .2..&:!. day of~ ,2015.

~pit~b My commission expires: /0 . z. Zot1

U. S. Nuclear Regulatory Commission NL-15-0240 Page3

Enclosures:

1. Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fourth Six-Month Status Report Regarding Reliable Spent Fuel Pool Instrumentation (EA-12-051)
2. Edwin I. Hatch Nuclear Plant- Units 1 and 2 Southern Nuclear Operating Company Supplemental Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
3. Hatch Unit 1 and Hatch Unit 2 Elevation View of Level 1, 2, 3 and Instrument Range
4. Hatch Unit 1 and Hatch Unit 2 Proposed Sensor Locations and Conduit Routing on Elevation 228'
5. Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant
6. Hatch Unit 1 and Hatch Unit 2 Proposed System Design Configuration
  • cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President - Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager - Hatch RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch Mr. B. A. Purnell, NRRIJLD/PMB Mr. S. R. Jones, NRRIDSS/SBPB State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation CEA-12-051)

Enclosure 1 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report Regarding Reliable Spent Fuel Pool Instrumentation (EA-12-051) to NL-15-0240 Fourth Six-Month Status Report of SFPI OIP Implementation Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fourth Six-Month Status Report Regarding Reliable Spent Fuel Pool Instrumentation (EA-12-051) 1 Introduction Edwin I. Hatch Nuclear Plant Units 1 and 2 developed an Overall Integrated Plan (Reference 1 of this enclosure), documenting the requirements to install reliable spent fuel pool instrumentation (SFPI), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of 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 In addition to the submittal of status reports, the following milestone(s) directly related to SFP instrumentation implementation have been completed since the previous 6-month update, and are current as of December 31, 2014:

  • None 3 Milestone Schedule Status The table 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.

Target Revised Target Activity Milestone Completion Completion Status Date Date Submit 60 Day Status Report Oct 2012 Complete N/A Submit Overall Integrated Plan Feb 2013 Complete N/A Submit 6 Month Status Report Aug 2013 Complete N/A Submit 6 Month Status Report Feb 2014 Complete N/A Unit 1 1st RFO Mar 2014 Complete N/A Develop Modifications Unit 1 Dec 2014 In Progress Mar 2015 Submit 6 Month Status Report Aug_ 2014 Com_Qiete N/A Submit 6 Month Status Report Feb 2015 Complete N/A Receipt of Unit 1 SFP Instrument Channel Feb 2015 In Progress Jun 2015 Unit 2 1st RFO Mar 2015 Not Started Develop Modifications Unit 2 Ap_r 2015 In Progress Submit 6 Month Status Report Aug 2015 Not Started Complete Functional Test of Unit 1 SFP 3Q 2015 Not Started Instruments Receipt of Unit 2 SFP Instrument Channel Nov 2015 In Prqgress Submit 6 Month Status Report Feb 2016 Not Started Unit 1 lm_Qiementation Complete (2nd RFO)* Mar 2016 Not Started Submit 6 Month Status Report Aug 2016 Not Started Complete Functional Test of Unit 2 SFP 4Q 2016 Not Started Instruments Unit 21mplementation Complete** Dec 2016 Not Started Submit Completion Report Dec 2016 Not Started

  • Full compliance after second listed refueling outage
    • Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016 E1-1 to NL-15-0240 Fourth Six-Month Status Report of SFPI OIP Implementation 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1 of this enclosure}.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Edwin I. Hatch Nuclear Plant Units 1 and 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Interim Staff Evaluation The NRC has reviewed the Hatch Overall Integrated Plan for compliance with Order EA-12-051 and issued an Interim Staff Evaluation (ISE} (Reference 5} providing concurrence with the approach described in the Overall Integrated Plan. In the ISE, the NRC identified areas where additional information is required for its determination regarding the compliance with the Order.

Accordingly, the additional information is provided in Enclosure 2.

Although not identified by Reference 5 as an open item, SNC stated its intent in Reference 4 to provide: (1} a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangements for the portions of instrument channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets}, (2} datum values representing Level 1, Level 2, and Level 3 as well as the top of the fuel racks, and (3} the portion of the level sensor 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. This information is provided in .

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

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

1. Edwin I. Hatch Nuclear Plant Units 1 and 2 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 27, 2013.
2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.
3. Edwin I. Hatch Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos.

MF0721 and MF0722), dated August 1, 2013.

4. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company Response to the Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 29,2013.
5. Interim Staff Evaluation and Request for Additional Information - Hatch Nuclear Plant, Units 1 and 2 (HNP) Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0721 and MF0722), dated October 28,2013.

E1-2 to NL-15-0240 Fourth Six-Month Status Report of SFPI OIP Implementation 9 Other Additional Information The following information provides clarity or corrections to the Overall Integrated Plan but does not constitute a change in strategy:

  • The Edwin I. Hatch Nuclear Plant Units 1 and 2 SFPI will not involve use of a stilling well.

E1-3

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

Enclosure 2 Interim Staff Evaluation and Request for Additional Information- Hatch Nuclear Plant, Units 1 and 2 (HNP)

Regarding Overall Integrated Plan (OIP) tor Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) to NL-15-0240 SNC Response to NRC ISE Request for Additional Information NRC RAI1 Please provide additional information describing how the proposed arrangement of the routing of the cabling between the level probes and the electronics cabinets that process the signal meets 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.

SNC Response to RAI 1 By letter NL-13-0172 dated February 27, 2013, SNC provided the Hatch Overall Integrated Plan (OIP) required by Order EA-12-051. Attachment 1 of the OIP provided a probe layout sketch depicting the Spent Fuel Pool Level Instrument (SFPLI) probe locations and corresponding cable routing associated with each based on available information. SNC has chosen to relocate the SFPLI probes to eliminate the need to route both instrument channels in close proximity of one another. A plan view sketch of the Unit 1 and Unit 2 SFP areas is provided in Enclosure 4, depicting the location/placement of the primary and alternate level sensors, and the routing of cables that extend toward the location of the electronics. To provide reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP, the primary and alternate channel cabling will be routed in flex conduit inside steel plate-covered trenches and physically separated to the extent practicable.

NRC RAI2 Please provide additional information describing how the proposed arrangement of the SFP level instrumentation meets 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.

SNC Response to RAI 2 As stated in response to RAI #1 above, SNC has relocated the SFPLI probes from the location depicted in the OIP dated February 27, 2013. Enclosure 4 provides the revised location for the Unit 1 and Unit 2 SFPLI probes. Physical separation of the primary and alternate channels, to the extent practicable and comparable to the short side of the pool, is used to provide reasonable protection of the level indication function against missiles that may result from the damage to the structure over the SFP.

NRC RAI3 Please provide the following:

a) The design criteria that will be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.

Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

E2-1 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

SNC Response to RAJ 3 a) 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 are provided in Enclosure 5.

b) The simplified drawing shown below provides a basic representation of the attachment of the probe and the sensor cable to the mounting sliding bracket (launch plate), and mounting bracket attachment to the SFP structure. The mounting bracket will be attached to the SFP concrete floor utilizing expansion-type concrete anchor bolts. The level sensor consists of a stranded stainless steel cable level probe that is threaded on the top end. The probe attaches (threads) into a coupling that is secured to the mounting bracket launch plate and extends down into the pool. The attachment to the signal cable is via a coaxial connection on the top side of the launch plate coupling. The Edwin I. Hatch Nuclear Plant Units 1 and 2 SFPI will not involve use of a stilling well .

c) The simplified drawing below shows a representation of the attachment of the probe and the sensor cable to the mounting bracket (launch plate), and mounting bracket attachment to the SFP structure.

The level sensor (probe) is designed to be attached near its upper end to the mounting bracket. The mounting bracket will be attached to the SFP concrete floor utilizing expansion-type concrete anchor bolts. The mounting bracket to the SFP concrete floor anchorage is designed to meet the requirements of the Hatch design and licensing basis for Seismic Category I components including seismic loads, static weight loads and hydrodynamic loads.

Cable Coupling Probe (Bottom)

E2-2 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information NRC RAI4 For RAI 3(a) above, please provide 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.

SNC Response to RAI 4 The analysis 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, are provided in Enclosure 5.

NRC RAI5 For each of the mounting attachments required to attach 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.

SNC Response to RAI 5 The design inputs and methodology used to qualify the structural integrity of the affected structures/equipment for each of the mounting attachments required to attach SFP Level equipment to plant structures are provided in Enclosure 5.

NRC RAI6 Please provide the following:

a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under BOB ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) 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.

c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

E2-3 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information SNC Response to RAI 6 A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted is addressed in the design. Included is a discussion of this seismic reliability demonstration as it applies to:

1. The level sensors mounted in the SFP area and are provided in Enclosure 5.
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 are installed per DCP, utilizing Site SSE, and ASME & IEEE codes per the UFSAR.

A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy is provided in Enclosure 5.

NRC RAI7 For RAI #6 above, please provide the results from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

SNC Response to RAI 7 The results from the analysis and testing are provided in Enclosure 5.

NRC RAI8 Please provide the following:

a) A description of how the two channels of the proposed level measurement system meet this requirement so that the potential for a common cause event to adversely affect both channels is minimized to the extent practicable.

b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

SNC Response to RAI 8 a) Physical separation, of the primary and backup channels to the extent practical and comparable to the short side of the pool, is used to minimize the potential for a common cause event to adversely affect both channels in the pool. Sensor cable from each probe will be installed in flex conduit, in separate trenches, covered by steel plate.

b) Each level measurement system is designed and installed independently of the others. The primary and backup channels have separate power sources, cabling, conduit, electronics, and displays. See Enclosure 6 for the proposed U 1 and U2 design configuration.

E2-4 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information NRC RAI9 Please provide the following:

a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

SNC Response to RAI 9 a) Normal electrical AC power will be provided by different sources from the 120V AC Distribution System for each level measurement channel as shown in Enclosure 6.

U 1 Primary and U2 Primary: 1R25-S 125 U1 Backup and U2 Backup: 2R25-S102 b) The results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured are provided in Enclosure 5.

NRC RAI10 Please provide the following:

a) An estimate of the expected instrument channel accuracy performance under both (a) normal SFP level conditions (approximately Level1 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.

b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy 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 within the normal condition design accuracy.

SNC Response to RAI 10 Analysis verifying that the proposed instrument performance is consistent with the estimated accuracy normal and BOB values along with demonstration that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power is provided in Enclosure 5.

NRC RAI11 Please provide the following:

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

E2-5 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information b) A description of how 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.

c) A description of how functional checks will 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.

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

SNC Response to RAI 11 While the SFP is operating within design basis and at normal level, the indicators may be compared to fixed marks within the SFP by visual observation to confirm indicated level. The periodic calibration verification will be performed within 60 days of a refueling outage considering normal testing scheduling allowances (i.e., 25%). Calibration verification will not be required to be performed more than once per 12 months. These calibration requirements are consistent with the guidance provided in NEI 12-02, Section 4.3. Periodic calibration verification procedures will be in place based on information provided by Westinghouse in WNA-TP-04709-GEN, .. Spent Fuel Pool Instrumentation System Calibration Procedure ... Preventive maintenance procedures to include tests, inspection and periodic replacement of the backup batteries will be developed based on recommendations from Westinghouse.

NRC RAI12 Please provide the following:

a) The specific location for the primary and backup instrument channel displays.

b) For any displays located outside the main control room, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

SNC Response to RAI 12 The proposed location of the U1 and U2 Primary display panels is in Stairwell1 R208 on EL 164' of the Reactor Building. The proposed location of the U 1 and U2 Backup display panels is in Stairwell 2R208 on EL 164' of the Reactor Building.

The locations are being evaluated considering the accident conditions described in NEI12-02 and NEI12-06, using design inputs from Westinghouse and existing Station Blackout evaluations. The results of the evaluation are expected to demonstrate the displays can be accessed without unreasonable delay and without placing station personnel at undue risk with regards to temperature, humidity, and radiation levels.

E2-6 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information The selected location of the U1 and U2 Primary display panels in Stairwell1 R208 is approximately 230 feet from the U1 and U2 Control Room. The selected location of the U1 and U2 Backup display panels in Stairweii2R208 is approximately 250 feet from the U1 and U2 Control Room. Using a conservative walking pace of 1 mph, Primary & Backup display locations would each require less than 10 minutes to access the display location, perform local function and return to the Control Room. The substantial structures between the SFP and the pathways to the display, combined with the short transit duration, personnel traveling the pathways are not expected to require heroic means with the SFP at Level 3 or above. The display location remains habitable considering the minimal time required to access the displays, distance from the SFP, presence of substantial intervening structures, and the lack of heat producing equipment within the room during accident conditions. Both locations are expected to allow for prompt, non-heroic access to the displays from the Control Room.

SNC intends to periodically monitor the display at one to two hour intervals during accident conditions.

NRC RAI13 Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP instrumentation. Please provide a brief description of the specific technical objectives to be achieved within each procedure.

SNC Response to RAI 13 Procedures have been developed to ensure the following objectives:

Procedure Objectives to be achieved

1) System Inspection Verify system components are in place, complete, and configured correctly.
2) Calibration and Test Verify the system is within the specified accuracy, functioning as designed, and indicating SFP water level.
3) Maintenance Establish and define maintenance requirements (both scheduled and preventative) and activities necessary to minimize possibility of system interruption.
4) Repair Specify steps for problem identification, repair, and replacement activities in the event of system malfunction.
5) Operation Provide sufficient instructions for operation by the plant operations staff.
6) Responses Define actions to be taken upon observation of system level indications, including actions to be taken at the levels defined in NEI12-02.

E2-7 to NL-15-0240 SNC Response to NRC ISE Request for Additional Information NRC RAI14 Please provide the following:

a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Please include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) Further information on how the guidance in NEI12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

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

SNC Response to RAI 14 a) See SNC response to RAI 11.

b) A Condition Report will be initiated and addressed through SNC's Corrective Action Program and eSOMS Action Tracking application. Provisions associated with out of service (OOS) or non-functional equipment, including allowed outage times and compensatory actions, will be consistent with the guidance provided in Section 4.3 of NEI12-02. If one OOS channel cannot be restored to service within 90 days, appropriate compensatory actions, including the use of alternate suitable equipment, will be taken. If both channels become OOS, actions would be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels to operable status and implement appropriate compensatory actions, including the use of alternate suitable equipment and/or supplemental personnel, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

c) If both channels are OOS, a Condition Report will be initiated and addressed through SNC's Corrective Action Program and eSOMS Action Tracking application. SNC will maintain sufficient spare parts for the SFPIS, taking into account the lead time and availability of spare parts, to provide assurance that a channel can be restored to service within 90 days.

NRC RAI15 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.

SNC Response to RAI 15 As stated in response to NRC RAis 11 and 14 above, SNC will develop periodic calibration procedures, consistent with the guidance of NEI12-02, Section 4.3, based on Westinghouse recommendations contained in WNA-TP-04709-FEN, Spent Fuel Pool Instrumentation System Calibration Procedures. A listing of applicable procedures will be included in the completion letter for EA-12-051 for Edwin I. Hatch Units 1 and 2.

E2-8

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation CEA-12-051)

Enclosure 3 Hatch Unit 1 and Hatch Unit 2 Elevation View of Level 1, 2, 3 and Instrument Range to NL-15-0240 Hatch Unit 1 and Hatch Unit 2 Elevation View of Level 1, 2, 3 and Instrument Range Unit l Unit 2 Bottom of Launch Plate Bottom of Launch Plate 228' 4-1/2" 228' 4-1/2" 12" Dead Zon~ 12" Dead Zon~ Top of Curb c228' 4" 227' 4-1/2" 227' 4-1/2" Upper Range 225'9" Levell 226' 2-1/2" 1---- Levell

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  • Corresponds with the Top of Spent Fue l Racks E3-1

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

Enclosure 4 Hatch Unit 1 and Hatch Unit 2 Proposed Sensor Location and Conduit Routing on Elevation 228' to NL-15-0240 Hatch Unit 1 and Hatch Unit 2 Proposed Sensor Location and Conduit Routing on Elevation 228' Proposed Unit 1 Sensor Loca tion and Conduit Routing on El. 228'

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E4-1 to NL-15-0240 Hatch Unit 1 and Hatch Unit 2 Proposed Sensor Location and Conduit Routing on Elevation 228' Proposed Unit 2 Sensor Location and Conduit Routing on EL. 228' Fuel Pool Sensor 2B POOL

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Fuel Pool Sensor 2A E4-2

Edwin I. Hatch Nuclear Plant- Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (EA-12-051)

Enclosure 5 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

1 Design Specification SFPIS Requirements WNA-DS-02957-GEN Contains technical SFPIS requirements N/A derived from based on NRC order, NEI guidance, References 1, 2, & 3 and the ISG listed above.

2 Test Strategy Per Requirements. WNA-PT-00188-GEN Strategy for performing the testing and N/A verification of the SFPIS and pool-side bracket.

3 Environmental 50° F to 140° F, EQ-QR-269, Rev. 2 and Results are summarized in EQ-QR- Test passed conditions qualification for 269, Rev. 2 and WNA-TR-03149- described.

Oto 95% RH WNA-TR-03149-GEN electronics enclosure GEN.

for all conditions.

with Display TID~ 1E03 R y normal Radiation Aging verification (outside SFP area) summarized in Section 5 ofWNA-TR-03149-GEN.

TID~ 1E03 R y abnormal (outside SFP area) 4 Environmental Testing 50°F to212°Fand EQ-QR-269, Rev. 2 Testing summarized in Section 5.7. Passed for Level Sensor I 00% humidity components in SFP area

- Saturated Steam &

Radiation 1E03 R y normal (SFP WNA-TR-03149-GEN Thermal Aging & radiation aging Passed area) verification summarized in Sections 4.1 and 5 (entire system) ofWNA-TR-03149-GEN.

1E07 R y BDB (SFP EQ-QR-269, Rev. 2 Additional radiation aging testing Passed area) documented in Section 5.3.

ES-1 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

5 Environmental Testing 50° F to 140° F, EQ-QR-269, Rev. 2 Testing summarized in Section 5.5. Passed for Level Sensor Oto95%RH Electronics Housing -

outside SFP 100%RH WNA-TR-03149-GEN 100% humidity addressed in Section Passed 7.5.

TID :S 1E03 R y normal WNA-TR-03149-GEN Radiation Aging verification Passed (outside SFP area) summarized in Section 5.

TID :5 1E03 R y abnormal (outside SFP area) 6 Thermal & Radiation 1E03 R y normal (SFP EQ-QR-269, Rev. 2 and Thermal Aging & radiation aging Passed Aging - organic area) WNA-TR-03149-GEN verification summarized in Sections components in SFP area 4.1 and 5 (entire system) ofWNA-TR-03149-GEN.

1E07 R y BDB (SFP EQ-QR-269, Rev. 2 Additional radiation aging testing Passed area) documented in Section 5.3.

E5-2 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

7 Basis for Dose SFPNormal LTR-SFPIS-13-35 and Explanation of Basis for Radiation Passed for all conditions Requirement Conditions: Dose Requirement WNA-DS-02957-GEN 1E03 R y TID (above (includes the clarification of pool) production equivalency of electronics enclosure used for Seismic and EMC Testing) 1E09 R y TID (1' above fuel rack)

SFP BDBE Conditions:

1E07 R y TID (above pool)

< I E07 R y TID (1' above fuel rack) 8 Seismic Qualification Per Spectra in WNA- EQ-QR-269, Rev. 2 Documented in Section 5.4. Passed DS-02957 -GEN WNA-TR-03149-GEN WNA-TR-03149-GEN provides high Passed level summary of the pool-side bracket analysis and optional RTD.

EQ-QR-269, Rev. 2 Seismic Pull test for new connectors Passed documented in Section 4.4.

ES-3 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

9 Sloshing N/A LTR-SEE-II-13-47 Calculation to demonstrate that probe Passed will not be sloshed out of the SFP.

WNA-TR-03149-GEN Sloshing is also addressed in Section Passed 7.2.

10 Spent Fuel Pool Acceptance Criteria for WNA-TP-04613-GEN Test procedure used to demonstrate See applicable EQ test.

Instrumentation System Performance during EQ that SFPIS meet its operational and Functionality Test testing accuracy requirements during Procedure Equipment Qualification Testing programs.

11 Boron Build-Up Per requirement in WNA-TR-03149-GEN Boron build up demonstrated through Passed WNA-DS-02957-GEN Integrated Functional Test (1FT).

12 Pool-side Bracket N/A CN-PEUS-14-26, Rev. o Also includes hydrodynamic forces, as Passed Seismic Analysis appropriate.

13 Additional Brackets N/A WNA-DS-02957-GEN Weights provided to licensees for their N/A (Sensor Electronics and own evaluation.

Electronics Enclosure) 14 Shock & Vibration WNA-DS-02957 -GEN WNA-TR-03149-GEN Section 7 provides rationale and N/A summary of RTD.

ES-4 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

15 Requirements Maps Requirements to WNA-VR-00408-GEN, The RTM maps the requirements of Complete Traceability Matrix documentation I Rev. 1 the NRC order, NEI guidance, ISG to evidence that the applicable technical requirements Requirement is met in the SFPIS design specification and maps the design specification requirements to the documentation demonstrating the requirement is met.

16 Westinghouse Factory 1FT Functional WNA-TP-04752-GEN The Integrated Functional Test (IFT) Pilot 1FT executed/passed Acceptance Test, Requirements from demonstrates functionality of the full including testing of WNA-DS-02957-GEN system for each customer's FAT, dead-zones which includes calibration of each channel.

Hatch functional checks Farley functional checks executed/passed executed/passed Vogtle functional checks executed/passed 12" dead-zone at top of WNA-TP-04752-GEN Dead-zone tests are in Section 9.6.2. N/A probe 4" dead-zone at bottom of probe 17 Channel Accuracy +1- 3 inches per WNA- WNA-CN-0030 1-GEN Channel accuracy from measurement Passed DS-02957 -GEN to display.

E5-5

Enclosure 5 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant Westinghouse

  1. Topic Parameter Summary Additional Comment Test or Analysis Results Reference Document#

18 Power Consumption 3 day battery life WNA-CN-00300-GEN N/A Passed (minimum) 0.257 Amps power consumption 19 Technical Manual N/A WNA-G0-00127-GEN Information and instructions for N/A Operation, Installation, use, etc. are included here.

20 Calibration Routine WNA-TP-04709-GEN Also, includes preventative N/A Testing/calibration maintenance actions such as those for verification and Boron buildup and cable probe Calibration method inspection.

21 Failure Modes and N/A WNA-AR-00377-GEN Addresses mitigations for the potential N/A Effects Analysis failure modes of the system.

(FMEA) 22 Emissions Testing RG 1.180 R1 test EQ-QR-269, Rev. 2 Documented in Section 5.6. Passed conditions

References:

1) ML12056A044, NRC Order EA-12-051, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION," Nuclear Regulatory Commission, March 12, 2012.
2) ML12240A307, NEI 12-02 (Revision 1), "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" August, 2012.
3) ML12221A339, Revision 0, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", August 29, 2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate.
4) Westinghouse Proprietary Document, WNA-DS-02957-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System Design Specification," Revision 4 reviewed by NRC in April2014; current revision is Revision 4.

ES-6 to NL-15-0240 Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Edwin I. Hatch Nuclear Plant

5) Westinghouse Proprietary Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy," Revision 1 reviewed by NRC in February 2014; NRC did not review in April; current revision is Revision 3.
6) Westinghouse Proprietary Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation,"

Revision I reviewed by NRC in April 20 14; current revision is Revision 2.

7) Westinghouse Proprietary Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report," Revision 1 reviewed by NRC in April2014; current revision is Revision 1.
8) Westinghouse Proprietary Document, LTR-SFPIS-13-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronics Enclosure Used for Seismic Testing," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision I.
9) Westinghouse Proprietary Document, LTR-SEE-II-13-47, "Determination if the Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out of the Spent Fuel Pool during a Seismic Event," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.
10) Westinghouse Proprietary Document, WNA-TP-04613-GEN, "Spent Fuel Pool Instrumentation System Functionality Test Procedure," Revision 5 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 5.
11) Westinghouse Proprietary Document, CN-PEUS-14-26, "Seismic Analysis of the SFP Mounting Bracket at Hatch Nuclear Plant Units 1 and 2,"

Revision 0; never reviewed by the NRC.

12) Westinghouse Proprietary Document, WNA-VR-00408-GEN, "Spent Fuel Pool Instrumentation System Requirement Traceability Matrix,"

Revision 0 reviewed by the NRC in Apri12014; current revision is Revision 1.

13) Westinghouse Proprietary Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Procedure," Revision 1 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 2.
14) Westinghouse Proprietary Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis," Revision 0 reviewed by the NRC in February 20 14; NRC did not review in April; current revision is Revision 2.
15) Westinghouse Proprietary Document, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation,"

Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.

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

Revision I reviewed by the NRC in April2014; current revision is Revision 3.

17) Westinghouse Proprietary Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure," Revision 3 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.
18) Westinghouse Proprietary Document, WNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis,"

Revision 2 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.

ES-7

Edwin I. Hatch. Nuclear Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation CEA-12-051)

Enclosure 6 Hatch Unit 1 and Hatch Unit 2 Proposed System Design Configuration to NL-15-0240 Hatch Unit 1 and Hatch Unit 2 Proposed System Design Configuration U 1 and U2 Proposed System Des ign Conf iguration Unit 1 Rx Bldg Unit 2 Rx Bldg EL. Sensor Sensor EL. Sensor 228' lA 2A 2 28' 28 V\l* ......... f!l,. . .

EL. Xmtr El. 164 Stalrw~II 1 Rl08 El. 164 Stal rw~ll 2R208 1 Xmtr El. Xmtr 203' lA 2A 203' 28 Electronics cabinet Display Airlock lA Existing 2T43*H56U El.

164' El.

164' Existing Pen Electronics Alr1ock Roof Electronics cabinet cabinet Display Display 1 lR24*SOll  : 2A 28

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600VMCC IC  : 600V MCC '8 ESS 01v 1 I ESSOIV 2 I

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