NOC-AE-15003225, Fourth Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation

Fourth Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation

ML15069A220
Person / Time
Site:	South Texas
Issue date:	02/26/2015
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NOC-AE-15003225, TAC MF0827, TAC MF0828
Download: ML15069A220 (16)

Text

Nuclear Operating Company South Tes Project Electric Generat'ng Station PO. Box 289 Wadswonth, Texas 77483 /

February 26, 2015 NOC-AE-15003225 10 CFR 2.202 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Unit 1 & 2 Docket Nos. STN 50-498, STN 50-499 4 th Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0827 and MF0828)

References:

1. Letter, Eric Leeds to All Power Reactor Licensees, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," March 12, 2012 (EA-1 2-051) (ST-AE-NOC-1 2002271)

(ML12054A679)

2. Letter, D. L. Koehl to NRC Document Control Desk, "Overall Integrated Plan Regarding Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," February 28, 2013 (NOC-AE-1 3002959) (ML13070A006)

3. NRC letter, "South Texas Project, Units 1 and 2 - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-1 2-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828),

June 7, 2013 (ML131149A09)

4. Letter, G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828), June 25, 2013 (ML13190A466)

5. Letter, G. T. Powell to NRC Document Control Desk, Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828), August 27, 2013 (ML13249A078)

6. NRC Letter, South Texas Project, Units 1 And 2 - Interim Staff Evaluation and Request For Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0827 AND MF0828), September 19, 2013 (ML13254A210)

STI 34057731

NOC-AE-1 5003225 Page 2 of 3

7. Letter, G. T. Powell to NRC Document Control Desk, 2 nd Six-Month Status Update of Overall Integrated Plan in Response to Order EA-1 2-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) February 27, 2014 (ML14066A388)

8. Letter, G. T. Powell to NRC Document Control Desk, 3 rd Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) August 27, 2014 (ML14251A028)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) modifying licenses with regard to requirements for reliable spent fuel pool instrumentation. On February 28, 2013, STP Nuclear Operating Company (STPNOC) submitted an Overall Integrated Plan (Reference 2) in response to the NRC Order. By letter dated June 25, 2013 (Reference 4), STPNOC provided additional information requested by the NRC in References 3 and 6 in regard to our Overall Integrated Plan. The purpose of this letter is to provide our fourth six-month status of our Overall Integrated Plan pursuant to Section IV, Condition C.2, of Reference 1.

The STPNOC status report is provided in the attachment. The report provides an update of milestone accomplishments required to implement the Order since submittal of the Overall Integrated Plan, including any changes to the compliance method and schedule.

There are no regulatory commitments in this letter.

If there are any questions, please contact Robyn Savage at 361-972-7438.

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

Executed on: c,, i,t. ZO 15 G. T. Powell Site Vice President

Attachment:

Six Month Status Report for the Implementation of Order Number EA-12-051 -

Reliable Spent Fuel Pool Instrumentation STI 34057731

NOC-AE-15003225 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission Steve Frantz, Esquire 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Senior Project Manager U.S. Nuclear Regulatory Commission NRG South Texas LP One White Flint North (MS 8 G9A) John Ragan 11555 Rockville Pike Chris O'Hara Rockville, MD 20852 Jim von Suskil NRC Resident Inspector CPS Enery U. S. Nuclear Regulatory Commission Kevin Polio P.O. Box 289, Mail Code: MN116 Cris Eugster Wadsworth, TX 77483 L. D. Blaylock Eric Leeds Crain Caton & James, P.C.

Director, Office of Nuclear Reactor Peter Nemeth Regulation U.S. Nuclear Regulatory Commission One White Flint North (MS 13 H 16M) City of Austin 11555 Rockville Pike Cheryl Mele Rockville, MD 20852 John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free

Attachment NOC-AE-15003225 ATTACHMENT SIX MONTH STATUS REPORT FOR THE IMPLEMENTATION OF ORDER NUMBER EA-12-051 RELIABLE SPENT FUEL POOL INSTRUMENTATION

Attachment NOC-AE-1 5003225 Page 1 of 12 Six Month Status Report for the Implementation of Order Number EA-12-051 -

Reliable Spent Fuel Pool Instrumentation

References:

1. Letter, Eric Leeds to All Power Reactor Licensees, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation,"

March 12, 2012 (EA-1 2-051) (ST-AE-NOC-1 2002271) (ML12054A679)

2. Letter, D. L. Koehl to NRC Document Control Desk, "Overall Integrated Plan Regarding Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," February 28, 2013 (NOC-AE-1 3002959)

(ML13070A006)

3. NRC letter, "South Texas Project, Units 1 and 2 - Request for Additional Information RE:

Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828), June 7, 2013 (ML131149A09)

4. Letter, G. T. Powell to NRC Document Control Desk, "Response to Request for Additional Information Regarding the Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828),

June 25, 2013 (ML13190A466)

5. Letter, G. T. Powell to NRC Document Control Desk, Six-Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) August 27, 2013 (ML13249A078)

6. NRC Letter, South Texas Project, Units 1 And 2 - Interim Staff Evaluation and Request For Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0827 AND MF0828), September 19, 2013 (ML13254A210)

7. Letter, G.T. Powell to NRC Document Control Desk, 2 nd Six Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) February 27, 2014 (ML14066A388)

8. Letter, G.T. Powell to NRC Document Control Desk, 3 rd Six Month Status Update of Overall Integrated Plan in Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC Nos. MF0827 and MF0828) August 27, 2014 (ML14251A028)

9. NRC Japan Lessons-Learned Project Directorate Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29, 2012 (ML12221A339)

10. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-1 2-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, August 2012 (ML122400399)

Attachment NOC-AE-1 5003225 Page 2 of 12

11. EPRI TR-1 07330, "Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in Nuclear Power Plants"

12. STP Calculation No. CC09973, Qualification of Horn & Transmitter Supports for Spent Fuel Pool Level Indicator

13. IEEE Standard 344-2004, "Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations" Reference 2 provided the Overall Integrated Plan which the STP Nuclear Operating Company (STPNOC) will implement for Units 1 and 2 to comply with the requirements of NRC Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" (Reference 1), NRC Interim Staff Guidance JLD-ISG-2012-003, Revision 0, (Reference 9) and NEI Report 12-02, Revision 1 (Reference 10). This attachment provides an update of milestone accomplishments since submittal of the third status update (Reference 8) of the Overall Integrated Plan. This report also provides an update to information requested in Reference 6.

Attachment NOC-AE-15003225 Page 3 of 12 SIX MONTH STATUS REPORT ORDER EA-12-051, RELIABLE SPENT FUEL POOL INSTRUMENTATION STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1. Introduction This attachment provides the fourth update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method and schedule.

As discussed in Reference 1, any changes to the requirements in NRC JLD-ISG-2012-003 or NEI 12-02 may require relief from the requirements and schedule documented in the Overall Integrated Plan.

2. Milestone Accomplishments STPNOC has installed the Spent Fuel Pool Level Instruments in Unit 2. The calibration and testing still needs to be complete. Full implementation of the Order in Unit 2 will be no later than prior to the start-up from Refueling Outage (2RE1 7), currently scheduled for April 26, 2015. Full implementation of the Order in Unit 1 will be completed no later than prior to the scheduled start-up from Refueling Outage (1 RE1 9), currently scheduled for November 16, 2015.

3. Milestone Schedule Status There are a few changes to the status of the milestones in the integrated plan that were submitted in the last status report submitted on August 27, 2014 (Reference 8).

Unit 1 Milestones are as follows:

• Design/Engineering - complete, with one exception. STPNOC is adding a protective guard on one of two waveguides - See the response to RAI #1 for additional details.

The guard will be designed and installed prior to the start-up from the Refueling Outage (1RE19).

• Purchase of instruments & equipment - complete

• Receipt of equipment - complete

• Unit 1 Installation & Functional Testing - October 2015 with full implementation prior to the start-up from the Refueling Outage (1RE19).

Unit 2 Milestones are as follows:

• Design/Engineering - complete, with one exception. STPNOC is adding a protective guard on one of two waveguides - See the response to RAI #1 for additional details.

The guard will be designed and installed prior to the start-up from the Refueling Outage (2RE17).

• Purchase of instruments & equipment - complete

• Receipt of equipment - complete

• Installation & Functional Testing - Installation of the instrumentation is complete.

Calibration/testing is expected to be completed in March 2015.

• Installation of protective guard on one of the two waveguides will be completed prior to the start-up from the Refueling Outage (2RE1 7). See the response to RAI #1 for additional details.

Attachment NOC-AE-1 5003225 Page 4 of 12

4. Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan.

5. Open Requests for Additional Information (RAIs)

See responses to information requested in Reference 6. The recent onsite NRC audit of STP's Spent Fuel Pool Level Instruments (SFPLI) implementation of the Order occurred the week of February 9, 2015. Three specific items remained open following the exit: RAI #1, RAI #2 and RAI #10. The responses to these RAls have been revised and/or additional information has been provided below. Response to RAls #16, #17, and #19 on training and procedures have also been updated.

NRC RAI #1 (Reference 6)

In its letter dated June 25, 2013, the licensee provided a sketch depicting the waveguide piping for the two redundant channels as 1 in, stainless steel pipes. The NRC staff noted that this sketch depicts the two pipes to be run side by side from the through-the-air horn to the sensor receivers located in the Mechanical Auxiliary Building (MAB), and from there, cabling for the two instrument channels seem to be run side by side to the display units mounted in the Radwaste Control Room. The NRC staff has concerns regarding the routing of these two channels in accordance with the guidance on channel separation as described in NEI 12-02. Additional information is needed forthe staff to complete its evaluation.

Please provide additional information describing how the proposed arrangement of the waveguides and routing of the cabling between the radar horns and the electronics in the Radwaste Control Room 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.

STPNOC Revised Response: (Additional information or changes added in bold italics)

The following information should provide assurance that STP's plan meets the Order:

1. STP's Spent Fuel Pools (SFPs) are located inside safety related buildings, designed to protect against external missiles.

2. Everything mounted above and around the SFP is mounted to seismic 11/1 criteria. That is components and their supporting structures which are not seismic Category 1 and whose collapse could result in loss of required function of structures, equipment or systems required after a seismic event maintain their integrity against collapse when subjected to a seismic event.

3. Review of internal generated missile calculations shows no concerns for internal missiles from rotating equipment or pressurized bottles on the operating deck of the Spent Fuel Pool.

4. The radar horns are separated on the north end of the SFP by approximately 20 feet. There are several obstructions that prevent any further separationon the north end. The horns could only be installed on the north end of the pool because the Spent Fuel Handling (SFH) machine rails on the pool deck run the entire length of the east and west sides of the pool.

Attachment NOC-AE-15003225 Page 5 of 12

5. The reason the south side of the SFP (shortside) was not utilized for one of the horns was because the waveguide run would have exceeded the design parametersof the system, due to the number of bends and the length of pipe that would have been required. The south side of the pool across the SFP deck, has limited space to run the waveguide because of removable hatches, new fuel inspectionarea, and other recessed areas on the SFP area operating deck. Additionally, in order to clear the SFH machine rails in the south direction, the waveguide would have to run along the SFP floor more than 100 feet, before it had a bend to direct it outside the SFP area.

This additional100 feet would challenge the design criteria limitation on waveguide length, bends and complexity.

6. The waveguide is physically separatedthroughoutthe runs to the sensors which are located inside the MechanicalAuxiliary Building. The waveguide and supports will remain fully intactand the instrumentationfunctional during and after STP's Safe-Shutdown Earthquake (SSE). The waveguide supports and associated instrumentationwere analyzed and will remain functional subsequent to the highest seismic input of the SFP at STP. This is consistent with requirementsas described in Section 3.3, Mounting of NEI 12-02 (Reference 10). The conduit supports and associatedinstrumentationare designed and qualified to remain fully intact during and after STP's Safe-Shutdown Earthquake(SSE). See also STPNOC response to RAI

1. 10 below.

7. From the sensors, the cabling will run in separate conduit to the power control panels located inside the Radwaste Control Room.

8. A Heating, Ventilation, and Air Conditioning (HVAC) duct (seismically mounted Il/I) runs along the north wall above both waveguides and provides protection from falling objects as discussed in the Order. There are places along the wall where two different seismically mounted HVAC ducts provide this protection. The inherent shieldingprovided by the HVAC duct also provides protection againstmissiles.

9. The approximately 40' of waveguide piping run is separated by 8 1/4" vertically. The following was considered in determining the location and configuration of the wave guide piping. The waveguides are run close together to avoid obstructionssuch as existing conduit, piping, lighting panels, removable access hatches, and a transformerwhich would make the waveguide path too torturous. A minimum number of bends in the waveguide piping is required to ensure proper operation.

10. The location of the waveguides, 7 feet above the SFP deck, was necessary to limit any potentialdamage from personnel traversing that area as well as to reduce the safety hazard and obstructions of personnel working in the area. It also aids in ensuring personnel/equipmentwill not come in contact with or damage the waveguide. The intermediate area (3 - 5 feet) above the SFP deck was not a feasible location because of existing lighting panels and equipment that need to be accessed.

11. Where the waveguides are run in close proximity in the Fuel Handling Building (FHB)

(approximate40' run), STP will install a protective guard for one of the two waveguides.

STPNOC considers the status of this item to be OPEN

Attachment NOC-AE-15003225 Page 6 of 12 NRC RAI #2 (Reference 6)

The NRC staff notes that the proposed application of such seismic design criteria appears to be reasonable and addresses the staff-endorsed NEI 12-02 guidance stating that the channel is to be designed to be consistent with the highest seismic or safety classification of the SFP. The licensee's proposed plan, with respect to the seismic design of the mounting, appears to be consistent with NEI 12-02, as endorsed by the ISG. The staff plans to verify the results of the licensee's seismic testing and analysis report when it is completed based on the licensee's response to the following RAI.

Please provide the analyses verifying that the seismic testing of the horn and waveguide assembly and the electronics units, and the analysis of the combined maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly exposed to the potential sloshing effects, show that the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure.

STPNOC Response: (NOTE: Included RAI #2 for completeness regardingdiscussion on response to seismic qualification of the instruments. See response to RAI #10.)

The horn and waveguide assembly and the electronics units were successfully seismically tested in accordance with the requirements of the Institute of Electrical and Electronics Engineers (IEEE) Standard 344-2004 (Reference 13), (see the response to NRC RAI #10, below for further explanation of this test). In addition to the seismic test, an analysis of the combined effects of the seismic and hydrodynamic forces on the cantilevered portion for the assembly exposed to the potential sloshing effects was performed and the results were satisfactory. Reference 12 is being revised to clarify the seismic evaluation.

STPNOC considers the status of this item to be OPEN NRC RAI #10 (Reference 6)

The NRC staff notes that the licensee will demonstrate the reliability of the seismic design and installation in accordance with NEI 12-02, as endorsed by the ISG. The licensee's planned approach with respect to the seismic reliability of the instrumentation appears to be consistent NEI 12-02, as endorsed by the ISG. However, the staff plans to verify the results of the licensee's seismic test when it is completed.

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 to anticipated for the SFP structures at STP, has been adequately demonstrated.

STPNOC Revised Response: (Additional information added in bold italics)

The sensor, indicator, power control panel, horn end of the waveguide, standard pool end and sensor end mounting brackets, and waveguide piping were successfully seismically

Attachment NOC-AE-15003225 Page 7 of 12 tested in accordance with the requirements of IEEE Standard 344-2004 (Reference 13). The system was monitored for operability before and after the resonance search and seismic tests. The required response spectra used for the five Operating Basis Earthquakes (OBE) and one Safe Shutdown Earthquake (SSE) in the test were taken from EPRI TR-107330, Figure 4-5 (Reference 11). This test level exceeds the building response spectra where the equipment will be located. The standard pool end mounting bracket used in the seismic test differs from the ones that will be used at STP. Separate seismic qualification analyses were performed on the pool end mounting brackets, waveguide intermediatemounting brackets, sensor mounting brackets and the power control panel mounting. These supports are designed to meet the STP seismic criteriafor the FHB and MAB, which are Category I structures. These supports will remain fully intactduring and after STP's Safe-Shutdown Earthquake(SSE). This is consistent with requirementsas describedin Section 3.3, Mounting of NEI 12-02 (Reference 10). STP calculationsare being revised to provide clarificationof the seismic evaluationperformed.

STPNOC considers the status of this item to be OPEN NRC RAI #16 (Reference 6)

The NRC staff has concerns with the licensee's lack of information regarding the training of personnel for activities such as use of the instrument channels, provision for alternate power, and calibration and surveillance of the SFP instrumentation. Another staff concern is the lack of information on the licensee's approach to training with respect to the SFP instrumentation.

Please describe the activities for which personnel will be trained, such as use of the instrument channels, provision of alternate power, calibration and surveillance. Describe the approach to training used to identify the population to be trained and determined the initial and continuing elements of the required training for the SFP instrumentation.

STPNOC Response:

Operations Training The Spent Fuel Pool level indication changes were evaluated and no new tasks, or changes to existing tasks were identified for licensed and non-licensed operators. The new configurations are covered by existing tasks and learning objectives with only changes to the technical content.

The technical changes were distributed for update to training materials for the Initial Licensed and Non-Licensed Operator lesson plans. The technical changes were presented in the Licensed and Non-Licensed Operator Requalification training programs during the recent Spent Fuel Pool Cooling and Cleanup system review lesson presented in training cycle 142 and the FLEX implementation training presented in training cycle 145 in 2014. Spent Fuel Pool Cooling and Cleanup system requalification review is every 4 years. In addition to this training, Licensed and Non-Licensed Operators will receive email training bulletins on all new or revised operations procedures regarding operation/use of the SFP level instrumentation.

Instrumentation & Control (I&C) Technician Training I&C technician initial apprentice training lesson plan IMT 303, Level Measurement was revised to include the operation and calibration of the radar level sensing technology used for the new

Attachment NOC-AE-15003225 Page 8 of 12 Spent Fuel Pool (SFP) level instrumentation. This same technology is used in the Diesel Fuel Oil Storage Tank (DFOST) and the Caustic tank. A Needs Analysis in accordance with the Systematic Approach to Training was conducted for the Spent Fuel Pool level indication and the Fluke 705 Calibrator to determine the elements of the training required for operation and calibration of the level detection system. The Curriculum Review Committee approved covering both during cycle training in the summer 2015 (ICC151) for certified I&C technicians even though the same technology instrumentation was included in initial I&C training which has been conducted since 2006.

STPNOC considers the status of this item to be CLOSED.

NRC RAI #17 (Reference 6)

The NRC staff has concerns with the licensee's lack of information about its plans to develop procedures. The staff previously requested this information as RAI-10 in NRC letter dated June 7, 2013. However, based on feedback from licensees, the staff revised this RAI as follows:

Please provide a list of 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. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

STPNOC Response:

STPNOC is developing and/or revising the following procedures/ preventive maintenance activities for the operation, calibration, maintenance, testing, and inspection of the new spent fuel pool level instrumentation.

Procedure No. or Title Technical Objectives Preventive Maintenance No.

OPOP01-ZQ-0022 Plant SFP level instrument periodic channel check Operations Shift comparing the two level channels.

Routines 0POP09-AN-22M2 Annunciator Annunciator response procedure for Control Lampbox Room Panel CP022 will include guidance on 22M02 SFP level indication available locally or on Response the plant computer.

Instructions 0POP04-FC-0001 Loss of Spent Off-normal operating procedure for Fuel Pool Level responding to SFP Hi/Lo levels or loss of or Cooling cooling to SFP including identification of conditions for transition to Severe Accident Management Guidelines SCG-5 & SAG-9 and OPOP12-ZO-FSG 11

Attachment NOC-AE-15003225 Page 9 of 12 Procedure No. or Title Technical Objectives Preventive Maintenance No.

OPOP04-AE-0003 Loss Of Power Off-normal procedure for response to loss of To One Or normal power to the Remote SFP level More 13.8 KV instrument Standby Bus OPOP04-ZO-0001 Control Room Off-normal procedure for response to Control Evacuation Room evacuation OPOP04-SY-0001 Seismic Event Off-normal procedure for response to a seismic event OPOP04-ZO-0002 Natural or Off-normal procedure for response to a Destructive severe weather Phenomena Guidelines OPOP05-EO-ES01 Reactor Trip Emergency Operating Procedure for Reactor Response Trip response which includes periodic verification of SFP cooling and level OPOP12-ZO-FSG11 Alternate SFP FLEX Support Guideline for providing Makeup and alternate method (i.e., FLEX SFP makeup Cooling pump) for filling SFP during Extended Loss of AC Power event. Remote SFP level monitoring provided by new SFP level instrument.

SAG-9 Refill the Spent Severe Accident Management Guide Fuel Pool (SAMG) for mitigating severe accident in the Fuel Handling Building where spent fuel overheating and potential for fission product release exists SCG-5 Recover Spent Severe Accident Management Guide where Fuel Pool Level spent fuel has been uncovered and potential for fission product release and hydrogen combustion exists OPMP08-FC-1401 AND FLEX SFP Periodic calibration of the spent fuel pool associated Preventive Level Loop level indication channels which will include Maintenance (PM) Calibration calibration on backup power.

activities This will be performed in accordance with the PM 15127 & 15212 (Unit STP PM program and NEI 12-02 guidance

2) and similar PMs will be (Reference 10).

developed for Unit 1

Attachment NOC-AE-1 5003225 Page 10 of 12 Procedure No. or Title Technical Objectives Preventive Maintenance No.

PM activities Replace SFPLI Periodic replacement of Battery backed Back Up Power power for spent fuel pool level indication PM 15213 & 15131 (Unit Supply channels.

2) and similar PMs will be Batteries.

developed for Unit 1 This will be performed in accordance with the STP PM program and NEI 12-02 guidance (Reference 10).

PM activities Replace SFPLI Periodic replacement of the sensors for spent Sensor fuel pool level indication channels.

PM 15253 & 15254 (Unit

2) and similar PMs will be This will be performed in accordance with the developed for Unit 1 STP PM program and NEI 12-02 guidance (Reference 10).

OPOP06-PE-00L2/ Load Center Provides guidance for actions to take when 0POP06-PE-OOSO 1L2 (2L2) and de-energizing the normal power supplies for 1S (2S) Bus the remote SFP level instrument for Outage maintenance on the applicable bus.

STPNOC considers the status of this item to be CLOSED.

NRC RAI #19 (Reference 6)

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) A description of how the guidance in NEI 12-02 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.

(This information was previously requested as RAI-1 1 in NRC letter dated June 7, 2013)

Attachment NOC-AE-1 5003225 Page 11 of 12 STPNOC Response:

a) STPNOC will perform periodic channel checks and channel calibrations of the SFP level instrumentation. Preventive maintenance activities are being developed to replace the SFP level instrumentation batteries and replace the SFP level instrumentation sensor in accordance with the STP PM program, vendor recommendations and NEI 12-02 guidance (Reference 10).

b) A new procedure is being developed (0PGP03-ZO-0056) that will list compensatory actions for non-functioning FLEX and SFP level instrument equipment in accordance with NEI 12-02 Section 4.3 (Reference 10) as described in item c below.

c) Both primary and backup SFP level instrument channels incorporate permanent installation (with no reliance on portable, post-event installation) of relatively simple and robust augmented quality equipment. Permanent installation reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) is (are) out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:

CONDITION REQUIRED ACTION COMPLETION TIME A. One FLEX SFP level A.1 Verify associated alternate FLEX Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instrument NOT functional. SFP level is functional. Note (1)

AND Restore non-functional FLEX Within 90 days SFP level instrument to functional status.

B. Action A.1 completion time B.1 Initiate compensatory action in Within 14 days not met, accordance with Note (2) below.

OR One FLEX SFP level instrument expected to be non-functional for greater than 90 days.

C. Two FLEX SFP level C.1 Initiate actions to restore one Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instruments NOT SFP level instrument to functional. functional status.

AND Initiate compensatory action in Within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> accordance with Note (2) below.

(1) Compare local level indication to functional remote SFP level indication once per shift.

Attachment NOC-AE-15003225 Page 12 of 12 (2) Present report to Plant Operations Review Committee within following 14 days. The report shall outline planned alternate method of monitoring, cause of non-functionality, and schedule for restoring level instrument channel(s) to functional status.

STPNOC considers the status of this item to be CLOSED.

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

7. Potential Draft Safety Evaluation Impacts None