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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)
	ML15245A338
Person / Time
Site:	Seabrook
Issue date:	08/27/2015
From:	Dean Curtland; NextEra Energy Seabrook
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-051, SBK-L-15138, TAC MF0837
	Download: ML15245A338 (95)
	v • d • e

ENERGY '4 August 27, 2015 SBK-L-15 138 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, LLC's 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-12-05 1)

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-05 1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29, 2012 (ML12221A339)

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-05 1, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 1, August 2012

4. NextEra Energy Seabrook, LLC Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (Order Number EA-12-05 1), October 26, 2012 (ML12311A012)

5. NextEra Energy Seabrook, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, (Order Number EA- 12-05 1), February 26, 2013 (ML13063A439)

6. NextEra Energy Seabrook, LLC, First Six Month Status Report for the Implementation of Order EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, August 28, 2013 9ADAMS Accession No. ML13247A177).

'7. Seabrook Station, Unit 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA 051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0837), December 4, 2013 (ADAMS Accession No. ML13267A388).

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 U C

U.S. Nuclear Regulatory Commission SBK-L- 15 13 8/Page 2

8. NextEra Energy Seabrook, LLC, Second Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, February 27, 2014 (ADAMS Accession No. ML14064A189).

9. NextEra Energy Seabrook, LLC, Third Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, August 24, 2014 (ADAMS Accession No. ML14246A192).

10. NextEra Energy Seabrook, LLC, Fourth Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, February 27, 2014 (ADAMS Accession No. ML15068A007).

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra). Reference 1 was immediately effective and directs NextEra to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

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. 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 NextEra initial status report regarding mitigation strategies. Reference 5 provided the NextEra overall integrated plan. Reference 6 provided NextEra' s first six-month status report. In Reference 7, the NRC requested additional information to enable the continued technical review of the NextEra Energy Seabrook Overall Integrated Plan (OIP). Reference 8 provided an update of milestone accomplishments since the last status report, including changes to the compliance method, schedule, or need for relief and the basis, if any. It also provided responses to the Reference 7 request for additional information to the extent possible. Reference 9 provided the third update of milestone accomplishments and also included answers to the request for additional information. Reference 10 provided the fourth update of milestone accomplishments.

The attachment to this letter provides the fifth six-month status update of milestone accomplishments since the last status report, including changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.

11.S. Nuclear Regulatory Commission SBK-L-15 138/Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August ZI , 2015.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President Attachment cc: D. Dorman, NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 P. Cataldo, NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratclhnann, NRR/JLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency) Management Agency 400 Worcester Road Framingham, MA 0 1702-5399

Attachment to SBK-L- 15138 NextEra Energy Seabrook, LLC's 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'

4.0 CHANGES TO COMPLIANCE METHOD The Order includes the following requirement:

The spentfuel pool level instrument channels shall be arrangedin a manner thatprovides reasonableprotection of the level indicationfunction againstmissiles that may resultfrom damage to the structure over the spentfuel pool. This protection may be provided by locating the primary instrument channel andfixed portions of the backup instrument channel, ifapplicable, to maintain instrument channel separationwithin the spentfuel pool area, and to utilize inherent shieldingfrom missiles provided by existing recesses and corners'in the spent fuel pool structure.

NEI 12-02 guidance on this requirement states that:

The intent of the arrangementrequirement is to specify reasonableseparationand missile protection requirementsfor permanently installedinstrumentation used to meet this order.

Separation and shielding can help minimize the probability that damage due to an explosion or extreme naturalphenomena (e.g., wind-driven missiles) will renderfixed channels ofSFP instrumentation unavailable. However, the intent of this requirement is not to constrain the design of the SFP instrumentationchannels to the extent that it unduly impairs reliability, operability, or maintainabilityof the instrumentation. To the extent practical,the SFP instrumentation channels should not impair the ability to accomplish normal SFP operations and associatedsupport activities, nor other activities that take place on the SFP deck. Installation of the SFP instrument channels shall be consistent with the plant specifc SFP design requirements.

Channel separationshould be maintainedby locating the installed sensors in different places in the SEP area. Jfpractical, examples of sensor location arrangementsare

on opposite sides or corners of the pool area,

separatedby a distance comparable to the shortest length of a side of the pool,

in recesses of the pool to maximize the inherent missile protection provided by the pool walls,

cask decontaminationpits andfuel transfer tube areas, or

next to or connected to structures that are securely connected to the side of the pool (e.g., a new fuel elevator) which may provide some protectionfrom falling debris or missiles.

The Overall Integrated Plan for Seabrook Station stated that the primary and backup instrument channel sensors for monitoring Spent Fuel Pool level for Seabrook Station would be located in the northwest and southwest corners of the Spent Fuel Pool (SFP) with the signal cable routed in rigid steel conduit to the adjacent west wall of the Fuel Storage Building (FSB). Each conduit would be routed on its own separate independent series of seismically qualified supports to level transmitters located in the Containment Enclosure Building (CEB) using Class 1EB type separation as currently assumed in the plant design basis. The plan also noted that the corners of the SFP would provide inherent missile protection for the level sensor probes in the pool.

Subsequently, a detailed field review of the plan has identified several implementation concerns with this plan. Installation of the sensor mounting brackets would require removal of 1/2 inch steel plates that were installed during plant construction to form the non-pool side of the curb that supports the stainless SFP liner. These plates are recessed into the Fuel Handling Machine (FHM) rail pockets and their removal would be very difficult.

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The process of removing the plates also presents risk for potential damage to the SFP curb, loss of EME and personnel safety concerns due the limited work space next to the pool. The final design will also result in limited clearance (A1-1/2 inch) between the sensor mounting brackets and the frame of the FHM. Considering these concerns, alternative locations for SEP level sensor mounting have been evaluated. Based on current activities for SEP operations, and considering the physical limitations for mounting the sensor bracket and sensor signal cable access, the west side of the SEP is considered to be the preferred mounting location for both the primary and backup instrument channel sensors.

This submittal also documents minor revisions to previous NextEra responses to Nuclear Regulatory Commission (NRC) requests for additional information regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation. These include:

1. Revised acceptance criteria for channel checks. The level displayed by the SEPIS channels will be verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as part of Nuclear System Operator (NSO) rounds. This verification will compare level readings from the SEPIS channels (1-SF-LI-2616/1l-SF-LI-2617) to the existing control room SEP level indication (1-SF-LI-2607). Channel maintenance including channel calibration(s) will be initiated if the deviation between indicated level readings exceeds the bounding uncertainty of SEP level readings between the existing SEP level indicators (1-SF-LI-26 07, +/-/- 2 in.) and the new SEPIS indicators (+/-/-3 in). Channel maintenance and!/or channel calibration shall be initiated if the deviation between indicated level readings exceeds 3.0 inches between the new SEPIS indicators or 2.0 inches between the new SFPIS indicator and the existing 1-SF-LI-2607 indicator.

2. Provided clarification on the Westinghouse established unmeasurable zones (instrument sensitivity bands) of the sensor probe for the SEPIS. The instrument sensitivity band at the top of the probe is 12 inches. Therefore, the SEP level instrument upper range will be at least 15 inches above Level 1 (Elev. 23 ft,. 4 in.) to account for the upper instrument sensitivity band and instrument loop uncertainty. The instrument sensitivity band at the bottom of the probe is 4 inches. The established elevation for Level 3 (Elev. (-) 6 in) will not need to be affected to provide additional margin for instrument sensitivity band and uncertainty. An indicated level on either the primary or backup instrument channel of greater than plant elevation (-) 0 ft., 6 in will assure that the fuel remains covered.

3. Revised the pool side bracket design to support relocation as described above.

4. Revised responses to address requests for addition information during the 2015 NRC FLEX Audit.

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5. Incorporated the following description of procedures that are being developed to maintain the system:

PM TITLE FREQ SF-L-26 16-CAL-i TRAIN A SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year SF-L-2616-BR-1 TRN A SEP LEVEL I-SF-CP-300-A BATTERY REPLACEMENT 3 Year SF-L-261 6-MAN-i TRN A SEP LVL XMTR 1-SF-LIT-26 16 REPLACEMENT 7 Year SF-L-2616-MAN-2 TRN A SEP LVL PWR SUPPLY I-SF-UQ-2616 REPLACEMENT 10 Year SF-L-26 17-CAL-I TRAIN B SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year SF-L-26 17-BR-i TRN B SEP LEVEL 1-SF-CP-300-B BATTERY REPLACEMENT 3 Year SF-L-26 17-MAN-i TRN B SEP LVL XMTR I-SF-LIT-2617 REPLACEMENT 7 Year SF-L-26 I7-MAN-2 TRN B SEP LVL PWR SUPPLY I-SE-UQ-26 17 REPLACEMENT 10 Year The following high level FSGs will direct operators to monitor SFP level using SFPIS:

FSG-0.0, Extended Loss of All AC Power with SEPS FSG-0.1, Extended Loss of All AC Power without SEPS FSG-5, Initial Assessment and FLEX Equipment Staging FSG-1 1, Alternate SFP Makeup and Cooling FSG-14, Extended Loss of All AC Power while Plant Shutdown When SFP level cannot be maintained greater than 23 feet above the top of the racks the FSG procedures direct operators to implement FSG-1 1, Alternate SFP Makeup and Cooling.

FSG-5, Initial Assessment and FLEX Equipment Staging, will provide methods to establish portable ventilation in the CEVA area when area temperature is greater than 130°F.

FSG-5, Attachment G, Restore Miscellaneous Lighting and Pipe Chase Ventilation Power, will provide an alternate power source to SFPIS.

The following Operating Procedures will also be revised to address alignment of the SFPIS for operation.

OS 1014.01, Spent Fuel Cleanup and Cooling System Fill and Vent (system lineup)

OS 1046.58, MCC-5 15 Maintenance Procedure OS 1046.65, MCC-615 Maintenance Procedure

5. 0 NEED FOR RELIEF!/RELAXA TION AND BASIS Consistent with the requirements of Order EA-12-05 1 (Reference 8) and the guidance in NEI 12-02 (Reference 5), the six month reports will also delineate progress made, any proposed changes in compliance methods, updates to the schedule, and if needed, requests for relief and their bases.

Evaluation of the alternate mounting locations considered FHM clearance, potential impact of bracket mounting on the attachment structure, access and maintainability of the level sensors and the impact that the location would have on normal SFP operations and support activities.

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The review also considered the potential for adjacent equipment and structure over the SFP to impact functionality of the sensors during a Beyond Design Basis External Event (BDBEE).

The evaluation considered alternate mounting locations on the east and west sides of the SFP.

The north and south sides of the SFP were not considered to be viable locations for sensor mounting since the FHM traverses the entire length of the SFP which presents the clearance and curb concerns noted above. The east side of the SFP contains the fuel transfer gate, two fuel pool lighting fixtures, two embedded SFP purification system skimmer intakes, 10 inch SFP cooling system discharge piping and 4 inch SFP filter system return piping, and a permanent storage location for one of the fuel handling tools. This side of the SEP is also used as the personnel access point and work area for SFP operations including: spotting during fuel movements, inspection camera access, Operator access for transfer gate manipulation and inspections, transfer canal inspections, and temporary storage location for radioactive wastes prior to survey and removal by Health Physics personnel. The west side of the SFP contains two SFP purification system skimmer intakes, two fuel pool lighting fixtures and the sensor for the existing SEP level instrumentation (1-SF-LE-2607). This side of the SFP is also used as the personnel access point for maintenance of the existing pool level instrumentation and cleaning of two of the skimmer intake basket filters.

Based on current activities for SFP operations, and considering the physical limitations for mounting the sensor bracket and sensor signal cable access, the west side of the SFP is considered to be the preferred mounting location for both the primary and backup instrument channel sensors. However, due to the interferences described above, e.g., the FHM rails on the north and south walls, the various appurtenances, equipment and access on the east wall and the skimmers inboard of the FHM rails on the west wall, sensor mounting will be on the west wall, physically separated by approximately 18 ft, 2 in. on center as shown on the attached sketches (Enclosure 3).

This configuration is considered to be in compliance with the requirements of references (1), (2) and (3) based on the following:

1. The FSB is a seismic Category I reinforced concrete structure designed and constructed to meet the requirements of Seabrook UFSAR §3.8.4, Reinforced concrete is designed and constructed per the American Concrete Institute code, ACI 318-71. Steel framing within the structure is designed and constructed to the requirements of the American Institute of Steel Construction code, AISC Specification for the Design, Fabrication and Erection of Structural Steel for Building, 1969 Edition. Concrete walls are a minimum of 24 inches thick concrete with a minimum compressive strength of 3000 psi. No block or concrete masoury partitions are utilized in any Category I structure at Seabrook Station. The FSB superstructure is constructed of concrete walls and roof. The building is capable of withstanding the effects of extreme natural phenomena, including earthquake, tornado, hurricanes, and floods.

2. The SEP is constructed of concrete walls having a minimum thickness of 6 feet and a 4'-

10" thick concrete floor. For leak tightness, the inside surface of the SEP is lined with stainless steel plates 3/16" thick on the walls and 1/4" thick on the floor.

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3. Structural integrity qualification of the Category I FSB for actual and postulated loads imposed by equipment mounted to the structure is addressed by local analysis of the attachment mechanism. Concrete anchors are used for attachment to the structure.

Embedded concrete anchor allowable loads are based on the anchor failing before the concrete. Thus the embedded anchor design assures that the concrete structure maintains its local structural integrity.

4. The effect of the actual and postulated loads on the global building structural integrity is a matter of comparison of the additional load to the generic design loads for the structure.

Generic design loads, as described in the structural design criteria, are used to account for undefined loads. Additional loads that exceed the generic design loads warrant an evaluation of the affected structural elements. Loads that exceed the generic design loads are not expected for the sensor mounting bracket installations. The design inputs for the attachment connection are the weight of the component, the method of attachment, the local seismic response of the building, plus any other pertinent loads per UFSAR §3.8.4.3, Loads and Loading Combinations.

5. Simple static analyses will be used to evaluate the support attachment design. This conservative analysis methodology will use peak acceleration in each of three orthogonal directions obtained from the building amplified response spectra. Those accelerations are increased by 50% to account for multi-modal response (multiplied by 1.5). Attachment loads are calculated in each of the three directions. Then loads are combined by square root sum of the squares (SRS S), and then combined with dead weight loads and compared with allowable loads. Alternatively, the stiffness of the component and support may be computed and the frequency of the first mode of vibration estimated. Should the frequency fall in the rigid range of the response spectra, then the zero period accelerations of the three orthogonal directions may be used for the static analysis described above.

Since the FSB is a Seismic Category I structure, all equipment mountings within this building are designed to remain anchored during and following a seismic event. This design provides reasonable assurance that missiles will not be generated during a BDBEE by equipment located in the areas adjacent to the alternate sensor mounting locations on the west side of the SFP (Ref. Enclosure 3). Physical separation of the SFP level sensors and instrument channel cables to the extent practicable will also be used to provide protection against missiles that may result from unexpected damage to adjacent seismically installed structures or components. Physical separation will be maintained using Class 1E type separation. The separation will be achieved through mounting to safety class structures, use of independent Seismic Category I supports and raceways, and physical distance between the channel sensors, sensor cabling, electronic enclosures and equipment mounted in the SEP or stored next to the SEP in accordance with the design criteria described in UFSAR § 8.3.1.4, "*Independence of Redundant Systems," UFSAR Appendix 8A, "Attachment C to AEC Letter Dated December 14, 1973, Physical Independence of Electric Systems," and UFESAR Table 8.3-10, "Electrical Cable and Raceway Separation Criteria." All SFP level instrument sensor equipment located in the FSB will be seismically qualified and installed to maintain the Class 1E separation criteria currently assumed in the plant design basis.

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6.0 REQUESTS FOR ADDITIONAL INFORMATION The NRC staff determined that additional information was required to enable the continued technical review of the NextEra Overall Integrated Plan (OIP). Tables 1 and 2 provide a summaly2 of the status of responses to the Request for Additional Information (RAIs) and subsequent NRC questions that were received on December 4, 2013 (Reference 10).

Enclosures 1, 2 and 3 summarize the design, support the responses in the tables and include the design requirements for the Westinghouse supplied level monitoring equipment with reference applicable Westinghouse qualification documentation. Required changes to RAI responses that result from changes in details developed since the previous submittal as discussed above have been incorporated into the tables for this submittal.

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Summary of RAL Status Open RA~s Status RAI- - Levels Complete, Reference 11 RAI Arrangement Complete, Reference 11 RAI-3 a, b, c -Mounting Complete, Table 2 RAI Mounting Complete, Table 2 RAI-5 -Mounting Complete, Reference 11 RAI-6 a, b, c -Qualification Complete, Table 2 RAI Qualification Complete, Table 2 RAI Independence Complete, Table 2 RAI Power Supply Complete, Table 2 RAT Accuracy Complete, Table 2 RA-11I- Testing and Calibration Complete, Table 2 RAI Display Complete, Table 2 RAI-13 Complete, Reference 11 RAI-14 Complete, Reference 11 RAI-15 -Testing and Calibration Complete, Table 2 References

1. NRC Electronic Mail to NextEra Energy Seabrook, LLC, "Draft Requests for Additional Information Regarding the Seabrook Overall Integrated Plan for Reliable SFP Instrumentation, dated July 18, 2013 (ADAMS Accession No. ML13217A166).

2. NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-05 1), dated February 26, 2013 (ADAMS Accession No. ML13063A439)

3. NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 22, 2013 (ADAMS Accession No. ML13063A438)

4. NRC JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29, 2012.

5. 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, August 2012.

6. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012.

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7. Seabrook Calculation C-S-1-24606, "Spent Fuel Pool Level for Reliable Pump Suction,"

Revision 00.

8. NRC Order BA- 12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 (ADAMS Accession No ML12056A044).

9. NextEra Energy Seabrook, LLC, First Six Month Status Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation ," dated August 28, 2013 (ADAMS Accession No. ML13247A177).

10. Seabrook Station, Unit 1 - Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA- 12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0837), Dated December 4, 2013 (ADAMS Accession No. ML13267A388).

11. ML14064A189, NextEra Seabrook, LLC, Second Six-Month Status Report I Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 27, 2014.

12. ML14246A192, NextEra Energy S eabrook, LLC's Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number BA- 12-051), dated August 24, 2014.

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RAI No. ,'NRC QUESTION*:': . . ,': LICENSE REsPONsE,:":*", ,° ....

RAI 1-The OJP states, in part.that:

NextEra Response RAI-I .a Level 1its the level adequate to support operation of the. Enclosure 1 contains an elevation view of the proposed arrangement for the portions of the instrument channel consisting of norm~al fuel pool cooling svstenm - Based on permanent measurement channel equipment. In addition, the datum values for the Levels 1, 2 and 3 are depicted based on 1oreliminare calculation,the low level limit for reliable assumed sensitivity and instrument ioop accuracy.

SEP coolin system operationcorresponds to an elevation of approximatelyv22ft.. 6 in. This level is For Level 1, the two points described in the NEI 12-02 guidance are; the level at which reliable suction loss occurs due to bas*ed on a preliminarv calculation that assumes uncovering of the coolant inlet pipe, weir or vacuum breaker (depending on the design), or the level at which the water height, mitigating effects byv the installedsuction straineron assuming saturated conditions, above the centerline of the cooling pump suction provides the required net positive suction vortexing. The actual effect of the straineron this level head specified by the pump manufacturer or engineering analysis.

w*ill be determinedduring the engtneeringand design ahase of the oraoject.

To determine the higher of the two levels the following was taken into consideration:

For the purooses oft this submittal the minimum level (1) The level at which reliable suction loss occurs due to uncovering the coolant inlet pipe or any weirs or vacuum that will be adequateto support normal fuel pool breakers associated with suction loss. This level was established based on nominal suction strainer inlet elevation coolingsystem operation.as indicatedon either the primaryor backuo instrument channel, is assumedto and conservative estimate for the onset of vortexing. The actual effect of the strainer on this level has been formally determined by calculation C-S-i1-24606, "Spent Fuel Pool Level for Reliable Pump Suction," (Reference corr"espondto a olant elevation of22 ft.. 6 in. 36). The elevation for reliable pump suction is plant elevation 23 ft., 4 inches.

(2) The level at which the normal spent fuel pooi cooling pumps lose required NPSH assuming saturated conditions shieldine fur a oerson standingon the soent fuel pool in the pooi. Reference 36 demonstrates that the point of zero NPSH margin is 22 ft., 4 inches of plant elevation.

operating deck - Indicated level on either the primarv With the spent fuel pool at 212 degrees F, saturated conditions, the NPSHA is approximately 11.2 ft. The NPSHR or backup instrument channel ofgreater than an for the pump is 1l ft, at 212 degrees F. This results in a ratio of NPSHA/NPSHR value of approximately 1.12.

elevation of 10 ft.. 9.5 in will orovide substantial Therefore, the NPSHA is greater than the NPSHR at saturated conditions.. The higher of the above points is the radiationshieldine for a person standing on the SEP level where the inlet strainer will lose suction (Item (1) above). Therefore, Level 1 has been revised to elevation ooeratingdeck. This elevation is approximately13 feet 23 ft., 4 inches for both the primary and backup instrumentation.

above the top of the soentfuel oositioned in the oool The SFP level instrument upper range will be at least 12 inches above Level 1 to account for upper instrument sensitivity band (Nominal Elev. (-) 1 ft., 5-3/4 in.). With 13 feet ot and instrument ioop uncertainty. From a practical perspective, the upper range capability will extend even higher (e.g. above water above the highest futel elementpnosition. the normal operating level).

calculateddose rate at the surface of the SEP is less than 2.5 mrem/hr (Reference 10, Section Level 3 has also been revised to provide margin for the instrument sensitivity band and uncertainty. For the purposes of this 12.3.2.1.c). This monitoring level ensures there is submittal level on either the primary or backup instrument channel that corresponds to a plant elevation of greater than (-) 0 ft.,

adeauate water level to torovide substantialradiation 6 in will assure that the fuel remains covered.

Basis External Events inchudingthe initiation of SFP makeup strategiesthat would require access to the Fuel Storage Building (FSB).

NextEra Response RAI-I.b J. I Page ilof 20

"RAt No.* NRC QUESTION ,,: , ,- : i, :E LICENSE.. R ESPONSE*: :, .. ,:. ...- ,.,* .* ** *. ... ,

Level 3 is where futel remains covered - Indicatedlevel on Enclosure 1 contains an elevation view of the proposed arrangement for the portions of the instrument channel consisting of either the primarv or backup instrument channel of permanent measurement channel equipment. In addition, the datum values for the Levels 1, 2 and 3 are depicted as well as greaterthan Elevation (-) l foot. This is the nominal the assumed accuracy of the equipment.

iiaterlevel approximately6 in. above the top of the futel racks. This monitoring level will assure the maximum Westinghouse has established that the accuracy for the SFPIS will be +/- 3.0 inches (Reference 22). Westinghouse has also range of level informationis available to the alant established the unmeasurable zones (instrument sensitivity bands) of the sensor probe. The instrument sensitivity band at the Operatorsand emergency responsepersonnel. This level top of the probe will be 12 inches. Therefore, the SFP level instrument upper range will be set to a value that is at least 15 is also assumed to be the minimum level that assures that inches above Level 1 to account for the upper instrument sensitivity band and instrument ioop uncertainty. The instrument adequate *lrater level remainsabove the top of the stored sensitivity band at the bottom of the probe will be 4 inches.

fuel seated in7the SFP(nominal elevation of ()2 ft.. 2.5 The instrument lower range will be set to a value that is at least 7 inches below Level 3 (Plant Elev. (-) 0 ft., 6 in) to account for the instrument sensitivity band and uncertainty. A level on either the primary or backup instrument channel that corresponds Pleaseprovide the following: to Plant Elev. (-) 0 ft., 6 in will assure that the fuel in the pool remains covered.

a) For level]., specify how' the identified elevation represents the HIGHERof the two points described in the NE1 12-02 zuidancefor this level.

b) A clearly labeled sketch depictingthe elevation view o~f the proposedtypical mounting arrangementfor the portionsat instrument channel consistingofpermnanent measurement channel equinment (e. g.. _fixed level sensors and/or stilling wtells. and mounting brackets). Indicate on this sketch the datum values representingLevel]., Level 2. and Level 3 as well as the top of the futel racks. Indicate on this sketch the portion of the level sensor measurementrange that is sensitive to measurement afthe fuel pool level. with respect to the Level 1 Ipoyal 2 nu,- tpvoy alunTm* nnint RAI 2. The QIP states, in part,that; Enclosure 3 contains plan views of the proposed arrangement for the portions of the instrument channel consisting of Page 2 of 20

Table I RAI No. NRC QUESTION LICENSEE RESPONSE permanent measurement channel equipment. As requested the enclosure depicts the inside dimensions of the SFP, planned The Spent Fuel Pool Level (SFP) Instrunmentationfor each placement of the primary and backup level sensors in the SEP and the proposed routing of cables that will connect the channel wiill consist afla level sensingprobesuspended in the sensors to the level transmitters. The location of the signal conditioning processor module (level Transmitter) for each channel SFP, a signal conditioningprocessormodule, level indicator has been revised from the Primary Auxiliary Building to the Containment Enclosure Building. The planned location of the UPSI and a backup battery system. Redundant Train A and Train B remote display in the Train A and Train B Essential switchgear Rooms is also provided.

cables will be routedfrom the Fuel Storage Building (FSB) through the ContainmentEnclosure Ventilation Area (CEVA) and into the PrimaryAuxiliary Building (PAB) to connect each probe to a signal conditioaingprocessormodule. The signal processormodule is a panel-mounted instrumentthat has a display screen showing a numerical readout of SFP level as a continuous indication (i.e., remote Indication,). The signal conditioningprocessormodule for each channel will be mounted in a separate stainlesssteel enclosure located in the PAB so that the instrumentswiill not be subject to the radiation, high temperature and high humidity conditions that could result from postulatedloss of/wtater inventory in the SFP. The primary operator indicationand backup battery systems wvill be provided in the Train A and Traini B EssentialSwitchgearRooms (Elev.

2]1ft., 6 in.) located in the ControlBuilding.

Please modijfy the sketch in Figure]1 orprovide a marked-up plant drawiingof the plan viewmof the SEP area, depicting the SFP inside dimensions, the planned locations/placementof the primaryand back-up SFP level sensors, and the proposed routing of the cables that iiillextend fram the sensors toward the location of the local electronics cabinets and read-out/display devices in the main control roam or"alternate accessible location.

RAI 3. The OIP states, in part, that; Page 3 of 20

Table I RAI No. ,NRC QUESTION *,,.. , LICENSEE RESPONSE.>,* .. , ,5 " i Equipment mounting wlill be Seismic CategoryI in accordance Question for RAI 3a, 3b, and 3c are addressed in the response to NRC questions included in Table 2.

wiith guidelines of Regniatory Guide 1.29. Installed equipment wjill be seismicall' qutali ed to withstand the maximum seismic ground motion consideredin the design of the plant areo in iihtch it wtill be installed.

Where the collapse of componentsl would adversely affect the performonce of the SFP level insmtrmentation, the components will be supportedto withstandseismic loading or isolatedfrom the systems or components by Seismic Categoty I boundary restraints.

Pleaseprovide the following:

a) The design criteria that itill be used to estimate the total loading on the mounting device(s,), tncluding static wveight loads anddynamic 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 resultfrom pool slashing or other effects that could accompanysuch seismicforces.

b) A description of the manner in which the level sensor ('and stilling ii'ell, if appropriate)will be attached to the refueling floar and/or other supportstructuresfor eachplannedpoint of attachment ofthe probe assembly. Indicate in a schematic the portions of the level sensor that iwill serve as points of attachmentfor mechanical/mountingor electrical connections.

c) A descriptionof the manner by ii'hich the mechanical connections iill attach the level instrument to permanent SFP structuresso as to support the level sensor assembly.

The QIP states, in part, that; RAI 4.

_____-Components of the instrumentchannels will be -Question for RA! 4a, 4b, and 4c are addressed in the response to NRC questions included in Table 2.

Page 4 of 20

- .. .. . ' Table 1 RA I N .. QUE TIO

.. NRC.

qualifiedfor shock and vibration using one or"more of the following methods...

{-,i:

LICENSEE RESPO NSE ...'. .

The effects ofpostulatedseismic events on installed instrument channel components (w~ith the exception of battery chargersandreplaceable batteries,), wiill be verified to ensure that the equipment design and installationis robust.

Applicable components of the instrument channels wiill be qualifiedby the manufacturer (or otherwise tested)for seismic effects at response levels commensurate with the equipment mounting location. Instrument channel quaflifcation w'ill be based on the guidanceprovided in Sections 7, 8, 9, and 10 of IEEE Standard344-2004, IEEE Recommended Practicefor Seismic Qualijfication of Class 1E Equipmentfor Nuclear Power Generating Stations, or a substantiallysimilar industrialstandard.

In addition, any of the beloii' may also be used to provide additionalassurance that the equipment u'illpetform as designed during andfolloit'ing a seismic event:

Reviewl of operatinghistoiyfor component used in environments w'ith significantvibration, such as for portable hand-held devices or devices used in transportation applications. The effects of low frequency, high acceleration w'ill be included in the qualification as discussed above. Vibration qualifcationwill be inclusive of methods that demonstrate the effects of seismic motion imparted to the components at the location of installation.

Demonstr'ationthat devices are substantially similarin design to equipment that has been previously testedfor seismic effects in accordancewith the olant desien basis at the Page 5 of 20

~~~~~~~T bl

I...

I

* .... . ¸*,

i.. . ....

RAI No. NRCQUESTION LICENSEE

" RESPONSE location wihere the instrument is to be installed (g- levels andfrequency ranges).

In addition,pool mounted equtipment wiill be qualified for submergence, providingprotectionfrom wJave and seismic relateddisturbancesdutringand after a seismic event.

Pleaseprovide thefollowing:

a) A description of the specifc method or combinationi of methods you intend to apply to demonstrate the reliability of the permanently installed equipment under Beyond- Design-Basis (BDB,) ambient temperature,hutmidity, shock, vibration, and radiation conditions b) A description of the testing and/or analyses that wtill be condutcted to provide assutrancethat the equipment iiill performl reliably under the worst-case credible design basis loading at the locationi wihere the equipmentwitill be mounted. Include a discutssion 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-outt and re- transmittingdevices that wiill be employed to convey the level informationfrom the level sensor to the plant operatorsor emergency responders.

c)A description of the specifc method or combination of methods that wiill be used to confirm the reliabilityof the permanently installed equipmnent such thatfolloi 'ing a seismic event the instrutment w'ill maintain its Page 6 of20

R !No" NRC QUESTION ...... .:. LI..

CEN.SEE RESPONsE : ,* . ..... '.. ..! . . ... " :.. .. . . .. .

requiredaccuracy.

RAI 5. The OIP states, in part, that; NextEra Response RAI-5.a The backup instrument channel will be The permanently installed primary and backup instrument channels are redundant and will be installed independent of redundant to, and independent of, the primary each other with respect to physical separation and electrical power sources. The physical and electrical separation will instrument channel. Independence will be minimize the potential for a common cause event to adversely affect both channels. Each channel will consist of a level obtained through separationof the sensors, sensor, Level Transmitter and a Uninterruptible Power Supply (UPS) with remote level display.

indication, backup batterypower supplies, associatedcablingand channelpower feeds.

Powersources to each channelwill be from a The level transmitters, one per channel, will be mounted in separate locations within the Containment Enclosure Building different Class 1E plant bus (Train A and Train (CEVA) using independent seismically qualified supports. A vendor supplied cable will be independently run from each B). SFP sensor to the appropriate level transmitter. The vendor cables will be routed in dedicated rigid steel conduits that will be installed from each SFP sensor locations to the west wall of the SFP building, head south to the existing cable tray block outs, exit through the block outs to the transmitters location located in CEVA. Each conduit will be installed on Please provide the following: its own separate independent series of seismically qualified supports (i.e. "A" train and "B" train supports) maintaining a) A description of how the two channels of maximum physical separation between the primary and backup channel routings. The spatial separation of the the proposed level measurement system in transmitters and associated conduits will minimize the potential for a common cause event in the SEP area to adversely each pool meet this requirement so that the affecting both channels.

potential for a common cause event to adversely affect both channels is minimized to The primary and backup channel UPS/ Remote Indication Enclosures, which includes the remote displays, will be the extent practicable. located in the "A" and "B" train Essential Switchgear Rooms, one channel in each room. The Essential Switchgear Rooms are separated by physical barriers that assure train separation that preserves the independence of redundant b) Further information describingthe design and Class 1E plant electrical systems to prevent the occurrence of a common failure mode. From the transmitter locations in installationof each level measurement system, CEVA, new plant cables will be installed in the existing seismically qualified "A" and "B" train tray systems to the remote consisting of level sensor electronics, cabling, and indication enclosures (UPS/ Remote Indicator) located in the "A" and "B" train Essential Switchgear Rooms. Rigid steel readout devices. Please address how conduit will also be installed in each switchgear room from the enclosure to the tray system. All conduit and trays for the independence of these components of the primary routing of the cabling will be seismically qualified and capable of carrying safety related Class 1E circuits.

and back-up channels is achieved through the applicationof independentpower sources, physical and spatial separation,independence of signalssent to the location(s) of the readout devices, and the independence of the displays. The primary level channel will be powered from the120VAC distribution panel for MCC 615 (Train B). MCC 615 is located in the train B Essential Switchgear Room. The backup level channel will be powered from 120VAC distribution panel for MCC 515 (Train A). MCC 515 is located in the train A Essential Switchgear Room. These panels are physically separated from each other and will be normally powered from independent emergency diesel backed power supplies Page 7 of 20

* *: *, ,*,:* ° " -...... T able 1 -Ii ., = ? :

RAI No. NRC QUESTION LICENSEE RESPONSE i which serve to minimize the potential for a common cause event to affect both channels. In the event that the primary or backup power source from these panels is unavailable the channel UPS will automatically swap from 120VAC to the battery backup power supply.

The Overall Integrated Plan for Seabrook Station stated that the primary and backup instrument channel sensors for monitoring Spent Fuel Pool level for Seabrook Station would be located in the northwest and southwest corners of the Spent Fuel Pool (SFP) with the signal cable routed in rigid steel conduit to the adjacent west wall of the Fuel Storage Building (FSB). Each conduit would be routed on its own separate independent series of seismically qualified supports to level transmitters located in the Containment Enclosure Building (CEB) using Class 1 E type separation as currently assumed in the plant design basis. The plan also noted that the corners of the SFP would provide inherent missile protection for the level sensor probes in the pooi.

Subsequently, a detailed review of the plan has identified several implementation concerns. Installation of the sensor mounting brackets would require removal of 1/2 inch steel plates that were installed during plant construction to form the non-pool side of the curb that supports the stainless SFP liner. These plates are recessed into the Fuel Handling Machine (FHM) rail pockets. Removal of the plates will be very difficult and the process of removing the plates presents risk for potential damage to the SFP curb. Removal of the plates also presents potential FME and personnel safety concerns due the limited work space next to the pooi. The final design will also result in limited clearance (~1-1/2 inch) between the sensor mounting brackets and the frame of the FHM. Considering these concerns, alternative locations for SEP level sensor mounting are being considered and evaluated.

Evaluation of the alternate mounting locations considered FHM clearance, potential impact of bracket mounting on the attachment structure, access and maintainability of the level sensors and the impact that the location would have on normal SEP operations and support activities. The review also considered the potential for adjacent equipment and structure over the SFP to impact functionality of the sensors during a Beyond Design Basis External Event (BOBEE).

The evaluation considered alternate mounting locations on the east and west sides of the SEP. The north and south sides of the SEP were not considered to be viable locations for sensor mounting since the EHM traverses the entire length of the SEP which presents the clearance and curb concerns noted above. The east side of the SEP contains the fuel transfer gate, two fuel pooi lighting fixtures, two embedded SEP purification system skimmer intakes, 10 inch SEP cooling system discharge piping and 4 inch SEP filter system return piping, and a permanent storage location for one of the fuel handling tools. This side of the SEP is also used as the personnel access point and work area for SEP operations including: spotting during fuel movements, inspection camera access, Operator access for transfer gate manipulation and inspections, transfer canal inspections, and temporary storage location for radioactive wastes prior to survey and removal by Health Physics personnel. The west side of the SEP contains two SEP purification system skimmer intakes, two fuel pool lighting fixtures and the sensor for the existing SEP level instrumentation (1-SF-LE-2607).

This side of the SEP is also used as the personnel access point for maintenance of the existing pooi level instrumentation and cleaning of two of the skimmer intake basket filters.

Page 8 of 20

RAI No. NRC QUESTION ... .. ° " * . LICENSEE RESPONSE ., ,.. :

Based on current activities for SFP operations, and considering the physical limitations for mounting the sensor bracket and sensor signal cable access, the west side of the SFP is considered to be the preferred mounting location for both the primary and backup instrument channel sensors. However, due to the interferences described above, e.g., the FI-M rails on the north and south walls, the various appurtenances, equipment and access on the east wall and the skimmers inboard of the FHM rails on the west wall, sensor mounting will be on the west wall, physically separated by approximately 18"-6" on center as shown in Enclosure 3.

This configuration is considered to be in compliance with the requirements of references 1, 2 and 3 based on the following:

1. The FSB is a seismic Category ] reinforced concrete structure designed and constructed to meet the requirements of Seabrook UFSAR §3.8.4, Reinforced concrete is designed and constructed per the American Concrete Institute code, ACI 318-71.

Steel framing within the structure is designed and constructed to the requirements of the American Institute of Steel Construction code, AISC Specification for the Design, Fabrication and Erection of Structural Steel for Building, 1969 Edition. Concrete walls are a minimum of 24 inches thick concrete with a minimum compressive strength of 3000 psi.

2. No block or concrete masonry partitions are utilized in any Category I structure at Seabrook Station. The FSB superstructure is constructed of concrete walls and roof. The building is capable of withstanding the effects of extreme natural phenomena, including earthquake, tornado, hurricanes, and floods.

3. The SEP is constructed of concrete walls having a minimum thickness of 6 feet and a 4'-10" thick concrete floor. For leak tightness, the inside surface of the SFP is lined with stainless steel plates 3/16" thick on the walls and 1/4" thick on the floor.

4. Structural integrity qualification of the Category I FSB for actual and postulated loads imposed by equipment mounted to the structure is addressed by local analysis of the attachment mechanism. Concrete anchors are used for attachment to the structure. Embedded concrete anchor allowable loads are based on the anchor failing before the concrete. Thus the embedded anchor design assures that the concrete structure maintains its local structural integrity.

5. The effect of the actual and postulated loads on the global building structural integrity is a matter of comparison of the additional load to the generic design loads for the structure. Generic design loads, as described in the structural design criteria, are used to account for undefined loads. Additional loads that exceed the generic design loads warrant an evaluation of the affected structural elements. Loads that exceed the generic design loads are not expected for the sensor mounting bracket installations. The design inputs for the attachment connection are the weight of the component, the method of attachment, the local seismic response of the building, plus any other pertinent loads per UFSAR §3.8.4.3, Loads and Loading Combinations.

6. Simple static analyses will be used to evaluate the support attachment design. This conservative analysis methodoloav will use peak acceleration in each of three orthoaonal directions obtained from the buildino amolified Page 9 of 20

~~~Table 1I: :

RAI No. NRC QUESTION . .

LICENSEE RESPONSE , ;.

response spectra. Those accelerations are increased by 50% to account for multi-modal response (multiplied by 1.5). Attachment loads are calculated in each of the three directions. Then loads are combined by square root sum of the squares (SRSS), and then combined with dead weight loads and compared with allowable loads.

Alternatively, the stiffness of the component and support may be computed and the frequency of the first mode of vibration estimated. Should the frequency fall in the rigid range of the response spectra, then the zero period accelerations of the three orthogonal directions may be used for the static analysis described above.\

Since the FSB is a Seismic Category I structure, all equipment mountings within this building are designed to remain anchored during and following a seismic event. This design provides reasonable assurance that missiles will not be generated during a BDBEE by equipment located in the areas adjacent to the alternate sensor mounting locations on the west side of the SEP (Ref. Attachment A).

Physical separation of the SEP level sensors and instrument channel cables to the extent practicable will also be used to provide protection against missiles that may result from unexpected damage to adjacent seismically installed structures or components. Physical separation will be maintained using Class 1E type separation. The separation will be achieved through mounting to safety class structures, use of independent Seismic Category I supports and raceways, and physical distance between the channel sensors, sensor cabling, electronic enclosures and equipment mounted in the SFP or stored next to the SEP in accordance with the design criteria described in UFSAR §8.3.1.4, "Independence of Redundant Systems," UFSAR Appendix 8A, "Attachment C to AEC Letter Dated December 14, 1973, Physical Independence of Electric Systems," and UFSAR Table 8.3-10, "Electrical Cable and Raceway Separation Criteria." All SEP level instrument sensor equipment located in the ESB will be seismically qualified and installed to maintain the Class 1E separation criteria currently assumed in the plant design basis.

NextEra Response RAI-5.b Two completely redundant, independent and permanently installed SEP level measurement channels, both from the same supplier are being provided. Each channel utilizes guided wave radar (GWR) technology which uses the principle of time domain reflectometry to detect SEP water level.

Each level measurement channel will consist of a stainless steel sensor cable probe suspended in the SEP from a bracket attached to the operating deck at the side of the pooi, a level transmitter located in an adjacent area (CEVA) and a Uninterruptible Power Supply (UPS) with remote level display. Physical and spatial separation will be included in the design as described in the NextEra response to RAI-5.a above.

Each level measurement channel will be powered by an independent Emergency Diesel backed power source. The primary level channel will be powered from the120VAC distribution panel for MCC 615 (train B). The backup level channel will be oowered from 120VAC distribution ioanel for MCC 515 (Train A).

Page 10 of 20

RAI. No. NRC. QUESTION... , '- LICENSEE' RESPONSE*""*,* *' " .. .. , ,,.! -... *-,* .*'*' ' -- :,

The primary level channel signals between the level probe, transmitter and level processor cabinet are entirely independent and separated from the backup level channel as described in the NextEra response to RAI-5.a above.

RAI 6. The OIP states, inpart, that NextEra Response RAI-6.a The primary and backup instrument channels The primary and backup channels will be powered from independent Emergency diesel backed power distribution system.

The primary level channel will be powered from the120VAC distribution panel for MCC 615 (Train B). MCC 615 is located in will be powered from redundant dedicated the Train B Essential Switchgear Room and is normally powered from Unit Substation 61. The backup level channel will be batteriesand local battery chargers. The powered from 120VAC distribution panel for MCC 515 (Train A). MCC 515 is located in the train A Essential Switchgear Room battery chargerswill normally be supplied 120 V AC power from redundant Class 1E and is normally powered from Unit Substation 51. The A and B Train Essential Switchgear Rooms are physically separated from each other by reinforced concrete wall(s).

distributionpanels (Train A and Train B) that are sequenced and powered by the Emergency Diesel Generatorsor the On a loss of offsite power MOO 615 and MOO 515 are powered from separate independent Emergency Diesel Generators. In the event that the primary or backup power source from these panels is unavailable the respective channel UPS will also SupplementalEmergency PowerSystem (SEPS) on loss of off-site power (LOOP) automatically swap from 120VAC to battery backup power supply.

events. If the normal Class 1E power supply to a channel is not available, the dedicated battery supply wiil automaticailypower the instrument channel. A minimum battery life of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months will be provided for each channel.

NextEra Response RAI-6.b The design wiil include the capablility to isolate Battery sizing will be in accordance with IEEE 485-2010 (Refer to reference 23). The design criteria for each channel will the normal Class IE power supply to each assume continuous level measurement system operation for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following a loss of the normal ac power source.

channel by opening the feeder breaker within Westinghouse calculation of system power consumption will be based on the specified values listed in component the Class 1E distributionpanel. The Class 1E manufacturer specifications. Margin will be added to the battery sizing calculations, following guidelines of IEEE 485-2010, distribution panels that wiil be used for this Section 6.2.2. The specified 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery mission time will provide ample margin to allow the implementation of Phase II appilication are located in the Essential Train A FLEX actions as described in section IX of the overall integrated implementation plan for Seabrook. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery life and Train B Switch gearRooms. will be tested and verified during the Factory Acceptance Test or Site Acceptance Test prior to final acceptance of the system.

The minimum battery lfe of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months wiil be sufficient to assure that the SFP level instrumentation will provide reliable level indication until off-site resourcescan be Page 11 of 20

S-.--,RAI No. NRC QUESTION LICENSEE RESPONSE * *i..*i*.*:** *=.;i*- "

deployed by the mitigatingstrategies resulting from OrderEA-12-049. As part of the mitigating strategiesfor Order EA-12-049 (Reference 2), it is assumed that one channelof the SFP level instrumentationwill be repoweredby the SEPS approximately 10 minutes into the event if the emergency diesel generatorsare not available.

Off-site resources (personnel, equipment, etc.)

will begin to arrivingat the station approximatelyhour 6 into the event and full staffing is expected within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Requested portable equipment that will be connected to repowerthe redundant vital plant bus, including the power feed to the redundantSFP level monitoringinstrument channel, is assumed to arrive at the site from the RegionalResponse Center (RRC) approximately24 hours into the event.

Long term coping strategieswill include repowering of the redundant SEP level monitoring instrument channeland SFP cooling equipment approximately 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months into the event.

Please provide the following:

a) A description of the electricalAC power sources and capacitiesfor the primary and backup channels.

b) If the level measurement channels are to be powered through a battery system (either directly or through an UninterruptiblePower Supply (UPS)), please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously followino the onset of the Page 12 of 20

RAI No. °NRC QUESTION LICENSEE RESPONSE.

BDB event for the minimum duration needed, consistent with the plant mitigation strategies for BDB external events (Order EA- 12-049).

The OIP states, in part, that RAI 7. RAl 7a and 7b are addressed in the response to NRC questions included in Table 2.

The instrument channels will be The following is a summary of the Table 2 responses:

designed such that they will maintain their design accuracyfollowing a The Westinghouse documents WNA-CN-00301-GEN (Reference 22) and WNA-DS-02957-GEN (Reference 34) describe powerinterruption or change in power the channel accuracy under both (a) normal SFP level conditions and (b) at the Beyond Design Basis (BOB) conditions source without recalibration.Channel that would be present if SEP level were at Level 2 and Level 3 datum points. The overall channel accuracy tor the SEPIS accuracy will considerSEP level indication was established by Westinghouse based on individual component accuracies using statistical square root conditions, e.g., saturated water, sum of the squares (SRSS) methodology as stated in ISA RP67.04.02-2010, "Methodologies for the Determination of steam environment, or concentrated Setpoints for Nuclear Safety Related Instrumentation." Each instrument channel will be accurate to within +/- 3 inches borated water. during normal spent fuel pooi level conditions. The instrument channels will retain this accuracy during and following a BDBE. This accuracy is within the +/-1 toot channel accuracy requirements of the Order.

Additionally, instrument channelaccuracy will be sufficient to allow trainedpersonnel to determine The level displayed by the SFPIS channels will be verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as part of Nuclear System Operator when the actual level exceeds the key spent fuel pooi (NSO) rounds. This verification will compare level readings from the SEPIS channels (1-SF-LI-2616/ 1-SF-LI-2617) water levels (Levels 1, 2 and 3) without conflicting or to the existing control room SEP level indication (1-SF-LI-2607). Channel maintenance including channel ambiguous indication. The accuracy will be within the calibration(s) will be initiated ifthe deviation between indicated level readings exceeds the bounding uncertainty of SEP resolution requirements of Figure 1 of NEI 12-02. level readings between the existing SEP level indicators (1-SF-LI-2607, +/- 2 in.) and the new SEPIS indicators (+/- 3 in).

Channel maintenance andl/or channel calibration shall be initiated if the deviation between indicated level readings Please provide the following: exceeds 3.0 inches between the new SFPIS indicators or 2.0 inches between the new SEPIS indicator and the existing a) An estimate of the expected instrument 1-SF-LI-2607 indicator.

channel accuracyperformance (e.g., in % of span) under both a) normal SEP level conditions (approximately Level I or higher) and b) at the BDB conditions (i.e., radiation,temperature, humidity, post-seismic and post- shock conditions) that would be present if the SFP level were at the Level 2 and Level .3datum points.

b) A description of the methodology that will be used for determiningthe maximum allowed deviation from the instrument channel desi~qn Page 13 of 20

RAI No NR QUSTION :. :i .:LICENSEE RESPONSE*':::"": .. .... '"'...."....

accuracythat will be employed under normal operatingconditions as an acceptancecriterion for a calibrationprocedure to flag to operators and to techniciansthat the channelrequires adjustment to within the normal condition design accuracy.

RAI 8. The OIP states, in part, that; PAI 8a, 8b, 8c and 8d are addressed in the response to NRC questions included in Table 2.

Instrument channel design will provide for routine testing and calibrationconsistent with OrderEA-12-051 and the guidance in NEt 12-02. Instrument channel testing and calibrationwill be performed using existing plant work control processes. Details for testing and calibrationwill be determined during the engineeringand design phase of the project.

Pleaseprovide the foilowing:

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

b) A description of how such testing and calibrationwill enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installedSFP level instrumentation.

Page 1_4 of 20

" ~~Table 1V c) A description of how calibration tests and functional checks will be performed and the frequency at which they will be conducted. Discuss how these surveillances will be incorporated into the plant surveillance program.

d) A description of what preventative maintenance tasks are 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.

RAI 9.

The OIP states, in part, that NextEra Response RAI 9.a The location for primary and backup SFP level Local and remote Spent Fuel Pool (SFP) wide range level instrument displays will be provided for each level measurement indicationwill be accessibleduring and following channel (Primary and backup). The displays will be located in areas outside of the area surrounding the SEP floor.

an event. The Operatorindication(Primaryand Backup indication) wlll be provided in the Train A A local display will be located on the front of the primary and backup level transmitters located in the Containment Enclosure and Train B EssentialSwitchgearRooms (Elev. Ventilation Area (Ref. Enclosure 3). The CEVA is adjacent to the Spent Fuel Building (SFP) and has multiple access routes 21 ft., 6 in.) which are located in the Seismic through the Seismic Category [ Primary Auxiliary Building (PAB) which is normally accessed through the Radiation Protection Category I Control Bullding. The Train A and Checkpoint. Alternate routes into the PAB and CEVA are provided through doors P418 and EM414 (~' Elev. 25 ft.). These Train B Essential Switch gear Rooms are in close doors provide access from the exterior of the PAB and are normally locked. Door EM 414 provides access into the Main proximity to the main Control Room and Steam Feedwater Pipe Chase and/ or RCA Tunnel. Door P418 provides direct access to the 25 ft. elevation of the PAB.

Emergency Planning Technical Support Center locatedon elevation 75 ft of the Control Bullding. Normal access into the CEVA is provided through door P415 which located on the south east corner of the 25 ft elevation of The location of the primary and backup indication the PAB. An alternate access route into CEVA is provided from the West Main Steam and Feedwater Pipe Chase stairwell is: through door EM409 (Elev. 21 ft., 6 in.). The level transmitters and associated displays will be physically protected from the environmental and radiological conditions that could result from a beyond design basis (BDB) event by a reinforced concrete

Promptlyaccessible to the appropriateplant walls that separate the CEVA from the SFB.

staff giving appropriateconsiderationto various drain down scenarios,

Outside of the PSB, e.g., an appropriate Remote Spent Fuel Pool (SFP) wide range level instrument displays will also be located in the Train A and Train B Essential distance from the radiologicalsources resulting Switchgear Rooms (Elev. 21 ft., 6 in.) contained in the Seismic Category I Control Building (Ref. Enclosure 3, one remote from an event impactingthe SFP, indicator per Train). The Train A and Train B Essential Switchgear Rooms are in close proximity to the main Control Room and

Inside a seismic category I structureproviding Emergency Planning Technical Support Center which are located on Elevation 75 ft of the Control Building. The remote level orotection aoainstadverse weather and Page :15 of 20

RAI No. NRC QUESTION, "* ;' ".. .. ...... CENSEREPNE ...

outside of any high radiationareas during displays will be physically protected from the environmental and radiological conditions that could result from a beyond design normal operation, basis (BDB) event by a reinforced concrete walls that separate the Essential Switchgear Rooms from the PAB and SFB. This area will be accessible and continuously habitable following a beyond design basis event.

Please provide the following: Multiple routes are available to access the Essential Switchgear Rooms from the Control Building. The normal route from the Main Control Room is provided by door 0300. This door provides access into the Turbine Building where stair cases TBST1, TBST2, TBST3 and TBST4 provide alternate routes to door 0102 on the 21 ft., 6 in. elevation. Door C102 provides access a) Since the backup display location is not in the from the Turbine Building into the Train A Emergency Switchgear Room. From the Train A Emergency Switchgear Room, main control room, provide a description of the doors 0105 or 0109 provide access directly into the Train B Emergency Switchgear Room.

display location that addressesprimary and alternateaccess route evaluation, continuous An alternate access path into the Train B Emergency Switchgear Rooms is provided from the Main Control Room via an habitabilityatdisplaylocation(s), continual enclosed Seismic Category I stairwell (Stairwell CBST2). Door 0312 provides access from the Main control room into the 75 ft resource availabilityfor personnelresponsible to elevation of the stairwell. Door 0118 provides direct access from the 21 ft, 6 in elevation of the stairwell into the Train B promptly read displays, and provisions for verbal Emergency Switchgear room. From the Train B Emergency Switchgear room, doors 0105 or 0109 provide direct access into communications with decision makers for the the Train A Emergency Switchgear room. Stairwell CBST2 can also be accessed from outside of the control building via door various SEP drain down scenarios and external 0119 (Elev. 21 ft., 6 in.).

events.

The minimum shift complement following a beyond design basis event will initially consist of the staffing positions noted below.

b) The reasonsjustifying why the locations Primary and secondary responders from the Offsite Emergency Response Organization would augment this staff within 60 selected will enable the information from these minutes of a declared Alert level emergency condition if it is safe to access the plant. If it is unsafe to access the plant, the instruments to be considered "promptly primary and secondary responders from the offsite Emergency Response Organization will report to the Alternate Technical accessible". Include considerationof various Support Center!/Operation Support Center located at the Emergency Operations Facility in Portsmouth, New Hampshire. Staff drain-down scenarios, from the Alternate Technical Support Center!/Operation Support Center will be dispatched to the plant when safe access routes are established.

Shift Manager Unit Supervisor Work Control Supervisor Two Control Room Operators Five Nuclear Systems Operator Firefighter Chemistry Technician Health Physics Technician Hand held radios, satellite phones, person to person contact or the plant PBX phone system are communication systems that will be available for transmitting the information.

_______ ___________________________________NextEra Response RAI-9.b Page 16 of 20

~~~Ta ble 1I.. . "

RAI No. NRC QUESTION , , -,....: ,LICENSEERESPONSE, , ,.... ,; ,.*.. ,,

The information from the SEP level instrument is promptly accessible for various drain-down scenarios and external events based on the reasons specified in RAI 9a above.

RAI1i0. The OIP states, in part, that NextEra Response RAI-10O.a, b Procedureswill be developed using guidelinesand vendor instructionsto address The modification review process will be used to ensure all necessary procedures are developed for maintaining and operating the maintenance, operation, and abnormal the spent fuel level instruments after installation. These procedures will be developed in accordance with NextEra procedural response issues associatedwith the new controls. The objectives of each procedural area are described below:

SFP instrumentation.

Inspection, Calibration and Testing - Guidance on the performance of periodic visual inspections, as well intrusive testing, to ensure that each SEP channel is operating and indicating level within its design accuracy.

Procedureswill address a strategy to ensure SFPaditon ate levl i intiatd a anPreventative Maintenance - Guidance on scheduling of, and performing, appropriate preventative maintenance activities appropriatetime consistent with implementation of NEI 12-06, Diverse and necessary to maintain the instruments in a reliable condition.

Flexible Coping Strategies(FLEX)

Implementation Guide and EA-12-049, Maintenance - To specify troubleshooting and repair activities necessary to address system malfunctions.

Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Proorammatic Controls - Guidance on actions to be taken if one or more channels is out of service.

Strategies for Beyond-Design-Basis External Events. System Operations - To provide instructions for operation and use of the system by plant staff.

Response to inadequate levels - Action to be taken on observations of levels below normal level will be addressed in Site off normal procedures and/or FLEX Support Guidelines.

Please provide the following:

Westinghouse calibration procedure WNA-TP-04709-GEN (Reference 25) describes the capabilities and provisions for a) A list of the operating(both normal and abnormal periodic testing and calibration of the SFPIS, including in-situ testing. Seabrook utilized the methodology described in the response) procedures, calibration/testprocedures, Westinghouse calibration procedure for the functional channel checks at the pool side bracket and channel calibrations.

maintenance procedures, and inspection procedures that will be developed for use of the SFP The following procedures have been developed to maintain the system:

instrumentation in a manner that addressesthe

________ order requirements.

Page 17 of 20

Table I RAI No. NRC QUESTION ~*~LICENSEE RESPONSE PM TITLE FREQ b) A brief descriptionof the specific technical objectives to be achieved within each procedure. SF-L-2616-CAL-i TRAIN A SPENT FUEL POOL LEVEL (BOB) CALIBRATION 1 Year If your plan incorporatesthe use of portable spent SF-L-2616-BR-i TRN A SFP LEVEL 1-SF-CP-300-A BATT-[ERY REPLACEMENT 3 Year fuel level monitoring components, please include SF-L-26i16-MAN-i TRN A SEP LVL XMTR i-SF-LIT-2616 REPLACEMENT 7 Year a description of the objectives to be achieved with regardto the storage location and provisions for SF-L-2616-MAN-2 TRN A SEP LVL PWR SUPPLY i-SF-UQ-2616 REPLACEMENT 10 Year installationof the portable components when SF-L-2617-CAL-1 TRAIN B SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year needed. SE-L-261 7-BR-i TRN B SEP LEVEL 1-SF-CP-300-B BATI-ERY REPLACEMENT 3 Year SF-L-26i17-MAN-i TRN B SEP I.VL XMTR i-SF-LIT-26i7 REPLACEMENT 7 Year SF-L-2617-MAN-2 TRN B SEP LVL PWR SUPPLY i-SF-UQ-26i7 REPLACEMENT i0 Year The following high level FSGs will direct operators to monitor SEP level using SFPIS:

FSG-0.0, Extended Loss of All AC Power with SEPS FSG-0.1, Extended Loss of All AC Power without SEPS FSG-5, Initial Assessment and FLEX Equipment Staging FSG-i11, Alternate SEP Makeup and Cooling FSG-i4, Extended Loss of All AC Power while Plant Shutdown When SEP level cannot be maintained greater than 23 feet above the top of the racks the FSG procedures direct operators to imp*lement FSG-1 1, Alternate SEP Makeup and Cooling.

FSG-5, Initial Assessment and FLEX Equipment Staging, will provides methods to establish portable ventilation in the CEVA area when area temperature is greater than i30°F.

FSG-5, Attachment G, Restore Miscellaneous Lighting and Pipe Chase Ventilation Power, will provide an alternate power source to SFPIS.

The following Operating Procedures will also be revised to address alignment of the SFPIS for operation.

OS10i4.0i, Spent Fuel Cleanup and Cooling System Fill and Vent (system lineup)

OSi046.58, MCC-515 Maintenance Procedure OS1046.65, MCC-615 Maintenance Procedure RAI 1.1. The OIP sates, in part, that NextEra Response RAI-11I .a~b~c

________ _______________________________________a) Seabrook will establish and implement procedures for control and oversight of SFPIS maintenance and testing.

Page 18 of 20

- -* : *~Table 1I i; RAI o. NRC QUESTION *LICENSEE RESPONSE, -.

Processeswill be established andmaintained The new procedure(s) will include requirements for all necessary tests to be performed, frequency of testing, for scheduling and implementing necessary acceptance criteria, and requirements for inspection and audit of test performance and results. Westinghouse testing and calibrationof the primary and calibration procedure for the functional channel checks at the pooi side bracket and channel calibrations. The backup spent fuel pool level instrument following procedures have been developed to maintain the system:

channels to maintain the instrumentchannels at the design accuracy. Testing and calibration of the instrumentation will be consistent with PM TITLE FREQ vendor recommendationsand any other SF-L-2616-CAL-1 TRAIN A SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year documented basis. Calibrationwill be specific to the mounted instrumentsand indicators. SF-L-2616-BR-1 TRN A SEP LEVEL 1-SF-CP-300-A BATTERY REPLACEMENT 3 Year SF-L-261 6-MAN-i TRN A SEP LVL XMTR 1-SF-LIT-2616 REPLACEMENT 7 Year SF-L-2616-MAN-2 TRN A SEP LVL PWR SUPPLY 1-SF-UQ-2616 REPLACEMENT 10 Year Please provide the following:

SF-L-261 7-CAL-i TRAIN B SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year SF-L-26i17-BR-i TRN B SEP LEVEL 1-SF-CP-300-B BATTERY REPLACEMENT 3 Year a) Purt her information describing the maintenance SF-L-2617-MAN-1 TRN B SEP LVL XMTR 1-SF-LIT-2617 REPLACEMENT 7 Year and testing program the licensee will establish and implement to ensure that regulartesting and SF-L-2617-MAN-2 TRN B SEP LVL PWR SUPPLY 1-SF-UQ-2617 REPLACEMENT 10 Year calibrationis performed and verified by inspection and audit to demonstrate conformance with design and system readinessrequirements. Include a description of your plans for ensuring that necessary b) Seabrook will implement measures to minimize the possibility of either the primary or backup channel being out channel checks, functional tests, periodic calibration, of service for any extended period. Sufficient spare components and materials will be maintained in plant and maintenance inventory to enable timely repair or replacement of defective components. Seabrook will follow the NEI112-02 will be conducted for the level measurement system guidance with regard to the time periods when one or more channels may be out of service. Planned and its supporting equipment. compensatory actions for unlikely extended out-of-service events are summarized as follows:

Channel(s) Required Restoration Action Compensatory action b) A description of how the guidance in NEI 12-02 Out-of-service _____________________ _________________

Section 4.3 regardingcompensatory actions for one 1Initiate actions to restore channel to functional Implement actions in accordance with or both non-functioning channels will be addressed.

status within 90 days. (Note 1) Note 2.

c) A description of the compensatory actions to be taken in the event that one of the instrument 2 -Initiate action to restore at least one channel to -- Implement actions in accordance with channels cannot be restored to functional status

__________functional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Note 2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

within 90 days.

Note 1: If channel restoration is not expected to be completed within 90 days initiate compensatory action.

Note 2: Initiate an evaluation in accordance with the corrective action program. The evaluation shall initiate compensatory actions to implement an alternate method of monitoring and schedule required actions for restoring the instrumentation channel(s) to functional status.

Page 19 of 20

........ Table I RAI No. NRC QUESTIONi:' :° * * *:-"i:'"! ... LICENSEE RESPONSE'i' c) If a channel is non-functional, a corrective action document will be initiated and actions taken to correct the deficiency within 90 days as described in NEI 12-02. The technology selected for level instrumentation is easily replaceable as components are passive and modular. Sufficient spares will be available on-site.

As the spent fuel pool level instrumentation required by the Order (EA-12-051) is to be coordinated with FLEX actions, equipment unavailability actions will be similar to NEI 12-06, Section 11.5, Item 2. Specifically, ifthe equipment becomes unavailable such that the site capability (e.g., 2 channels) is not maintained, Seabrook will initiate actions within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the capability and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to monitor pooi levels.

Page 20 of 20

i - * ". ,* .i . .... ..... Table 2 ... ,* *-i ':

QuestiOn No. NRC QUESTION i'LICENSEE RESP*ONSE: *;: .':; "*** .. .. :.... ';' ", ' .... ""

1. Please provide the final elevation for Level 3 NextEra Response Question I and an updated sketch of the SFP elevation view with the SFP levels, if applicable. Westinghouse has established that the accuracy for the SFPIS will be +1-3.0 inches. Westinghouse has also established the unmeasurable zones (instrument sensitivity bands) of the sensor probe for the SFPIS. The instrument sensitivity band at the top of the probe is 12 inches. Therefore, the SFP level instrument upper range will be at least 15 inches above Level 1 (Elev. 23 ft,. 4 in.) to account for the upper instrument sensitivity band and instrument ioop uncertainty. The instrument sensitivity band at the bottom of the probe is 4 inches. The established elevation for Level 3 will not need to be affected to provide additionalmargin for instrument sensitivity band and uncertainty. The plant elevation for level 3 ((-) 0 ft., 6 in.) provides approximately 1 foot of water above the top of the racks seated in the spent fuel pooi. An indicated level on either the primery or backup instrument channel of greater than plant elevation (-) 0 ft., 6 in will assure that the fuel remains covered.

Enclosure 1 contains an elevation view of the sensor probe arrangement. The datum values for Levels 1, 2 and 3, and the top and bottom instrument sensitivity bands for the SFPIS probe are provided.

2.Please provide additional information NextEra Response Question 2 describing how the proposed arrangement of the waveg uides and routing of the cabling Enclosure 3 contains plan views of the proposed arrangementfor the portions of the instrument channel consisting of between the FSB through the CEB and into permanently mounted measurement equipment. The enclosure depicts the inside dimensions of the SFP, planned the PAB meets the Order requirement to placement of the primary and backup level sensors in the SEP and the proposed routing of cables that will connect the arrange the SFP level instrument channels in sensors to the level transmitters, and the level transmittersto the remote enclosure. The signal conditioningprocessor a manner that provides reasonable module (level Transmitter)for each channel will be located in the Containment Enclosure Building. The planned locations for protection of the level indication function the primary and backup UPS/remote display enclosures that will be mounted in the Train A and Train B Essential against missiles that may result from damage switchgear Rooms are also provided. Cablingbetween the level transmitters and the UPS/remote display enclosures will to the structure over the SFP. be routed through existing seismic category I raceways in the Primary Auxiliary Building to the Essential Switch gear Rooms.

Since the Spent Fuel Building (SFB), Containment Enclosure Building (CEB), Primary Auxiliary Building (PAB) and Essential Switch gear Rooms are seismic category I structures, all equipment mountings within these buildings are designed to remain anchored during or following a seismic event. Class IE type physical separationas currently assumed in the plant design basis will also be used to provide reasonable protection againstmissiles that may result from unexpected damage to structures over the SFPIS equipment. Each conduit/cable will be routed on its own separate independent series of seismically guallfied supports.

Page 1 of 31

...*: . . . '... .. * "* ...i .. . ..... .. .T a ble 2 . .. , . .." . .. . .. : "-

Question No. NRC QUESTION LICENSEE RESPONSE... "

The Overall Integrated Plan for Seabrook Station stated that the primary and backup instrument channel sensors for monitoring Spent Fuel Pool level would be located in the northwest and southwest corners of the Spent Fuel Pool (SFP) with the signal cable routed in rigid steel conduit to the adjacent west wall of the Fuel Storage Building (FSB). The plan also noted that the corners of the SFP would provide inherent missile protection for the level sensorprobes in the pool Subsequently, a detailed review of the plan has identified several implementation concerns, Installation of the sensor mounting brackets would require removal of 1/2 inch steel plates that were installed during plant construction to form the non-pool side of the curb that supports the stainless SFP liner (Ref. Attachment B). These plates are recessed into the Fuel Handling Machine (FHM) railpockets. Removal of the plates will be very difficult and the process of removing the plates presents risk for potential damage to the SFP curb. Removal of the plates also presents potential FME and personnel safety concerns due the limited work space next to the pooi. The final design will also result in limited clearance

(~1-1/2 inch) between the sensor mounting brackets and the frame of the FHM. Considering these concerns, alternative locations for SFP level sensor mounting are being considered and evaluated.

Evaluation of the alternate mounting locations considered FHM clearance, potential impact of bracket mounting on the attachment structure, access and maintainabilityof the level sensors and the impact that the location would have on normal SFP operations and support activities. The review also considered the potential for adjacent equipment and structure over the SFP to impact functionality of the sensors during a Beyond Design Basis External Event (BDBEE).

The evaluation considered alternate mounting locations on the east and west sides of the SFP. The north and south sides of the SFP were not consideredto be viable locations for sensor mounting since the FHlM traverses the entire length of the SFPwhich presents the clearanceand curb concerns noted above. The east side of the SFP contains the fuel transfer gate, two fuel pool lighting fixtures, two embedded SFPpurification system skimmer intakes, 10 inch SFP cooling system discharge piping and 4 inch SFP filter system return piping, and a permanent storage location for one of the fuel handling tools. This side of the SFP is also used as the personnel access point and work area for SFP operations including:

spotting during fuel movements, inspection camera access, Operatoraccess for transfergate manipulation and inspections, transfercanal inspections, and temporary storage location for radioactive wastes prior to survey and removal by Health Physics personnel. The west side of the SFP contains two SFP purification system skimmer intakes, three fuel pool lighting fixtures and the sensor for the existing SFP level instrumentation(1-SF-LE-260 7). This side of the SFP is also used as the personnel access point for maintenance of the existing pool level instrumentation and cleaning of two of the skimmer intake basket filters.

Based on current activities for SFP operations, and considering the physical limitations for mounting the sensorbracket and sensorsignal cable access, the west side of the SFP is considered to be the preferred mounting location for both the primaryand backup instrument channel sensors. However, due to the interferencesdescribed above (FHM rails on the north and south walls, the various appurtenances, equipment and access on the east wall and the skimmers inboard of the FHM rails on the west wall) sensor mounting will be on the west wall, physicaily separatedby approximately 18 feet (min.)

on center as shown in Enclosure 3.

Page 2 of 31

.... * , *; - ' ~ ~Table 2 : ,.. .- : :

Question No. NRC QUESTION , LICENSEE. RESPONSE}' , :;*i ..

This configuration is considered to be in compliance with the requirements of references 1, 2 and 3 based on the following:

1.The FSB is a seismic Category I reinforced concrete structure designed and constructed to meet the requirements of Seabrook UFSAR §3. 8.4, Reinforced concrete is designed and constructedper the American Concrete Institute code, AC1318-71 Steel framing within the structure is designed and constructed to the requirements of the American Institute of Steel Constructioncode, AISC Specification for the Design, Fabricationand Erection of Structural Steel for Building, 1969 Edition. Concrete walls are a minimum of 24 inches thick concrete with a minimum compressive strength of 3000 psi.

No block or concrete masonry partitions are utilized in any Category I structure at Seabrook Station. The FSB superstructure is constructed of concrete walls and roof. The building is capable of withstandingthe effects of extreme natural phenomena, including earthquake, tornado, hurricanes, and floods.

2. The SEP is constructed of concrete walls having a minimum thickness of 6 feet and a 4"-10" thick concrete floor. For leak tightness, the inside surface of the SEP is lined with stainless steel plates 3/16' thick on the walls and 1/4" thick on the floor.

3. Structural integrity qualification of the Category I FSB for actual and postulated loads imposed by equipment mounted to the structure is addressed by local analysis of the attachmentmechanism. Concrete anchors are used for attachment to the structure. Embedded concrete anchor allowable loads are based on the anchor failing before the concrete. Thus the embedded anchor design assures that the concrete structure maintains its local structural integrity.

4. The effect of the actual and postulated loads on the global building structuralintegrity is a matter of comparison of the additional load to the generic design loads for the structure. Generic design loads, as described in the structural design criteria, are used to account for undefined loads. Additional loads that exceed the generic design loads warrant an evaluation of the affected structuralelements. Loads that exceed the generic design loads are not expected for the sensor mounting bracket installations. The design inputs for the attachment connection are the weight of the component, the method of attachment, the local seismic response of the building, plus any other pertinent loads per UFSAR §3.8.4.3, Loads and Loading Combinations.

5. Simple static analyses will be used to evaluate the support attachment design. This conservative analysis methodology wiil use peak accelerationin each of three orthogonal directionsobtained from the building amplified response spectra. Those accelerationsare increased by 50% to account for multi-modal response (multiplied by 1.5).

Attachment loads are calculated in each of the three directions. Then loads are combined by square root sum of the squares (SRSS), and then combined with dead weight loads and compared with ailowable loads. Alternatively, the stiffness of the component and support may be computed and the frequency of the first mode of vibration estimated.

Should the frequency fall in the rigid range of the response spectra, then the zero period accelerationsof the three orthogonaldirections may be used for the static analysis described above.

Page 3 of 3l

Table 2 Question No. NRC QUESTION {LICENSEE RESPONSE Since the FSB is a Seismic Category I structure, all equipment mountings within this building are designed to remain anchored during and following a seismic event. This design provides reasonableassurance that missiles will not be generated during a BDBEE by equipment located in the areas adjacent to the alternate sensor mounting locations on the west side of the SEP (Ref. Enclosure 3).

Physical separationof the SEP level sensors and instrument channel cables in the Fuel storage Building to the extent practicable will also be used to provide protection against missiles that may result from unexpected damage to adjacent seismically installedstructures or components.

Physical separation will be maintained using Class 1E type separation. The separationwill be achieved through mounting to safety class structures, use of independent Seismic Category I supports and raceways, and physical distance between the channel sensors, sensor cabling, electronic enclosures and equipment mounted in the SEP or stored next to the SEP in accordance with the design criteria described in UFSAR §8.3.1.4, "Independence of Redundant Systems," UFSAR Appendix 8A4,"Attachment C to AEC Letter Dated December 14, 1973, Physical Independence of Electric Systems," and UFSAR Table 8.3-10, "ElectricalCable and Raceway Separation Criteria." All SEP level instrument sensor equipment located in the ESB will be seismically quallfied and installed to maintain the Class 1E separation criteria currently assumed in the plant design basis.

Please provide the following: NextEra Response Question 3a a) The design criteria that will be used to estimate the total loading on the mounting All SEPIS equipment will be designed in accordance with the Seabrook Nuclear Plant Safe Shutdown Earthquake device(s), including static weight loads and (SSE) design requirements. Simple static analyses will be used to evaluate the anchorage design for the SEPIS level dynamic loads. Describe the methodology sensor, electronic enclosures, conduits and associated supports. This conservative analysis methodology will use that will be used to estimate the total loading, peak accelerationin each of three orthogonal directionsobtained from the building response spectra at the mounting inclusive of design basis maximum seismic location. Those accelerations are increasedby 50% to account for multi-modal response (multip~ied by 1.5).

loads and the hydrodynamic loads that could Attachment loads are calculated in each of the three directions, loads are combined by Square Root Sum of the result from pooi sloshing or other effects that Squares (SRSS), and then combined with dead weight loads and compared with allowable loads.

could accompany such seismic forces.

Westinghouse evaluated the structuralintegrity of the SFPIS sensor mounting brackets in calculation CN-PEUS-14-16 (Reference 14). The GTSTRUDL model, used by Westinghouse to calculate the stresses in the bracket assembly, b) A description of the manner in which the considers load combinations for the dead load, live load including hydrodynamic load and seismic load on the bracket.

level sensor (and stilling well, if appropriate) The reactionaryforces calculated from these loads become the design inputs for the mounting bracket and it's will be attached to the refueling floor andlor anchorage to the refuel floor to withstand a Safe Shutdown Earthquake (SSE). The seismic load input for this other support structures for each planned anatysis was obtained from the Amplified Response Spectra (ARS) for the Spent Fuel Building (SEB) and the point of attachment of the probe assembly. following methodology was used by Westinghouse to determine the stresses on the sensor bracket assembly:

Indicate in a schematic the portions of the level sensor that will serve as points of *Frequency analysis, taking into account the dead weight and the hydrodynamic mass of the structure, Page 4 of 31

- :* *, -. , , Table 2 ,

Question No. NRC QUESTION -*LICENSEE RESPONSE ° : :...

attachment for mechanical/mounting or was performed to obtain the naturalfrequencies of the structure in all three directions.

electrical connections.

SSE response spectra analysis was performed to obtain member stresses and support reactions.

c) A description of the manner by which the mechanical connections will attach the level

The seismic loads for each of the three directions were combined by the Square Root of the Sum of instrument to permanent SFP structures so Squares (SRSS) Method.

as to support the level sensor assembly.

o Sloshing analysis was performed to obtain liquid pressure and its impact on bracket design and anchorage.

The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum. These combined results are compared with the allowable stress values.

SloshinQ Sloshing forces were obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach has been used to estimate the wave height and naturalfrequency. Horizontal and vertical impact force on the bracket components were calculatedusing the wave height and naturalfrequency obtained using TID-7024 approach.

Using this methodology, sloshing forces were calculatedand added to the total reactionary forces that would be applicablefor the bracket anchorage design. The analysis also determined that the level probe can withstand a design basis seismic event.

During the design basis event, the SFP water level is expected to rise and parts of the level sensor probe are assumed to become submerged in borated water. The load impact due to the rising water and submergence of the bracket components has also been considered for the overall sloshing impact. Reliable operation of the level measurement sensor with temporary submerged interconnecting cable has also been demonstratedby Westinghouse. Boron build up on the probe has been analyzed to determine the potential effects on the sensor.

The following Westinghouse documents provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a) CN-PEUS-14 Pool-side Bracket Seismic Analysis b) WNA-TR-O3149-GEN - Sloshing Analysis c) EQ-QR-269, WNA-TR-O3149-GEN, EQ-TP-353 - Seismic Qualification of other components of SFPI d) Westinoho use Letter L TR-SEE-II-13-47. Determinationif the Provosed Soent Fuel Pool level Page 5 of 31

Question No. NRC QUESTION . LICENSEE RESPONSE: .'**

instrumentationcan be sloshed out of the Spent fuel pool duning a seismic Event.

The design critenia used in this calculation met the requirements to withstand SSE and will meet the Seabrook Station seismic Category I installation requirements. The methods used in the calculation followed the IEEE 344-2004 and IEEE 323-2003 requirements for seismic qualification of the SFPIS instrument and raceway installations.

Westinghouse calculation CN-PEUS-14-16, rev 002 (FP 700468), 'SFPISMounting Bracket Seismic Analysis,' establishedthe design loading requirements for the pool side brackets. Since the brackets cantilever over the pool, and water displacement was determined to be above the 5FP high water level, slosh loads resulting from an earthquake were considered as part of the bracket design and analysis. The seismic load effects were calculated based on self-weight, dead load of the instrumentation, hydrodynamic load (sloshing) due to seismic effects and the seismic load.

The Westinghouse analysis assumes the hydrodynamic load acts in the vertical direction on the launch plate. The load is applied at center of the launch plate (the same location as where the coupler is located) and was determined as 185.8 lb.

Furthermore, the following summary of Interaction Ratios (IRs) demonstrates that the bracket design is adequate for the all applicable seismic loading including hydrodynamic loading. The IRs are based on Safe Shutdown Earthquake (SSE) loading, including hydrodynamic load (sloshing), due to seismic effects compared to AISC normal allowable (i.e., without an allowable stress increase factor).

Controlling Bolt IR ..................... 0.44 (3/8" Bolt)

Thread Engagement IR................. 0.89 (enclosure bolts)

FP 700468, Appendix G, EC 281849 ensures that the anchor design is adequate for the intended loads.

NextEra Response Question 3b The Westinghouse designed SFPIS level sensor consists of a stainless steel cable probe suspended from a launch plate via a coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, will be mounted to the refuel floor via four concrete expansion anchors. Enclosure 4 shows the level sensor mounting bracket with mechanicalattachment points.

_ _xtrraeRsponsejQes tionn3c Page 6 of 31

.*Table 2 NRC QUESTION*; : .-. :,:;:i LICENSEE RESPONSE :::*°.:

The bracket assembly that supports the sensorprobe and launch plate will be mechanically connected to the SFP structure. The mechanical connection consists of four concrete expansion anchors that will bolt the bracket assembly to the SFP structure via the base plate. The loads for the bracket concrete anchors were establishedby Seabrook based on translation of loads establishedby Westinghouse for the Pool-side bracket in Seismic Analysis CN-PEUS-14-16 (Reference 14). The concrete expansion anchors will be designed by Seabrook to meet the calculated Westinghouse loads (tension and shearloads) for the Seabrook modified bracket design with appropriatedsafety margin.

Seabrook design change EC 281849 modified the Westinghouse sensor probe 2shaped, stainless steel, probe bracket to allow for installation along the West side of the SEP (Ref. Enclosure 4). Each of the modified probe mounting plate will bolted to the West pool side concrete using four 5/8" diameter Hilti Ill stainless steel anchors each having a 4" minimum concrete embedment. Eccentric loads on the cantilever plate bolt group are checked based on forces and moments at the center of the Hilti Plate/cantileverplate taken from page 27 of the Westinghouse analysis (Reference 14).

Loads at Center of HKB3 Group Fx = 65#, Fy = 279#, Fz = 45#, Mx = 5,000 in #, My = 1,860 in #, Mz = 4,200 in #

SS HKB Ill Ailowables Tension = 2,065#, Shear=4,160#

Interaction IR bolt =Tbolt/T a!owabl*e+ V bolt/VaJowable 0.465 < 1.0....OK The HKB Ill bolts control the connection design which is based on conservative and maximum bolt tension and shear taken from the Westinghouse Strudl model. Base plate bending and shear stresses wiil be smail due to minimal Ioadino on the 33/4" cantilever olate.

4.

Please provide the analyses used to verify NextEra Response Question 4 the design criteria and methodology for seismic testing of the SFP instrumentation The foilowing documents provide the analyses used to verifly the design criteriaand describe the methodology that and the electronics units, including, design was applied for qualification of the SFPIS equipment, inclusive of the seismic and hydrodynamic loads for the pooi basis maximum seismic loads and the side equipment:

hydrodynamic loads that could result from pool sloshing or other effects that could a. FP 700468; Westinghouse CN-PEUS-14 Pool-side Bracket Seismic Analysis (Reference 14), revised accompany such seismic forces. by Seabrook to quailify modifications to the pooi side bracket.

b. WNA-TR-O3149-GEN - SFPIS Standard ProductFinal Summary Design Verification Report (Reference 20)

c. Westinghouse ProprietaryDocument, L TR-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 Page 7 of3l.

Qusino R QUESTIO LICENSEE RESPONSE: * ; o; 9Reference 30).

d. EQ-QR-269 - Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation System (Reference 18).

e. FP 700489, Seabrook SFPIS Pool Mounting Bracket No equipment failures were noted as a result of seismic testing. Seismic test results are documented in the Westinghouse qualification report summaries referenced above.

As described in the response to Question 3 above, equipment anchorage will be designed by Seabrook to meet the calculated Westinghouse loads (tension and shearloads) with appropriatedsafety margin.

S.For each of the mounting attachments NextEra Resp~onse Question 5 required to attach SFP level equipment to plant structures, please describe the design The Fuel Storage, Containment Enclosure Building and the Control Buildings are seismic Category I reinforced concrete inputs, and the methodology that was used structures designed and constructed to meet the requirements of Seabrook UFSAR 3.8.4, Reinforced concrete is to qualify the structural integrity of the designed and constructedper the American Concrete Institute code ACI 3 18-71. Steel framing within the structuresis affected structures/equipment designed and constructed to the requirements of the American Institute of Steel Construction code, AISC Specification for the Design, Fabricationand Erection of StructuralSteel for Building 1969 Edition. Concrete wails are a minimum of 24 inches thick concrete with a minimum compressive strength of 3000 psi. No block or concrete masonry partitionsare utilized in any Category I structure.

Structural integrity quailificationof the Category I buildings for actual and postulated loads imposed by equipment mounted to the structure is addressedby local analysis of the attachment mechanism. Attachment to the structureswill use concrete anchors. Embedded concrete anchor ailowable loads are based on the anchorfailing before the concrete. Thus a properly designed embedded anchor assures that the concrete structure maintains its local structural integrity.

The effect of the actual and postulated loads on the global building structuralintegrity is a matter of comparison of the additionalload to the generic design loads for the structure. Generic design loads, as described in the structural design criteria, are used to account for undefined loads. Additional loads that exceed the generic design loads warrantan evaluation of the affected structuralelements. Loads that exceed the generic design loads are not expected for this activity.

___________ ___________________________________ The design inputs for the attachment connection are the weight of the component, the method of attachment, the local Page 8 of 31

{

!, ,i . *i .Table 2...

Question No." NRC QUESTION, :'; :...: ;;? ;ICENSE L'" RESPONSE : ! "

seismic response of the building, any other pertinent loads per UFSAR 3.8.4.3 Loads and Loading Combinations. The allowable loads for the attachment mechanism are also design input.

Simple static analyses will be used to evaluate the supportattachment design. This conservative analysis methodology uses peak acceleration in each of three orthogonal directions obtained from the building ampilified response spectra.

Those accelerations are increased by 50% to account for multi-modal response (multiplied by 1.5). Attachment loads are calculated in each of the three directions, loads are combined by SRSS. and then combined with dead weight loads and compared with allowable loads.

Alternatively, the stiffness of the component and support may be computed and the frequency of the first mode of vibration estimated. Should the frequency fail in the rigid range of the response spectra then the zero period accelerations of the three orthogonaldirections may be used for the static analysis described above.

1. ControlPanels, 1-SF-CP-3OO-A and 1-SF-CP-300:

The sensor electronics control panels, 1-SF-CP-3OO-A and 1-SF-CP-3OO-B, will be located in the respective "A" and "B" Train Essential Switch gearRooms as shown in Enclosure 3. These control cabinets and

]unction boxes are to be instailedin accordancewith Seabrook drawing 1-NHY-300228. Drawing 1-NHY-300228, "Notes and Details," provides pre qualified, generic, seismicaily qualified supports.

2. Transmitterenclosures (1-SF-LIT-2616 and 1-SF-LIT-261 7):

The electronics cabinet will be installed on a seismically qualified C-32A figure 1 box supports in accordance with Seabrook drawing 1-NHY-300228.. The sensor head unit bracket and attached Level Indicating Transmitters 1-SF-LIT-2616 and 1-SF-LIT-26 17, are to be installed inside a 24"x 24"x 12" deep NEMA 4X( electronics cabinet seismically supported by the C-32A figure 1 box support frame detailed on 1-NHY-300228, sheet C-32A. Modifications to the C-32A frame required for supporting the sensor head bracket/level transmitterand electronics cabinet are detailed in Seabrook design change EC 281849.

The electronics cabinet is a 24" x 24" x 12" deep NEMA 4X( stainless steel enclosure. (Reference typical NEMA 4>( details; http://www.austinenclosures.com/products/view/

NEMA_4XStainlessSteel_Enclosure/AB-242412NFX/). The enclosure is 14 gage cold roiled steel that weighs less than 60 lbs. The sensor head mounting bracket is an 8" length of HSS 6" x 4" x 1/4" that, including mounting hardware, conservatively weighs 10 lbs. Per the Westinghouse drawings the total weight of the NEMA 4X>electronics box including all internal components is less than 100 lbs. The C32A figure 1 support is seismicaily qualified for 150 lbs. load on the frame for ail areas of the plant including areashaving higher ARS than the ARS that is applicable to the CEVA where the seismic demand is low (ground response).

Page 9 of 31

' ~Table 2, oQuestion No. NRC, QUESTION *, i ... , ,LICENSEE RESPONSE ::, ; ...

Please provide the following: NextEra Response Question 6a a) A description of the specific method or combination of methods you intend to apply a) Reliability of the new SFPIS was demonstrated by Westinghouse using a combination of design, analysis, to demonstrate the reliability of the operating experience and testing. The qualification program demonstrated that the new SEPIS will be capable of continuous operation while subjected to the normal and anticipatedBeyond Design Basis Event (BDBE) permanently installed equipment under senvice conditions. NRC Order EA 12-051 requires that the equipment be able to withstand the post event beyond-design-basis ambient temperature, environment for no fewer than 7 days including the impact of FLEX mitigatingstrategies. For Seabrook the humidity, shock, vibration, and radiation required environmentalservice conditions for the SEPIS equipment are noted in the following tables.

conditions.

Environmental Conditions at the Spent Fuel Pool:

b) A description of the testing and/or analyses that will be conducted to provide Parameter Normal Plant Operation Beyond Design Basis assurance that the equipment will perform

_____________Operation reliably under the worst-case credible design basis loading at the location where the Temperature 104 0F 212 0F equipment will be mounted. include a Pressure Slightly Negative (-) 3 psig Slightly Positive discussion of this seismic reliability Humidity 2 - 60 % 100 % (SaturatedSteam) demonstration as it applies to a) the level Radiation 1E03Ry 1E07 R sensor mounted in the SFP area, and b) any TID control boxes, electronics, or read-out and Boron 2400 ppm - 2600 ppm 9000 ppm re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or Environmental Conditions in the Containment Enclosure Ventilation Building (CEVA):

emergency responders.

Parameter Normal Plant Operation Beyond Design Basis

____________________Operation c) A description of the specific method or Temperature 104 0F 98 OF**

combination of methods that will be used to Pressure Slightly Negative (-) 3 psig Slightly Positive confirm the reliability of the permanently Humidity 2 -60 % 2-60 %

installed equipment such that following a Radiation 1E03 Ry 1E03R y seismic event the instrument will maintain TID____________ ___________ _

its required accuracy.

Page 10 of 31

" i";, :, .. . ; . . .. ... ". ...... , b: le,- 2"*- *Ao.. . ."-" : ""*.... ." ,Ta " : .

Question No. NRC QUESTION ' LICENSEE RESPONSE : .. :-

Environmental Conditions in the Essential Switch gear Rooms:

Parameter Normal Plant Operation Beyond Design Basis

____________________Operation Temperature 104 0 F 104 0 F Pressure Slightly Negative (-) 3 psig Slightly Positive Humidity 2 -60 % 2-60 %

Radiation 1E03 R y 1E03 R y TID________________________ _

Spent Fuel Pool Water Chemistry Properties:

Parameter Normal Fuel Pool Operation Electric Conductivity Determinedby the concentration of boric acid and alkali present. Expected range will be < 8 to 12 pJMhos/cm.

Solution pH 4.0 -5. 0 Chloride, ppm max. <0.1f5 Fluoride, ppm max. <_0.15 Silica, ppm max. <3 Sulfate <0.15 Aluminum < 0.5 ppm Ca + Mg <0.5 ppm Magnesium < 0.25 ppm Tritium <0.63 uCilml Silica 25 ppm max Boron Concentration 2400 ppm -2600 ppm (9000 ppm BDBE)

The results of the Westinghouse supplied equipment qualificationprogram are summarized in;

EQ-QR-269, Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation System Page 11 of 31

* ' ~~Table 2," '.

Question No. NRC QUESTION ... LICENSEE RESPONSE , .. ,*

(Reference 18).

WNA-TR-O3149-GEN, SFPIS StandardProduct Final Summary Design Verification Report (Reference 19).

CN-PEUS-14 Pool-side Bracket Seismic Analysis (Reference 14).

These reports document the seismic, electromagneticcompatibility and environmental testing and evaluations that were performed by Westinghouse to assure reliability of the system under normal and BDBE conditions.

Required environmentaland seismic qualification testing was performed in accordance with IEEE 323-2003 and IEEE 344-2004. The Seabrook environmental ser'vice conditions were bounded by the Westinghouse qualification test conditions.

Seismic Testing: Seismic qualification testing was performed by Westinghouse in accordance with the requirements of IEEE 344-2004. Technical evaluations were also performed by Westinghouse to confirm that the coaxial connector for the SFPIS meet the Westinghouse establish seismic requirements. Westinghouse's design specification satisfies the Seabrook installation requirements to withstand a SSE.

Vibration Justification: Components for both the primary and backup measurement channels will be permanently installed and fixed to rigid Seismic Category 1 structures and will not be subject to anticipated shock or vibration inputs beyond those covered by seismic verification. The mounting brackets and NEMA 4X(

enclosures that will be used to house the SFPIS electronics are inherently resistant to shock and vibration loadings. As a result, no additional shock and vibration testing is required for these components.

Sloshing Justification: Sloshing forces were obtained by analysis. The TlD-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach has been used to estimate the wave height and natural frequency. Horizontal and vertical impact force on the bracket components were calculated using the wave height and natural frequency obtained using TID-7024 approach. Using this methodology, sloshing forces were calculated and added to the total reactionaryforces that would be applicable for the bracket anchorage design. The analysis also determined that the level probe can withstand a design basis seismic e*/ent. The sloshing calculation performed by Westinghouse (L TR-SEE-IlI-13-47, Reference 29) was reviewed for a design basis seismic event and found acceptable. Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

Environmental Testing: Priorto conducting seismic qualification testing the SFPIS equipment was mechanically preconditioning, thermally aged and radiation aged in accordance with the requirementsof IEEE 323-2003. As part of the environmental testing program, the SFPIS coaxial cable, coupler and probe located within the spent fuel pooi area were also subjected to steam testing at 0-95% RH (Non-condensing) for the electronic enclosures and 0-100% (Non-condensing) for the sensor electronics (level transmitter). The EMC testing was also nerformed in accordancewith~the reouirements of NRC Reoulatorv Guide 1.180. The aooreoateof the Page 12 of 31

.*: . ...*::., '-:=: ' ~ ~~Table

... 2. " " " :*," :*!i . .

Question No., NRC QUESTION 'LICENSEE RESPONSE o environmental verification activities for the SFPIS demonstrate that the SFPIS will operate reliably per the service environment requirements specified for the Spent Fuel Building (SFB) as well those as for outside the SFB.

The plant Service environment chart (1-NHY-3002 19, reference 37) summarize the environmental conditions for the essential switchgear rooms where the SFPI displays will be located and containment enclosure fan area (CEVA) where the level transmitters will be mounted. The referenced calculations support the noted environmental conditions for radiation, pressure and humidity. The specified normal conditions are not expected to change in these areas as a result of an extended loss of offsite power event. See Enclosure 6.

Seabrook calculation MSVCS-FAG-08 calculates the temperature response of the environmental zones outside of Containment following a loss of all non-Class 1E HVAC systems. This calculation concluded that the steady-state temperature in the CEVA would not exceed 98'°F when one train of the Class 1E ventilation is running (1-EAH-FN-3 1-A/B, 1-EAH-FN-5-A/B and 1-EAH-FN-IO8-A/B). Therefore, one train of Class IE, safety related ventilation is assumed to be available as part of the FLEX strategies to ensure area temperature is not exceeded for long term operation of the SFPIS following a BDBE.

The A and B switchgear room supply and exhaust fans (1-CBA-FN-19, -20, -32 and -33) are capable of maintainingtemperature in the A and B switchgear rooms below 104°F.

During the interim to re-establishingpower to the area ventilation systems noted above, compensatory operator actions may be required to induce natural circulation cooiling in the Spent Fuel Building, CEVA and!/or Essential Switchgear Rooms. These actions wiil include the opening of doors to the outside environment and the deployment of portable equipment to initiate area cooiling. Assessment of these areas for high temperature and deployment of compensatory ventilation actions wiil be directed by the new FLEX Support Guideiline (FSG) procedures.

Temperature and humidity in the Fuel Storage Building are assumed to increase from normal operatingconditions to the conditions specified in Order EA-12-051 (212 F and 100% saturatedsteam,).

During normalplant operation the Fufel Storage Air HandlingSystem (FAIl,) maintainsa slightly negativepressure 4'-,) 3 psig) in the Fuel storage Building to supportfutel handling operations. During a BDB event the ventilation w*ould shutdoimn due to loss of poimer and Fuel Storage Buildingpressure *,'onld increase to atmosphericpressure (slightlypositive). Based on reviewl of the design of the pool side components a negative pressure of (-) 3 psig will not negatively impact the capability of the equipment to pemformn as designed. The pool side components arepassive devices. The coupler is composed of stainless steel imith a boric silicate glass seal. The connector on the coupler"also contains a siliconegasket and PEEK insulatorthat seals the coaxial cable connection. The cable connectors are Page 13 of 31

, " * '* : ;': * :ii * ,Ta b le 2 : : ° : '... . : ... ... . .. . ...... .. . ... . . . ..

Question No. NRC QUESTION {LICENSEE RESPONSE installed utsing crimp type connections that are sealed by epoxy. These seals wtill prevent the potentialfor moistur'e to be driven into the pool side probe connections and cables by this relatively small change in atmosphericpressure.

SEP Chemistry:

The SFPIS components that reside within the spent fuel pool that were evaluated for exposed to the chemistry of the spent fuel pool water are the Pool-Side Bracket, the probe and the coupler assembly. The materials for these components were selected by Westinghouse based on the application and are inherently resistant to the chemistty in the environment of the SEP. An evaluation of the SEP15 materialsand compatibility with the SFP chemistry was provided by Westinghouse in report WNA-TR-O3149-GEN (Reference 19)

Westinghouse also evaluated the effect that boric acid build up on the probe cable would have on SEPIS level measurement. Westinghouse testing demonstrated that the level measurement remained within standard accuracyof +1-3 inches with a 4-inch-long, 0.25-inch layer of boric acid buildup on the SEPIS probe cable.

Westinghouse also evaluated changes in boron concentration that would result as the SEP boils and level decreases to the top of the fuel racks. Analysis contained in Westinghouse letter L TR-CDME-13-78 (Reference

30) indicates that the boron concentration up to 9000 ppm post-event will not impact performance or accuracy the SEPIS.

NextEra Response Question 6b The SEPIS equipment (inside and outside of the SFB) were subjected seismic testing to demonstrate that the equipment will perform reliably during and following a seismic event. Seismic testing was conducted in accordance with IEEE 344-2004 and IEEE 323-2003. The seismic test results are documented in Westinghouse Reports EQ-QR-269 (Reference 18) and EQLR-281 (Reference 31). A pull test was also performed by Westinghouse to support seismic qualification of the 90 degree connectors on the coaxial sensor cables. This testing is documented in Westinghouse letter L TR-EQ-14-26 (Reference 32). Priorto seismic testing, the equipment was subjected to thermal and radiation aging as specified in Westinghouse document EQ-EV-196 (Reference 33).

The SEPIS equipment was tested to the Safe Shutdown Earthquake (SSE) and Hard Rock High Frequency (HRHF) spectra shown in Figure 4.4-1 and Figure 4.4-2 of Westinghouse Report EQ-QR-269 (Reference 18).

The OperatingBasis Earthquake (OBE) Test Response Spectra (TRS) at 5% critical damping was at least 70%

of the respective SSE seismic level. Five successful OBE level tests were performed, followed by two successful SSE level tests and one successful HRHF level test. The seismic Test Resoonse Soectra (TRS)

T i I

f Page 14 of 31

Question No. NRC QUESTIONLIESERPOE contained in Figures4.4-1 and 4.4-2 of Westinghouse Report EQ-QR-269 was compared to the Seabrook area specific required response spectra (RRS) and found to be enveloping with respect to the plant OBE and SSE response spectra included Enclosure 4 and reference 38.

Therefore, the SEPIS seismic qualification demonstrated that the SFPIS will maintain functionality in a BDBE environment (before and after a seismic event), including:

1. Structural integrity of the SEPIS system will be maintainedbefore, during, and after a seismic event.

2. The level reading and transmitting portions of the system will work before and after the seismic event, and remain within the acceptance criteriaof+_ 3 inches.

3. The SFPIS capabilityfor the SFPIS to switch to battery power automatically when AC power is removed will be maintainedbefore, during, and after a seismic event.

The seismic adequacyof the SEPIS (all components) was demonstrated by Westinghouse in accordance with the foilowing standards:

IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Electrical Equipment for Nuclear Power GeneratingStations

IEEE-323-1974, Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations

USNRC Regulatory Guide 1.100, Rev. 3

USNRC Regulatory Guide 1.92, Rev. 1 Seismic adequacy of the level sensor probe supportingbracket within the SEP area was demonstrated by analysis as discussed in response to Item 3 above.

NextEra Response Question 6c As described in the response to NRC question 3, Westinghouse seismically qualified the SEPIS equipment in accordance with the requirements of IEEE 344-2004 to OBE and SSE TRS that envelopes the RRS for the equipment mounting locations at Seabrook. The acceptance criteria for the seismic testing included verification that SFPIS level indication accuracy (+1-3 inches) was demonstrated during seismic qualification testing. With Page 15 of 31

Question No NC UETINLICENSEE RSOS the instrumentbeing seismically qualified and installedas described in the response to NRC question 3 above, the instrumentis assured to maintain reliable and accurate indication when required. Westinghouse report WNA-CN-00301-GEN and Seabrook Engineering Change 281849 provide the channel accuracyfrom measurement to display.

For RAI No. 6 above, please provide the NextEra Response Question 7 results for the selected methods, tests and analyses utilized to demonstrate the Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-O3149-GEN describe the qualificationprogram that Westinghouse applied to the SFPI components and summarizes the qualification test results.

qualification and reliability of the installed Westinghouse qualified the SFPI components to a 10 year design requirement. Seismic and environmental equipment in accordance with the Order qualification testing of the equipment was performed in accordance with IEEE 344-2004 and IEEE 323-2003.

requirements. Prior to conducting qualification testing the SFPIS equipment was mechanically preconditioning, thermally aged and radiationaged in accordance with the requirements of IEEE 323-2003. As part of the environmental testing, the SFPIS coaxial cable, coupler and probe located within the spent fuel pooi area were subjected to steam testing. The EMC testing was also performed in accordance with NRC Regulatory Guide 1.180.

The Seabrook environmentalservice conditions are bounded by the Westinghouse qualification test conditions.

In summary, the SFPIS equipment has been qualified by Westinghouse to withstand the following environmental conditions:

Environmental Conditions for Equipment in the Spent Fuel Pool Area:

The components that will be located in the spent fuel pool area are SFPISprobes and mounting brackets, launch plates, couplers and coaxial signal cables. In accordance with NRC OrderEA-12-051 the components that will be located in the spent fuel pool area are required to operate reliably at temperature, humidity and radiationlevels consistent with postulated worst case BDBE service conditions for at least seven days including:

Radiologicalconditions for a normal refueling quantity of freshly discharged (100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months ) fuel with the SEP water at level 3,

Temperature of 212 degrees F and 100% relative humidity environment,

SEP boliing water and/or steam environment,

Concentratedborated water environment.

Components of the system were subjected to beyond design basis conditions of heat and humidity, thermal and radiationaging mechanisms. This testing confirmed functionality of these system components under the oostulated BDBE conditions. Since the radiolcoicalconditions for level 3 had not been calculatedoreviouslv, Page 16 of 31

Tabl 2 Question No. NRC QUESTION *LICENSEE RESPONSE .o Seabrook contractedARE VA NP Inc to determine the total integrateddose to the pooi side SEPIS equipment for reduced SFP inventory conditions. The results of the calculation are document in Seabrook FP 700488, Spent Fuel Pool Instrumentation System Dose Assessment." The 7 day Time IntegratedDose (TID) to the pooi side SFPIS equipment was calculated by Seabrook based on the results of the ARE VA analysis with considerationof the shielded that would be provided by the water in the pool during drain down.

The TID to the pool side equipment considering worst case normal operationalconditions and post event conditions, for no less than 7 days post event is 8. 872E6 rad. This TID is bounded by Westinghouse qualification of pool side SEPIS equipment to 1E7 rad. This dose calculation is also considered to be consenvative since the Seabrook FLEX strategiesinitiate makeup to the spent fuel pooi well in advance of inventory/loss to level 3. Therefore, the duration of SFPIS operation at Level 3 will be much less than the 120.55 hrs assumed in the analysis above.

The Westinghouse qualification reports noted above describe the testing and evaluations that were performed as part of the equipment qualification program to demonstrate the capability of the pool side equipment to perform reliably for at least 185 hours0.00214 days 0.0514 hours 3.058862e-4 weeks 7.03925e-5 months when subjected to the beyond design basis environmental conditions noted in the table below. This duration exceeds the seven day requirement from NRC Order EA-12-051 for operation of the SFPIS. The as tested environmental parametersalso envelop the normal and BDBE senvice conditions for the Fuel Storage Building.

Westinghouse Qualified Environmental Conditions at the Spent Fuel Pool:.

Parameter Normal Plant Operation Beyond Design Basis Operation Temperature 50 - 140 0F 212 0F Pressure Atmospheric Atmospheric Humidity 0-95% RH 100% Saturated Steam Radiation TID (above 1E03 R y 1E07 R y Pool)

Radiation TID (1' < 1E09 R y (only probes 1E07 R y (only probe's above top of fuel rack) . stainless steel cable and weight stainless steel cable and are exposed for the period) weight are exposed for 7

____________________________________________days)

Page 17 of 31

{;Y

" ~~~Table 2 ** *". "

Question No." NRC QUESTION, LICENSEE RESPONSE : ..:":i :* .. * *' ' :"... '*

With the exception of pressure the qualification program demonstrated that the pool side equipment will perform reliable during normal and anticipatedBDB environmentalconditions in the Fuel Storage Building for the seven day duration requiredby NRC Order EA-12-051. During normal plant operation the Fuel Storage Air Handling System (FAH) maintains a slightly negative pressure ((-) 3 psig) in the Fuel storage Building to support fuel handling operations. During a BDB event the ventilation would shutdown due to loss of power and Fuel Storage Building pressure would increase to atmospheric pressure (slightly positive). Based on review of the design of the pool side components a negative pressure of (-) 3 psig will not negatively impact the capability of the equipment to perform as designed. The pool side components are passive devices. The coupler is composed of stainless steel with a boric silicate glass seal. The connector on the coupleralso contains a silicone gasket and PEEK insulator that seals the coaxial cable connection. The cable connectors are installed using crimp type connections that are sealed by epoxy. These seals will prevent the potentialfor moisture to be driven into the pool side probe connections and cables by this relatively small change in atmosphericpressure.

Environmental Conditions Outside of the Spent Fuel Pool Area:

The components outside the spent fuel pooi area are required to operate reliably for the senvice environmental conditions specified for a mild environment. These components are the level transmitters, SFP Surge Filter and enclosures, and the SFPIS electronic equipment. Testing and evaluations that were performed by Westinghouse verified that this equipment will perform reliably when subjected to the normal and BDBE environmental condition noted below:

Environmental Conditions outside of the Spent Fuel Building:

Parameter Normal Plant Beyond Design Basis Operation Operation Temperature 50-120 deg. F 140 0F Pressure Atmospheric Atmospheric Humidity 0-95% RH 0-100% (non-condensing)for Sensor Electronics (Level transmitter) 0-95% (non-condensing) for Electronics Enclosure Radiation TliD 1E03 R y 1E03 R y Environmental 3 days 3 days Duration (for single charge of system installed batteries)

Page 18 of 31

Question No.* NRC QUESTION' ; *... .. "*: *'*: { ;ICENSEE L RESPONSE ' ;' ' ... .: :: ' **. ..... ." ' ,:i' ..* "!

With the exception of pressure the qualification program demonstrated that the equipment located outside of the Spent Fuel Building will perform reliable during normal and anticipatedBDB environmental conditions for the seven day duration required by NRC Order EA-12-051. During normal plant operation the Containment Enclosure Ventilation Area (CEVA) and the Essential Switch gear Rooms are maintained a slightly negative pressure by the area ventilations systems. The SFPIS equipment that will be located in these areaswill consist of cabling and panel wiring, batteries, emergency power control switches and the various electronic modules, digital indicators,power supplies, UPSs and surge filters that comprise the SFPIS signal processing electronics.

These components are similarin construction to other safety related and non-safety related components that have been in senvice in these areas for many years.

Based on similarity and operatingexperience, it was concluded that the minor pressure differentialthat results from area ventilations system operation will not affect reliability or performance of the SEPIS components that are located in CEVA or Essential Switch gear Rooms.

The level transmitterhousings were also verified to meet IP67 rating per EPSILON 08 TEST 2373, which ensures that the equipment is protected from dust and water ingress such that it can withstand 100% humidity.

The Westinghouse supplied coaxial cable is rated for temperatures up to 221 deg. F and will be able to withstand the conditions expected in the spent fuel building during a Beyond Design Basis Event (BDBE), which exceed those outside the spent fuel pooi area. The coaxial cable connectors are also rated to meet IP67.

Shock and Vibration:

SFPIS pool side brackets were analyzed for Safe Shutdown Earthquake (SSE) design requirements per NRC order EA-12-051 and NEI 12-02 guidance. Components for both the primary and backup measurement channels will be permanently instailed and fixed to rigid Seismic Category 1 structures and wiil not be subject to anticipatedshock or vibration inputs beyond those covered by seismic verification. The mounting brackets and NEMA 4X enclosures that wiil be used to house the SFPIS electronics are inherently resistant to shock and vibration loadings. As a result, no additionalshock and vibration testing is required for these components.

SFPIS pool side brackets for both the primary and backup Westinghouse SFF measurement channels wiil be permanently installed and fixed to rigid refuel floors, which are Seismic Category I structures. The SFPI system components, such as level sensor and its bracket, display enclosure and its bracket, were subjected to seismic testing, including shock and vibration test requirements. The results for shock and vibration tests were consistent with the anticipatedshock and vibration expected to be seen by mounted equipment. The level sensor electronics are enclosed in a NEMA-4X housing. The display electronics panel utilizes a NEMA-4X rated stainless steel housing as well. These housings wiil be mounted to a seismically qualified wail and will contain the active electronics, and aid in protecting the internal components from vibration induced damage.

_____________ .1__________________________________________ j Page 19 of 31

Qu~estion No. NRC QUIESTION " .. ILICENS*EE RESPONSE ' ' .... : -

Electromagnetic Compatibility (EMC) Qualification:

The Westinghouse supplied SEPIS equipment was subjected to EM// RFI emissions and susceptibility type testing in accordancewith the guidance provided in Regulatory Guide 1.180 Revision 1. The EMC qualification program included tests for Low and High Frequency Radiated Susceptibility (magnetic fields), Low and High Frequency Conducted Susceptibility, Low and High Frequency Radiated Emissions (Electric Field), Electrostatic Discharge, Surge and Electrical Fast Transients. Radiated Electromagnetic Emissions from the equipment were also measured. Westinghouse identified that the suite of EMC tests and acceptance criteria were establishedbased mainly on the non-safety related classification of the SFPIS. A summary of the results of the EMC qualificationtesting are provided in the Westinghouse reports referenced above.

Based on the results of the EMC qualification testing, Westinghouse confirmed that the SFPIS could only be qualified to the operationalrequirements for a Performance Criterion B system. The requirements for performance criterion A ensure that the equipment under test will continue to operate during and after the test.

Performance criterion B only requires that the equipment under test continue to operate after the test, but not during the test. Both performance criterion A and B require that there is no degradationor loss of function below the performance level specified by the manufacturer when the equipment is used as intended. For the EMC quailification testing Westinghouse monitored performance of the system level reading with an acceptance criteriabased on the capabilityto provide level readings within the estabilished accuracy of the system (+1- 3 inches).

During EMC testing Westinghouse encountered several chailenges to qualfification of the equipment to performance criterion B and modifications were requiredto harden the system. These modifications included routing of the coaxial cable in conduit from the level transmitter to the SFP probe, the addition of EMI gasketing around the door of the remote enclosure, replacement of the sensor (transmitter)level indicatorview port housing cover with a solid metal cover and several wiring and grounding modifications to remove antenna effects from cabling and shield ground connections within the electronics enclosure. These modifications were incorporatedinto the standard Westinghouse SFPISproduct design.

As a result of the challenges that Westinghouse encounteredduring EMC testing, a Utility Working Group was formed to review the test methods and determine the applicability of using performance criterion B versus criterion A for the SFPIS. The Utility Working Group concluded that criterion A should be applied as the goal for EMC quailification to ensure that the equipment will operate as intended. The group also requested that Westinghouse identity any gaps where the equipment could not be sufficiently hardened to meet criterion A with a basis for acceptance. With the Utility working Groups input, Westinghouse performed additionalEMC qualfification testing using performance criterion A. The results of this testing identified that the exposed portion of the probe is susceptible to radiatedemissions. Westinghouse Report EQ-QR-269 documents the results of the supplemental EMC testing.

____________ J ________________________________________ J Page 20 of 31

Question. No. !NRC QUESTION .. ; ., LICENSEE RESPONSE* ** ..,

Since the SFPIS could not be fully qualified to the operational requirements for performance criterionA due to RFI susceptibilityof the probe, Seabrook contracted National Technical Systems to perform EMIl RFI surveys of Spent Fuel Building and CEVA areas where the new equipment will be located. The results of the surveys are documented in Seabrook FP 700466, Evaluation of Spent Fuel PoolArea EMIl RFI Background Conditions. Comparison of the survey results to the results of the additionalEMC testing that was performed by Westinghouse indicates that there are no EMI!IRFI sources in the Spent Fuel Building during normal plant operation that would negatively affect proper operationor the capability to calibrate the SFPIS. Since the use of portable transmitters could have an effect on operationof the equipment, administrativecontrols will be implemented at Seabrook to ensure that radio use within the Spent Fuel Building is precluded during periods when the system is being calibratedand!/orlevel readings are being taken in response to a BDBE. It should also be noted that EMIl RFI sources will be limited to portable transmitter devices during a BDBE since power to plant communications equipment would not be available.

Chemistry/Boron Plating:

The SFPIS components that reside in or near the SFP will be exposed to the chemistry of the SFP as noted above. The materialsof the probe (316L Stainless Steel) and the pool side bracket (ASTM A 240 Type 304) were selected specifically based on the application and environment of the spent fuel pool. The coupler assemblies were also manufactured from stainless steel and boric silicate glass. These materials are inherently resistant to the chemistry in the 8FF environment. The only item of concern is boron due to the potential for plating that can occur on objects in the SFP at the normal water level. The probe manufacturer and Westinghouse performed testing to demonstrate the effects of boron on level measurement. The test demonstrated that the level measurement remained within standardaccuracy with a 0.25 inch by 4 inch long layer of boric acid build up on the probe cable (See Reference 19). This was further demonstrated during the FactoryAcceptance Testing of the SFPIS by Westinghouse.

The results of the Westinghouse supplied equipment qualification program are summarized in;

EQ-QR-269, Design Verification Testing Summary Report for the Spent FuelPool Instrumentation System (Reference 18).

WNA-TR-O3149-GEN, SFPIS StandardProduct Final Summary Design Verification Report (Reference 19).

CN-PEUS-14 Pool-side Bracket Seismic Analysis (Reference 14)

These reports document the seismic, electromagneticcompatibility and environmental testing and evaluations that were performed by Westinghouse to assure reliabilityof the system under normal and BDBE conditions.

Required environmentaland seismic qualificationtesting was performed in accordance with IEEE 323-2003 and IEEE 344-2004.

Westinoho use reoort EO-QR-269 contains an ooen item to track resolution of the n~otential shortfall in the Page 21 of 31

", i Table 2, Question No. NRC QUESTION ... LICENSEE: RESPONSE, " "

radiationdose calculations performed by Steris Isomedix based on NRC NON to SterisIsomedix Inspection Report No. 99901445/ 2014-20 1. Westinghouse provided an interim position on the inspection report in Westinghouse letter L TR-EQ- 14-163. Westinghouse's position is that the requirements for radiation aging of the SFPIS equipment included margin and uncertainty that was based on industry standards and known accuracy of the Steris dosimetry equipment. The radiationaging certificate for the SFPIS equipment identifies that a minimum of 12.1 Mrads was achieved; therefore, the actual radiationdose that was achieved for aging of the SEPIS equipment was sufficient for a 10-year specimen. NextEra is tracking closure of this open item and will provide additional update if this position changes.

The BDBE radiationvalue to which the Westinghouse equipment is qualified are 1E+09 R y for the stainless steel probe assembly in the spent fuel pool and 1E+07 R y for the SEPIS equipment (coupler, coaxial cable and connector) above the pool (Ref. Section 5.1.2 of Westinghouse Report WNA-TR-O3149-GEN, Reference 19).

When the SEP water level is at Level 3, the only components of the SEPI that are exposed to higher radiation are the stainless steel probe and anchor. These components are manufactured from stainless steel which is resistant to the effects of high radiation.

As described above, to the pool side SFPIS equipment was qualified tolE07 R 2". Based on the results of calculationsdocumented in FP 700488, Spent Fuel Pool InstrumentationSystem Dose Assessment" the dose rate for actions at the SEP during BDBE with SEP inventory reduced to level 2 is 0.01 radlhr. This dose rate assures adequate shielding is provided to maintain radiologicalexposure to personnel performing preplanned operatoractions in response to loss of SEP inventory within acceptable limits if SEP inventory is reduced to level 2.

8. Please provide the NRC staff with the final NextEra Response Question 8 configuration of the power supply source for each channel so the staff may conclude the One of the requirements of NRC Order EA-12-051 is that permanently installed SEP instrument channels shall be powered two channels are independent from a power by separate power supplies. To satisfy this requirement, instrument loop L-2616 will be supplied 120 Vac power from Train supply assignment perspective. A diesel backed MCC E515 via an existing spare circuit (CKT 20) in distribution panel E3E. Similarly, Train B diesel backed 120 Vac power from an existing spare circuitin MCC E615 distributionpanel E3F (CKT 20) will be used to power instrument loop L-26 17. The unit electricaldistribution one line diagram is attached as Enclosure 5. This diagram shows independence of the power supply from MCC-E515 and MCC-E615.

9. Please provide the results of the calculation depicting the battery backup duty cycle NextEra Response Question 9 requirements and compatibility with the duration required for the plant mitigating The Westinghouse Report, WNA-CN-0O30O-GEN (Reference 23), provides the results of the calculation depicting the Istrategy for assuring SFP level filling/ battery backup duty cycle. This calculation demonstrates that battery has the capacity to maintain the level indicating Page 22 of 31

. . *:i.. .. . Table 2 Question No., NRC QUESTIONLICENSEE RSPoNsE* o,.*

cooling, function to the display locations in the A and B Train Essential Switch gear Rooms for 4.22 days. The Flex designated guidelines for Seabrook is 3 days; therefore, the results of the calculation meet the battery capacity requirements for Seabrook.

Please provide the following: NextEra Response Question 10a 10.

a) An estimate of the expected instrument The Westinghouse documents WNA-CN-OO301-GEN (Reference 22) and WNA-DS-O2957-GEN (Reference 34) channel accuracy performance under both describe the channel accuracy under both (a) normal SEP level conditions and (b) at the Beyond Design Basis (BDB)

(a) normal SFP level conditions conditions that would be present if SEP level were at Level 2 and Level 3 datum points. The overall channel accuracy (approximately Level 1 or higher) and (b) at for the SFPIS level indication was established by Westinghouse based on individual component accuraciesusing the beyond design-basis conditions (i.e., statistical square root sum of the squares (SRSS) methodology as stated in ISA RP67.04.02-2010, "Methodologies for radiation, temperature, humidity, post- the Determinationof Setpoints for Nuclear Safety Related Instrumentation." Each instrument channel will be accurate seismic and post-shock conditions) that to within +1-3 inches during normal spent fuel pool level conditions.

would be present if the SFP level were at the Level 2 and Level 3 datum points.

The instrument channels will retain this accuracy during and following a BDBE. This accuracy is within the +/-1 foot channel accuracy requirements of the Order.

b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument NextEra Response Question 10b channel design accuracy that will be employed under normal operating Westinghouse calibrationprocedure WNA-TP-O4709-GEN (Reference 25) describes the methodology that will be conditions. used to ensure that channel accuracyis maintained. As described in the Westinghouse calibrationprocedure, an empirical Mwo point check of the equipment performance will be performed by lifting the probe assembly by a fixed distance.

This method requires unbolting of probe bracket assembly at the pooi and lifting the assembly approximately 2-1/2 feet above the curb of the SEP. The distance traveled will be compared to the change in SEPIS level reading. If the indicated

___________ ___________________________________SFPIS level is not within_+1-_3_inch of level readings that are based onM&TE measurement of SEP level,_the electronic Page 23 of 31

' ,o Table 2 ,

Question No. NRC QUESTION " * ': LICENSEE RESP*ONSE' Y ";

output of the level transmitterwould be verified andif requiredcalibratedto set to the output to the required 4-20 mA signal.

If the electronic output calibrationdoesn't resolve the anomaly a full range calibrationadjustment will be performed using the Westinghouse Calibrationkit. This calibrationmethod uses a repllcateprobe, couplerand launch plate to simulate the installed field equipment to perform a full range (five point) calibrationof the level transmitter.

Standardchecks will also be completed following the calibration to ensure that the SEPIS channels are operating propedly. These checks will include verification of the power supply performance, transmitterwaveform inspection, cleaning of any residual boron buildup on the probes and visual inspection of the probe assemblies for indication of degradation or damage. Proceduresdeveloped by Seabrook will follow the guidance provided in Westinghouse calibration procedure WNA-TP-O4709-GEN. Calibration will be performed once per refueling cycle within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g. 25%). This frequency is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation. New l&C maintenanceprocedures will be wdtten to incorporatethe Westinghouse calibrationmethods.

11. Please provide the following: NextEra Response Question 11a a) A description of the capability and Westinghouse calibrationprocedure WNA-TP-O4709-GEN (Reference 25) describes the capabilitiesand provisions provisions the proposed level sensing for periodic verification and calibrationof the SEPIS, including in-situ testing. Seabrook will utilize the methodology equipment will have to enable periodic provided in the Westinghouse calibration procedure in plant procedures for the functional check at the pooi side testing and calibration, including how bracket.

this capability enables the equipment to be tested in-situ. NextEra Response Question l1b The level displayed by the SFPIS channels wiil be verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as part of Nuclear System Operator(NSO) b) A description of the ways testing and rounds. This verification wiil compare level readings from the SFPIS channels to the existing control room SFP level calibration will enable performance of indication (1-SF-LI-2607). Channelmaintenance including channel calibration(s) will be initiated if the deviation regular channel checks of each between indicated level readingsexceeds the bounding 3.0 inch uncertainty of SFP level readingsbetween the existing independent channel against the other SFP level indicator(1-SF-LI-2607, +1-2 in.) and the new SFPIS indicators(+1-3 in).

and against any other permanently-installed SFP level instrumentation. NextEra Response Question 11c c) A description of how functional checks Procedures developed by Seabrook will follow the guidance provided in Westinghouse calibrationprocedure WNA-will be performed, and the frequency at TP-O4709-GEN. Calibration will be performed once per refueling cycle within 60 days of a planned refueling outage which they will be conducted. Describe considering normal testing scheduiling allowances (e.g. 25%). This frequency is in compliance with the NEI 12-02 how calibration tests will be performed, guidance for Spent Fuel Pool Instrumentation. New I&C maintenance procedureswill be written to incorporate the and the frequency at which they will be Westinghouse calibrationmethods. Standardchecks will also be completed as part of the calibrationto ensure that the conducted. Provide a discussion as to SFPIS channels are operatingproperly.

how these surveillances will be incorporated into the niant surveillance These checks will include verification of the cower sunolv cerformance, transmitterwaveform insjjection, cleanincq of I = w VJ * * . i - v Page 24 of 31

o . . . ... .o ..... :*T able 2 * ,'*

NRC QUESTION LICENSEE RESPONSE program. any residual boron buildup on the probes and visual inspection of the probe assemblies for indicationof degradation or damage. Calibrationprocedure implementation will be tracked as a preventive maintenance activity under the work control program.

d) A description of what preventive maintenance tasks are required to be performed during normal operation, and NextEra Response Question 1lid the planned maximum surveillance interval that is necessary to ensure that The level displayed by the SFPIS channels will be verified every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months as part of Nuclear System Operator(NSO) the channels are fully conditioned to rounds as described in the response to question 1l.b above. Channel maintenance or cailibrations that result from accurately and reliably perform their unacceptable deviations in level indications wiil be tracked by the corrective action program and associatedmaintenance functions when needed. activities under the work control program.

Seabrook will develop preventive maintenance tasks for the SEPI per Westinghouse recommendation identified in the technical manual WNA-GO-OO127-GEN (Reference 24) to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

12. Please describe the evaluation used to NextEra Response Question 12 validate that the display location can be accessed without unreasonable delay following a BDB event. Include the time NRC Order EA-12-O51inc/udes a requirement that the indication of SEP level must be promptly accessible to the available for personnel to access the display appropriateplant staff. For this application the appropriateplant staff includes the plant Operators and Technical Support as credited in the evaluation, as well as the Center (TSC) staff. The SFP level indication will be provided by digitalpanel meters located on the front of the redundant actual time (e.g. based on wal k-throughs) SFPIS control panels that will be mounted in the "A" and "B" Train Essential Switch gear Rooms which are located in the that it will take for personnel to access the Control Building. These locations assure that the SFP level indications wiil be promptly accessible from the Control Room dispay.Addiionlly incudea dscritio of Operatorsand TSC through assess routes that are protected by seismic Category I structures againstadverse weather, the radiological and environmental missiles and potentially degraded SFP radiologicalconditions that could occur during a BDBE.

conditions on the paths personnel might Page 25 of 31

Question No. NRc QUESTION, * .LICENSEE RESPONSE

take. Describe whether the display location Figure 5.1 of Seabrook procedure SM 7.20, "Control of Time CriticalActions and Operatorresponse Times',

remains habitable for radiological, heat and established a conservative 2 minute transittime for an Operatorto travel from the Control Room to the "B" Train humidity, and other environmental Essential SwitchgearRoom. The "A" Train EssentialSwitch gear Room is directly adjacent to the Train B Switch gear conditions following a BDB event. Describe Room. Conservatively assuming a 1 minute transit time between the essential switchgearrooms and 5 minutes to whether personnel are continuously read and communicate the SFP level reading to the Control Room, the maximum time to achieve a SEP level reading stationed at the display or monitor the from the Control Room is conservatively assumed to be 8 minutes. This time is considered to be reasonable with display periodically, respect to the requirement for prompt accessible indication of SEP level indications.

The plant Service environment charts attached as Enclosure 6 summarize the environmental conditions for the essential switchgear rooms where the SFPI displays will be located. The referenced calculations support the noted environmental conditions for radiation, pressure and humidity. The A and B switchgear room supply and exhaust fans (1 -CBA-FN-1 9, -

20, -32 and -33) are capable of maintaining temperature in the A and B switchgear rooms below 1040 F. Radiological conditions will not prevent access to the indication. The 60 year TID for the area is specified as 1 .50E3 rad. The maximum relative humidity specification for the area is 60 %. The specified normal conditions are not expected to change in these areas as a result of an extended loss of offsite power event.

i3. Please provide a list of the procedures NextEra Response Question 13 addressing operation (both normal and abnormal response), calibration, test, The modification review process will/be used to ensure all necessary procedures are developed for maintainingand maintenance, and inspection that will be operating the spent fuel level instruments after installation. These procedures will be developed in accordance with developed for use of the SFP NextEra proceduralcontrols. The objectives of each proceduralarea are described below:

instrumentation. Include a brief description of the specific technical objectives to be Inspection, Calibration and Testing - Guidance on the performance of periodic visual inspections, as well intrusive achieved within each procedure. testing, to ensure that each SEP channel is operating and indicating level within its design accuracy.

Preventative Maintenance - Guidance on scheduling of, and performing, appropriatepreventative maintenance activities necessary to maintain the instruments in a reliable condition.

Maintenance - To specify troubleshooting and repair activitiesnecessary to address system malfunctions.

ProgrammaticControls - Guidance on actions to be taken if one or more channels is out of service.

System Operations- To provide instructionsfor operation and use of the system by plant staff.

Resoonse to inadeguate levels - Action to be taken on observationsof levels below normal level will be addressed in Site off normal proceduresand/or FLEX Support Guidelines.

Westinghouse calibrationprocedure WNA-TP-O4709-GEN (Reference 25) descnibes the capabilitiesand provisions

__________________________________for periodic testing and calibrationof the SFPIS,including in-situ testing. Seabrook utilized the methodology Page 26 of 31

Table 2 NRC QUESTION , LICENSEE RESPONSE ."

described in the W~estinghouse calibrationprocedure for the functional channel checks at the pooi side bracket and channel calibrations.

The following procedures have been developed to maintain the system:

PM TITLE FREQ SE-L -2616-CAL-i TRAIN A SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year SF-L -2616-BR-I TRN A SFP LEVEL 1-SF-CP-3OO-A BA 7TERY REPLA CEMENT 3 Year SF-L -2616-MAN-I TRN A SFP LVL XMTR 1-SF-LIT-2616 REPLACEMENT 7 Year SF-L -2616-MA N-2 TRN A SEP LVL PWR SUPPLY I-SFE-UQ-2616 REPLACEMENT 10 Year SF-L-2617-CAL-I TRAIN B SPENT FUEL POOL LEVEL (BDB) CALIBRATION 1 Year SF-L-2617-BR-1 TRN B SFP LEVEL 1-SF-CP-3OO-B BATTERY REPLACEMENT 3 Year SF-L-2617-MAN-1 TRN B SEP LVL XMTR 1-SF-LIT-2617 REPLACEMENT 7 Year SF-L-2617-MAN-2 TRN B SEP LVL PWR SUPPLY 1-SF-UQ-2617 REPLACEMENT 10 Year The following high level FSGs will direct operators to monitor SEP level using SEPIS:

FSG-O.0, Extended Loss of All AC Power with SEPS FSG-O. I, Extended Loss of AII AC Power without SEPS FSG-5, Initial Assessment and FLEX Equipment Staging FSG-11I, Alternate SEP Makeup and Cooling FSG-14, Extended Loss of All AC Power while Plant Shutdown When SEP level cannot be maintained greaterthan 23 feet above the top of the racks the FSG procedures direct operators to implement FSG-11I, Alternate SEP Makeup and Cooling.

FSG-5, Initial Assessment and FLEX Equipment Staging, will provides methods to establish portable ventilation in the CEVA area when area temperature is greater than 130°0F.

FSG-5, Attachment G, Restore Miscellaneous Lighting and Pipe Chase Ventilation Power, will provide an alternatepower source to SFPIS.

The following OperatingProcedures will also be revised to address alignment of the SEPIS for operation.

0S1014.01, Spent Fuel Cleanup and Cooling System Fill and Vent (system lineup) 0S1046.58, MCC-515 Maintenance Procedure 0S1046.65. MCC-615 Maintenance Procedure Page 27 of 31

Table '2...

NRC QUESTION . . . *': : . .LICENSEE RESPONSE' "

o '. . .. " " ' ... "....

Piease provide the following: NextEra Response Question 14a a) Further information describing the SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and maintenance and testing program the system readiness will be established in accordance with NextEra's processes and procedures. The design modification licensee will establish and implement to process will take into consideration the vendor recommendations to ensure that appropriate regular testing, channel ensure that regular testing and checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit).

calibration is performed and verified by inspection and audit to demonstrate Once the maintenance and testing program requirements for the SEP are determined, the requirements will be conformance with design and system documented in Maintenance program documents.

readiness requirements. Please include a description of your plans for ensuring Performance checks, described in the Vendor Operator's Manual, and the applicable information will be contained in plant that necessary channel checks, procedures. Operator performance tests will be performed periodically as recommended by the vendor.

functional tests, periodic calibration, and maintenance will be conducted for the Channel functional tests with limits established in consideration of vendor equipment specifications will be performed at level measurement system and its appropriate frequencies.

supporting equipment.

Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications are planned to be performed at frequencies established in consideration of vendor recommendations.

b) A description of how the guidance in NEI NextEra Response Question 14b 12-02 section 4.3 regarding compensatory actions for one or both non-functioning Both primary and backup SFPI channels incorporate permanent installations (with no reliance on portable, post-event channels will be addressed. installation) of relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) will be out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:

TCompensatory jInitiate

t Channel(s) Required Restoration Action action 1Implement actions in accordance with 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 Out-of-service 1 actions to restore channel to functional status within 90 days. (Note 1) 2Initiate action to restore at least one channel to FNote 2.

Implement actions in accordance with days.

Page 28 of 31

Question NO. NRC QUESTION* -L'*!:; ICENSEE RESPONSE '** ... , % "" ,:,:'"-,'.=::

IIfunctional status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . INote 2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .I Note 1: If channel restoration is not expected to be completed within 90 days initiate compensatory action.

Note 2: Initiate an evaluation in accordance with the corrective action program. The evaluation shall initiate compensatory actions to implement an alternate method of monitoring and schedule required actions for restoring the instrumentation channel(s) to functional status.

NextEra Response Question 14c See RAI-14.b response above.

15. Please provide a description of the in-situ NextEra Response Question 15 calibration process at the SEP location that will result in the channel calibration being maintained at its design accuracy. Westinghouse calibrationprocedure WNA-TP-O4709-GEN (Reference 25) describes the capabilities and provisions for periodic testing and calibrationof the SFPIS, including in-situ testing. Seabrook will utilize the methodology described in the Westinghouse calibrationprocedure for the functional check at the pooi side bracket.

The level displayed by the channels will be verified per the Seabrook administrativeand operating procedures, as recommended by Westinghouse vendor technical manual WNA-GO-OO127-GEN (Reference 24). If the level is not within the required accuracy (+/-3 in), a full range channel calibration will be performed.

Channel verifications will be performed on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months basis by comparing SEP level reading from indicators SF-L/-26 16, SF-L/-2617 and SF-LT7-2607. Channelmaintenance and/or channel calibration will be initiatedif the deviation between indicated level readings exceeds 3.0 inches between the new SFP/S indicators or 2.0 inches between the new SFPIS indicatorand the existing 1-SF-L/-2607 indicator. Channel maintenance and!/orchannel calibration will also be performed if the SFF/S indicator displays an off scale "Hi",;"Lo" or out of range reading

("0000') when spent fuel pool level is within the normal operatingband (24. 81 to 25.23 Ft above the fuel racks).

Page 29 of 3l

' ~~References *' :

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) NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012.

5) ML13217A166, NRC Electronic Mail to NextEra Energy Seabrook, LLC, "Draft Requests for Additional Information Regarding the Seabrook Overall Integrated Plan for Reliable SFP Instrumentation, dated July 18, 2013.

6) MLI13267A388, Seabrook Station, Unit 1 - "Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0837)," dated December 4, 2013.

7) ML13063A438, NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 22, 2013.

8) ML13063A439, NextEra Energy Seabrook, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ), dated February 26, 2013.

9) ML12311A012, NextEra Energy Seabrook Letter, SBK-L-1 2211, Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 26,2012.

10) ML13247A177, NextEra Energy Seabrook, LLC, First Six Month Status Report for the Implementation of Order EA-1 2-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation , dated August 28, 2013.

11) ML14064A189, NextEra Seabrook, LLC, Second Six-Month Status Report I Responese to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 27, 2014.

12) ML14246A192, NextEra Energy Seabrook, LLC's 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 24, 2014.

13) Seabrook Calculation (FP 700488), Spent Fuel Pool Instrumentation System Dose Assessment.

14) Westinghouse Calculation CN-PEUS-1 4-16, Seismic Analysis of the SFP Mounting Bracket at Seabrook Station Unit 1, Revision 0.

15) Engineering Change Package 281849 - SPENT FUEL POOL INSTRUMENTATION UPGRADE FOR NRC ORDER EA-1 2-051.

16) Seabrook UFSAR Sections 1.2, 1.8, 3.1, 3.4, 3.5, 3.9 (B), 3.9 (N), 3.10 (B), 3.11, 6.1 (B), 6.1 (N), 6.5, 6.6, 7.1, 7.4, 8.1, 8.3, 9.1, 9.2, 12.2, 12.3, 12.4, 14.2 and 15.7.

17) Westinghouse Proprietary Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy," Revision 3.

18) Westinghouse Proprietary Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation," Revision 5.

19) Westinghouse Proprietary Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report," Revision 1.

20) Westinghouse Proprietary Document, WNA-DC-00269-FPL, "Spent Fuel Pool Instrumentation System Compliance Matrix - FPL/NextEra -Seabrook Unit 1," Revision 1.

21) Westinghouse Proprietary Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Procedure," Revision 2.

22) Westinghouse Proprietary Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis," Revision 1.

23) Westinghouse Proprietary Document, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation," Revision 1.

24) Westinghouse Proprietary Document, WNA-GO-001 27-GEN, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual," Revision 3.

25) Westinghouse Proprietary Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure," Revision 4.

Page 30 of 31

References:

26) Westinghouse Proprietary Document, wNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis," Revision 4.

27) Westinghouse Proprietary Document, LTR-EQ-1 4-1 63, "Interim Position for Radiation Aging of the Spent Fuel Pool Instrumentation System"

28) Westinghouse Proprietary Document, LTR-SFPIS-1 3-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronics Enclosure Used for Seismic Testing," Revision 1.

29) 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.

30) Westinghouse Proprietary Document, LTR-CDME-1 3-78 Rev 1, "Concentration of Boric Acid in the Watts Bar Spent Fuel Pool Due to Boiling and Its Effect on Level Instrumentation Cables."

31) Westinghouse Proprietary Report, EQLR-281, Revision 1, "Seismic Design Verification Test Report for the Spent Fuel .Pool Instrumentation System," September 2014.

32) Westinghouse Proprietary Letter, LTR-EQ-14-26, Revision 0, "Static Pull Test for Spent Fuel Pool Instrumentation System Connector," February 6, 2014.

33) Westinghouse Proprietary Document, EQ-EV-1 96, Revision 1, "Preconditioning, Thermal Aging and Radiation Aging of the Coaxial Signal Cables and Couplers for the Spent Fuel Pool Instrumentation System," August 2014.

34) Westinghouse Proprietary Document, WNA-DS-02957-GEN, Revision 4, "Spent Fuel Pool Instrumentation System Design Specification," May 2014.

35) LTR-SPFIS-13-027, Rev 0, "Radial and Pasternack Coax Cable Connector Documentation and Comparison", Westinghouse Electric Company, LLC.

36) Seabrook Calculation C-S-i -24606, "Spent Fuel Pool Level for Reliable Pump Suction," Revision 00

37) Seabrook Specification S-S-I -E-0227, "Spent fuel Pool Instrumentation System," Revision 002.

38) Drawing 1-NHY-300219, "Seabrook Service Environment Chart"

39) Calculation C-S-1-84616, "Power Uprate Spent Fuel Pool Cooling System Analysis," Revision 1.

40) Seabrook Design Basis Document DBD-SF-01, "Spent Fuel Pool Facilities and Spent Fuel pool Cooling, Purification and Cleanup System, " Revision 1. (Applicable Pages Attached)

Page 31 of 31

Enclosure 1 to SBK-L-15138 Spent Fuel Pool Levels Elevation View

ENCLOSURE 1 S;EABROOK SPENT FUEL POOL LEVELS ELEVATION VIEW

---.,--TO LEVEL TRANSMITTER OPEATING FLOOR EL. 25'-0" 1 -- *: f l INSTRUMENT NORMAL WATER LEVEL EL. 23'-4" 10 23'-9' -

BAND 12"

.- RELIABLE SUCTION LEVEL EL. 23'-4" .T t,--- . .. .. LEVEL I

~LOSS

~TOP OF NPSH 9 212° F EL. 22'-4" OF STRAINER '.EL. 21'-8"

-- SUCTION TECHNICAL SPECIFICATION LIMITEL. 2-1'1,/ 2 =

2 STRAINER

LEVEL FOR SUBSTANTIAL RADIATION SHIELDING EL. 10'-9'/" "-'- -- LEVEL2 of 2

IN.

o22NPSH-11.2F1 ~~LEVEL WHERE FUEL REMAINS COVERED EL. (-)0'-6'" - -- LEVEL 3 3

=rn INSTUMN

,= TOP OF FUEL RACK EL. (-) 1'-.5Y/4" SENSITIVITY BAND 4-"

NZ~U~Mfl~E

+/-

AVWK Page Ni4V o

""-DOTTOM OF SFP EL. (-) 15'-11 [/2"

--.: :-S 1,

,°-oo-ACCURACY

o.- *:_o NOMINAL

. o- - v -

NOTFS:ARE SCALE ELEVATIONS NOTFS~ TO I.ALL 1.ALL ELEVATIONS NOTARENOMINAL 2.TRANSMII-I"ER 2.NOT TO SCALE LEVEL 3.

3. LEVEL TRANSMI1TER ACCURACY +/-3 IN.

Enclosure Enclosure 1, Page 2 of 2 IM ~ 5~IMPI IFIFfl IIFP dn,', RIII9AIR ~fl~(1Q PM

Enclosure 2 to SBK-L- 1513 8 Summary of Westinghouse Silent Fuel Pool Instrumentation Design Reouirements

ENCLOSURE -2 PaamteTopichos Paraeter Westnghuse Rfeene efernceTest Additional Comment or Licensee Evaluation TpcSummary Document Number Analysis Results Design SFPIS WNA-DS-02957-GEN Contains technical N/A The design and implementation requirements as defined in Table 2 references 1, 2 and 3 Specification Requirements SFPIS requirements are bounded by the design Westinghouse Design Specification for the SEPIS (WINA-derived from based on NRC order, DS-02957-GEN).

References 1, 2, NEI guidance.

2 Test Strategy Per WNA-PT-00 188-GEN Strategy for perfonning N/A The SFPIS qualification test strategy as described in WNA-PT-001 88-GEN envelopes Requirements. the testing and the Seabrook specific environmental and seismic design requirements. Refer to verification of the Seabrook Specification S-S-E-0227, Spent Fuel Pool Instrumentation System.

SFPIS and pool-side bracket.

3 Environmental 500 F to 1400 EQ-QR-269 and WNA- Results are summarized Test passed For Seabrook specific temperature and humidity requirements the electronic enclosures qualification F, TR-03 149-GEN for all in EQ-QR-269 and conditions tbat will be located in the Containment Enclosure Building and Control Building for electronics 0 to 95% RH conditions. WNA-TR-03 149-GEN. described. Essential Switchgear Rooms are enveloped by the Westinghouse qualification for enclosure with RdainAngnormal and BDBE conditions.

Display TID < 1E03 R 7RaitoAgn normal (outside verification As described in Westinghouse Report WNA-TR-03 149-GEN, radiation is not SFP area) summarized in Section considered to be an aging mechanism for equipment that is only subjected to TID < 1E4 5 of WNA-TR-03 149- rads. TID to equipment located in the Containment Enclosure Building and Control TID < 1E03 R 7 GEN. Building Essential Switchgear Rooms will be less than 1E3 rads for normal and BDBE abnormal conditions. Refer to Seabrook Specification S-S-E-0227, Spent Fuel Pool (outside SFP Instrumentation System.

area) Westinghouse has provided an interim position regarding the radiation aging qualification and the open item from Steris (ref. Response to Table 2, NRC Question 7). NextEra Energy is tracking closure of the open item and will provide additional update if Westinghouse's position changes.

Page 1 of 8

ENCLOSURE -2 Parameter Westinghouse Reference Additional Comment Anaysst Lieseorluto Topic Summary Document Number Aayi ieseEauto Results 4 50 0oF to 212 0 Thermal aging test Passed The temperature and humidity values of 212°F and 100% envelop the service Environmental EQ-QR-269 results summarized in Testing for F and 100% enviromnent requirements for the SEP1S components that will be located in the SEP EQ-QR-269 Section Level Sensor humidity area. Refer to Seabrook Specification S-S-E-0227, Spent Fuel Pool Instrumentation 5.2.

components in System.

Steam test results SFP area-summarized in EQ-QR-Saturated 269 Section 5.7.

Steam &

Radiation 1E03 R y WNA-TR-03 149-GEN and Thermal Aging & Passed The normal operating dose in the SEP area per is < 1.E03 R 'y. Refer to Seabrook normal (SEP EQ-QR-269 radiation aging Specification S-S-E-0227, Spent Fuel Pool Instrnnentation System.

area) verification are summarized in Sections 4.1 and 5 (entire system) of WNA-TR-03 149-GEN lE07 R EQ-QR-269 Radiation aging Passed The BDBE radiation value to which the Westinghouse equipment was qualified is BDIBE (SEP program was conducted 1.E+9 R 'y for the probe stainless steel cable and weight and 1E+7R 'yfor the equipment area) in accordance with on the Operating deck above the pool (Ref. Section 5.1.2 of WNA-TR-03149-GEN).

procedures EQ-TP-326 With SEP water level at Level 3 the only components of SFPI that are exposed to the and EQ-TP-3 54. SEP are the stainless steel probe and the stainless steel anchor. Since stainless steel is inherently resistant to degradation from radiation the probe and anchor, environmental Radiation aging results testing of these components was not required. Equipment located above the SEP are summarized in EQ- (Coaxial cable, coupler and connector) were aged to lE+I 1 R 'yto assure qualification QR-269 Section 5.3. to 1E+7 R y. Westinghouse completed its aging qualification of the SEPIS to 10 years.

Westinghouse has provided an interim position regarding the radiation aging qualification and the open item from Steris (ref. Response to Table 2, NRC Question 7).

NextEra Energy is tracking closure of the open item and will provide additional update if Westinghouse's position changes.

Page 2 of 8

ENCLOSURE - 2 Parameter Westinghouse Reference Test or

Topic Summary Document Number Additional Comment Analysis Licensee Evaluation Results 5 Environmental 500 F to 1400 WNA-TR-03 149-GEN and Testing summarized rn Passed Temperature is < 140°F and humidity is < 95% RH- for abnoranal conditions in the Testing for F, EQ-QR-269 WNA-TR-03 149-GEN, Contaimnent Enclosure Building and Control Building Essential Switchgear Rooms.

Level ensorSection 3.3.

Elc0nc Oto 95% RH Radiation Aging As described in Westinghouse Report WNA-TR-03 149-GEN, radiation is not Housing - verification considered to be an aging mechanism for equipment that is only subjected to TID < 1E4 summarized in WNA- rads. TID to equipment located in the Contaimnent Enclosure Building and Control outside SFP TED < 1E03 R 3' TR-03 149-GEN, Building Essential Switchgear Rooms will be less than 1E3 rads for nornal and BDBE normal (outside Section 5. conditions. Refer to Seabrook Specification S-S-1-E-0227, Spent Fuel Pool SFP area) Thermal aging test Instrumentation System TID*<1E03 R results summarized in abnormal EQ-QR-269 Section (outside SEP 5.2.

area) Steam test results summarized in EQ-QR-269 Section 5.7 6 Thermal & 1E03 R y EQ-QR-269 and WNA- Thermal aging test Passed See response to Item 4 above.

Radiation normal (SEP TR-03 149-GENreutsmaredi Aging - area) EQ-QR-269 Section Aging Tests - Westinghouse completed aging qualification of SFPIS to 10 years.

oraic1.2R.Rdito aigrslsWestinghouse has provided an interim position regarding the radiation aging cmoneantsc BDE07R3 aito gn eut qualification and the open item from Steris (ref. Response to Table 2, NRC Question 7).

SEP area (SPaesmaie nE-NextEra Energy is tracking closure of the open item and will provide additional update area) QR-269 Section 5.3 if Westinghouse's position changes.

Thermal Aging &

radiation aging verification summarized in Sections 4.1 and 5 of WNA-TR-03 149-GEN.

Page 3 of 8

ENCLOSURE -2 Parameter Westinghouse Reference Test or Topic Summary Document Number Additional Comment Analysis Licensee Evaluation Results 7 Basis for Dose Normal LTR-SFPIS-13-35 and Westinghouse Basis for Passed for NextEra has determined the Westinghouse basis is acceptable.

Rqreet Cniin: WNA-DS-02957-GEN Raito oealThe normal operating dose in the SFP area is <lE+3 R y, which is bounding for 1E03 R y TID Requirement conditions Seabrook. Refer to Section 5.1.1 of WNA-TR-03 149-GEN and Seabrook specification (above pool) S-S-1-E--0227, Spent Fuel Pool Instrumentation System.

1E09 R'yTID Equipment located above the SFP (Coaxial cable, coupler and connector) were aged to (1' above fuel 1E+I 1 R 'yto assure qualification to 1E+7 R 'y. The as tested test BDBE condition (TID rack) of 1E+I 1 R 'y) above bounds the Seabrook requirement of 1.06E+7 R 'y BDBE Conditions:

1E07 Ry TID (above pool)

<1E09 R yTID (1' above fuel rack) 8 Seismic Per Spectra in EQ-QR-269 EQ-QR-269 Passed The TRS that was used by Westinghouse for seismic qualification of the SEPIS, Qualification WNA-DS- summarizes the results including the poolside mounting brackets, envelops the Seabrook RSS.

02957-GEN of seismic testing that was perfonned by Westinghouse.

WNA-TR-03 149-GEN WNA-TR-03 149-GEN Passed provides high level summary of the pool-side bracket analysis and equipment seismic test program.

Page 4 of 8

ENCLOSURE -2 Topicos Paamte Paraeter efernceTest Additional Comment Westnghuse Rfeene or Licensee Evaluation TpcSummary Document Number Analysis Results EQ-TP-3 53 (procedure) Seismic Pull test for Passed straight and 90 degree coaxial connectors was performed in accordance with Westinghouse procedure EQ-TP-3 53.

9 Sloshing N/A LTR-SEE-II-l3-47 and Caclto oPassed Adequate sloshing forces (inclusive of vertical and horizontal impact forces, WNA-TR-03 149-GEN. demonstrate that probe hydrodynamaic forces) were considered by Westinghouse in the calculation for sloshing willnot slshedoutforces.

e The calculated forces were also considered by Westinghouse in the design the of the SFP. bracket, including anchorage requirements, to ensure the probe will not be degraded or Sloshng isalsosloshed out of the SFP during a seismic event.

addressed in Section 7.2 of WNA-TR-03 149-GEN.

10 Spent Fuel Acceptance WNA-TP-0461 3-GEN and Test plan and procedure Passed The monitoring requirements from Westinghouse procedures WNA-TP-046 13-GEN Pool Criteria for used to demonstrate and WNA-TP-001 89-GEN assure SFPIS performance in accordance with requirements WNA-TP-00 189-GEN Instrumenta- Performance that SFPIS meet its of Table 2 reference 1, 2 and 3.

tion System during EQ operational and Functionality testing accuracy requirements Test Procedure during Equipment Qualification Testing.

11 Boron Build- Per requirement WN-TR-03 149-GEN, Boron build up Passed Boron buildup testing and justification provided in WNA-TP-001 89-GEN "Integrated Up in 'WNA-DS- LTR-CDME-13-78A and demonstrated through Functional Test Plan" assure SFPIS performance in accordance with the requirements 02957-GEN LTR-SFPIS-13-026 Integrated Functional of Table 2 reference 1, 2 and 3 Test (IFT).

Page 5 of 8

ENCLOSURE - 2 Westnghuse efernceTest Paraeter or

aamteTopichos Rfeene Additional Comment Licensee Evaluation

TpcSummary Document Number Analysis Results 12 Pool-side N/A CN-PEUS-14-16 Analysis included Passed See response to NRC Question. 4. Seabrook seismic requirements to withstand a SSE Bracket seismic forces and are bounded by the Westinghouse analysis for the poolside mounting bracket.

Seismic hydrodynamic forces, Equipment anchorage will be designed by Seabrook to meet the calculated Analysis as appropriate. Westinghouse loads (tension and shear loads, and hydrodynamic load) with appropriated safety margin.

13 Additional N/A WNA-DS-02957-GEN Weights provided to N/A Equipment anchorage will be designed by Seabrook to meet the calculated Brackets licensees for their own Westinghouse loads (tension and shear loads, and hydrodynamic load) with (Sensor evaluation, appropriated safety margin.

Electronics and Electronics Enclosure) 14 Shock & WNA-DS- WNA-TR-03 149-GEN WNA-TR-03 149-GEN, N/A Westinghouse SFP measurement channels will be permanently installed and fixed to Vibration 02957-GEN Section 7 provides rigid, structural walls or floors of Seismic Category 1 structures.

justification for shock and vibration.

Page 6 of 8

ENCLOSURE - 2 Parameter Westinghouse Reference AdiinlCme t estese Eaorto

Topic Summary Document Number AdiinlCm et Analysis LieseEauto Results 15 Westinghouse Integrated WNA-TP-04752-GEN, The Integrated passed SFPIS functional testing and post modification testing in accordance with Engineering Factory Functional Test WNA-TR-03357-WEP, Functional Test Change 281849 assure SFPIS perfonnaance in accordance with the requirements of Acceptance Requirements WNA-TR-03351-GPRY1 demonstrated Table 2 references 1, 2 and 3.

Test, including from WNA-DS- functionality of the full dead zone 02957-GEN. system, which included verification., 2 edzn calibration of each at top of probe channel.

4"atDead-zone ded-zoe tests are botto of robedescribed in WNA-TP-botto of robe04752-GEN, Section 9.6.2.

16 Channel +1-3 inches per WNA-CN-00301-GEN Channel accuracy from Passed Seabrook has reviewed WNA-DS-02957-GEN and WNA-CN-00301-GEN and found Accuracy WNA-DS- measurement to that channel accuracy requirements are met.

02957-GEN display.

17 Power 3 day battery WNA-CN-00300-GEN N/A Passed Seabrook has reviewed WNA-CN-00300-GEN and concluded that the SFPIS battery Consumption life (minimum) has a capacity that is > 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months which meets the Order requirements. The SFPIS power SFPISpowerloading does not challenge the plant electrical distribution system or Emergency Diesel SFPIumptowe Generator loading.

18 Technical N/A WNA-GO-00127-GEN Information and N/A Seabrook will utilize WNA-GO-00127-GEN as input for procedure preparation and Manual instructions for system maintenance.

Operation, Installation, use, etc. are included here.

Page 7 of 8

ENCLOSURE - 2 Paamte esinhos RfeeneTest or

aamteTopichos Rfeene Additional Comment Licensee Evaluation

TpcSummary Document Number *Analysis Results 19 Calibration Routine WNA-TP-04709-GEN Includes preventative N/A Seabrook will utilize WNA-TP-04709-GEN as input for development of plant Testing/calibrati maintenance actions procedures for calibration and preventive maintenance of the SFPIS.

on verification such as those for Boron and Calibration buildup and cable probe method inspection.

20 Failure Modes N/A WNA-AR-00377-GEN Addresses mitigations N/A Seabrook will utilize WNA-AR-00377-GEN as input for procedure preparation and and Effects for the potential failure system troubleshooting if required.

Analysis modes of the system.

(FMEA) 21 EMI/ RFI RG 1.180, Rev. WNA-TR-03 149-GEN and N/A Passed to Refer to the response to Table 2, NRC Question 7. NextEra has reviewed the test report Qualification 1 test conditions EQ-QR-269 perfor- and concluded that the results comply with the requirements performance criterion B.

Testing mance criterion B Page 8 of 8

Enclosure 3 to SBK-L- 15138 Plan Views of Instrument Channel Arrangement

ENCLOSURE 3 sFP CONTAINMENT 5SSI*N r [AL 8UILOhiNG LUDIING UP"S,$*EMOTE tN01CA for PI(NOIIT ---1r

- t -~ -

W(~TEfl LI POOL SIMPLIFJIED SEP LEVEiL MONIJTORIN G ClIA NN El.. $KETCIH JIlM S'* .SIMFi".Ir:I[it) -SI 1'.c*n *-/I 2120 1I 2.;7: 10 M .......

)NC:LOSURIE 3, PACBE P*Ojo 2 o! 6 Page 1 of 5

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ENCLOSURE 3

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Page 4 of 5

ENCLOSURE .3 SPENT FUEL POOL LEVEL SENSOR LOCATION DIAGRAM 0 SPENT FUEL POOL 4i

--I -- 1 4

< a* < . 4 . . 4 LOCATION PLAN NOTE 44; S SEABROOK ARE MODIFICATIONS CONSERVATIVELY TO THE CLASSIFIED POOL AS SIDE CLASS SAFETY BRACKET3, SEISMIC CATEGORY I TO ENSURE PROPER QUALITY OF MATERIAL AND WORKMANSHIP FOR THIS APPLICATION.

AFFECTED DOC'S: 101570. 101571, 111572

REFERENCE:

102200. 102203. ECA99/113212 NOTES:

1. THE SFP THE EXISITNG UNDERWATER CURB ANGLE 1--SF--LE-2616, LIGHT ASSEMBLY PER EC14371 IS TO BE ABNDONED BRACKET.

AND LOCATED WELDED ADJACENT TO TO IN PLACE AND A NEW BRACKET NEXTeraT...

ENER.(

IZ14 BLOG3/ELEV - FSB/25'--0" 2.

WILL BE INSTALLED BY EC281537.

THE PROBE CENTERLINE.

A MINIMUM OF 3 --0" NORTH OF REFERENCE SK 111576--EC281849 SHEET 2.

SEE EC281537 FOR DETAILS SPECIFIC TO THE RELOCATION OF THE LIGHT ASSEMBLY.

EXISTING H4ANDRAIL ANCHOR PLATE TO BE REMOVED.. HILTI'S ARE SAFETY CLASS SEISMIC CAT.

PREP/DATE"_'*--------

t*

I

,N/Q (NOE ÷

-- 7//-.

jLEVE TITLE SPENT FUEL INSTRUMENT POOL 1 -SF-E-261 6 &, 261 7 TO BE LEFT IN PLACE AND REUSED FOR NEW INSTRUMENT PLATE.

CHI<I/OATE * .. *'*f .- IC NO. 101 570-EC281 849 I REV o ENCLOSURE 3, PAGE Page 6 of 6 Page 5 of 5

Enclosure 4 to SBK-L-15 138 Pool Side Bracket Design and Seismic Recjuirements

FNC OSIJRF 4

JEA£CJ. _.O_.JRF 4 PAGE _oLf Page 1 of 5

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... .... .. . .. = I NOlTE .*: ;*.ACICIDDE MOtO" ICATCOT.5 TO 1iRE iPOOL 511)1* CIRACKIET ARE[ CBNII.II4VATIVE.Y *[AS-SIFI'ED AS SAFETY CL.ASS .. '

SEISMIC CA'IEGOC4Y I TO ENSIICE* PICIW*ER OUIALITY or MA*TERIHAL AND WOHEKMAtNSIClP I I( JIlIS A.PPL ICAT ION.

C 1YP) r I'Ico ~ Is .II IIIu O/ LIV "

_ -- SAI LTY ILie:.,t;,L*{* SPCNT FUJEL POOL DIN PtO'1"Ih41 SEI;1MIC co*,..*" LEVE*L INSTRUMENT 4C.t. .'J N 8 -f ENCLOSURE 4. PAGE PBae 4 of 6 Page 3 of 5

JENCLO+$URE.4t SFPIS OBE and SSE Test Response Spectrum (TRS) 5% Critical Damping vs SFP Req uired Response

Spectra (RRS) oo .* ~ t .......

__ ... _ ..L .[.'... ...L* ..

RhiFI*R TO THI4I*,XT PAGE FOR R*'

EN.CLOSU R E+4*AOEr13ae.5orG Page 4 of 5

ENGLOS.UREA4 O *EOpor~llnll I1,,.I.k I .IsrlhUtikR(. T*$l RconsO*S :pe,*:rur, 5% darnplnll Ill; - ar* ShtldnIwnI ri~tr¶?iqili~k( T(Ist flIspolvs*.* Ell.*.f'urll., 1 (laIl1pIhlIl rlI-133, Fuel .;Irap, IuIl*ldllt% AIII. 14orh7onltBI, N-S, OBE 4%PdIllmplfIR Ff14.34, Fue&4Stoidgeg hufldinlf1 AIlS, FIolizontllt, I -W, 0111I 4% dasrlphln 111-2'I,6, rtwl* Suwrag' lifludfng ARlS, I hrjioulhl. l*-S, 3,E 14%, d.'snahlng l(E-]TJ, Fuel Storag~e tiuhlhdle ARS, ItorI~onI1l. N-S. 551 4%/ danlping GR-003, Ground Ruesl~olsun Specfrrii Verlical, 081*,4% d~linllIngl 611-00)4, Groupid Rospoliso, Sllqcr~llr Vnr/tlcnl, 55.*S*4%* slnmping Thu1,eI lei,*'l fl.,,louB.,, lp*.*uIf (S"1"O)¢unedtnl Iu f ejiuu 4 .4.) e nd 4 44'

Wn~trhu=i=,s I~lloI EQO.'JI(4'C6i nue ,.Or.,pnn lOl, fle elunlo(k *o*o .r*unol*,.lnlqloI *nolpu., .eo,),.. [lltll) ,,.l ENCLOS8UAE._Al.*G E. o~oj0.of Page 5 of 5 to SBK-L- 15138 1-NHIY-3 10002

ENCLOSURE 5 12 11 10 9 8 7 8 5 4 3 2

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.3=4.3.3 3 3 534343.3633.43033043 L~3AZ 33.J ENIT 1 1-NAT- 310002 12 11 18 9 8 7 A 5 4 3 2 Page 1 of 1 to SBK-L-15138 Service Enviromnment Chart 1-NHY-300219

SERVICE ENVIRONMENT CHART Document No.: 1-NHY-300219, Revision No.: 28 Page: 44 of 542 EQ ZONE CB-6A (CONTROL BUILDING, TRAIN A SWIITCHGEAR ROOM A EL. 21'-6")

NORMAL Notes} ABNORMAL Notes! .PARAMETER EVENT DESIGN BASIS EVENT Notes!

CONDITIONS Ref. CONDITIONS Ref. CONDITIONS Ref.

55 to 104 Ri, R2 104 N5, Ri Peak Temperature HEBNAN/A MELB N/AN/A 0 to ATM (+) R3 0 to ATM (+) N2 Peak Pressure HELB N/ANA (psig)

MELB N/A N/A LOCA ATM (+) R 3 to 60 3 to 60 N2 Maximum Relative N6 R3 Humidity MELB N/ANA

()LOCA 60 R N/A N/A N/A N/A Water Spray HELB N/AN/

N/A N/A N/A N/A LOCA 8760 Hours (1 Year) R4 Integrated Dose (rads)N/

28-0 N3 28-0 N2 Maximum Dose Rate, y LOCA N/A N/A 2.86-03 3 2.6E-0 N2(r/hr) 1.50E+03 1.50E+03 N2 LOCA 8760 Hours (1 Year) R4 N4 Integrated y Dose R5 (rads) Negligible N/A NA N/ N/A Maximum Flood Height MELB /AR (Ft. above floor) HELB

References:

Notes:

Ri. Calculation. 6.01 .42.01 R2. Calculation 6.01 .42.02. R3. Calculation 6.01.42.08 R4. Calculation C-S-i1-28007 R5. Calculation C-S-1-380i7 R6. TP-7, MELB Study R7. Calculation MS-MISC-32 Ni. ATM represents atmospheric pressure. Areas where the normal pressure is slightly negative or positive are identified as ATM (-)or ATM (+).

N2. The normal environmental parameter is unchanged during the abnormal or design basis event. N3. Dose rate is the value calculated by dividing the 60 year integrated normal dose by (60* 8760). N4. The total integrated dose is for 60 years.

N5. Abnormal event is result of loss of offsite power from 100% power conditions. Event duration is for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and occurs once over plant operating life.

Nfl.Humidity may reach 95% during plant shutdown conditions ( Reference 7).

Page 1 of 6

SERVICE ENVIRONMENT CHART Document No.: 1-NH-Y-3 00219, Revision No.: 28 Page: 46 of 542 EQ ZONE CB-6A- Temperature Profile Data Table Post-LOCA Heat Up (Calculation 6.01.42.01)

Notes:

1. This Zone is provided with safety-related ventilation.

Page 2 of 6

SERVICE ENVIRONMENT CHART Document No.: 1-NHY-300219, Revision No.: 28 Page: 47 of 542 EQ ZONE CB-6B (CONTROL BUILDING, TRAIN B SWITCHGEAR ROOM A EL. 21'-6")

NORMAL Notes/ ABNORMAL Notes/ PARAMETER EVENT DESIGN BASIS EVENT Notesi CONDITIONS Ref. CONDITIONS Ref. CONDITIONS Ref.

55t1 02 14 N,1 Peak Temperature HELB N/A N/A (oF)

MELD N/A N/A LOCA 104 Ri 0 to ATM (+) R3 0 toATM (+) N2 Peak Pressure HELD N/A N/A (psig)

MELB N/A N/A LOCA ATM (+) R3 HELB N/A N/A 3 to 60 3 to 60 N2 Maximum Relative N6 Humidity MELB N/A N/A R3()LOCA 60 R3 N/A N/A N/A N/A Water Spray HELD N/A N/A N/A N/A N/A N/A LOCA 8760 Hours (1 Year) R4 Integrated 13Dose (rads) N/A 2.86E-03 N3 2.86E-03 N2 Maximum Dose Rate, y LOCA N/A N/A (r/hr) 1.50E+03 1.50E+03 N2 LOCA 8760 Hours (1 Year) R4 N4 Integrated y Dose R5 (ads)Negligible N/A NA N/ N/A Maximum Flood Height MELB NAR N/

NA N/ NA (Ft. above floor) HELDB/AR

References:

Notes:

Ri. Calculation 6.01,.42.01 R2. Calculation 6.01.42.02. R3. Calculation 6.01.42.08 R4. Calculation C-S-1-28007 R5. Calculation C-S-i-38017 R6. TP-7, MELB Study R7. Calculation MS-MISC-32 Ni. ATM represents atmospheric pressure. Areas where the normal pressure is slightly negative or positive are identified as ATM (-)or ATM (+).

N2. The normal environmental parameter is unchanged during the abnormal or design basis event. N3. Dose rate is the value calculated by dividing the 60 year integrated normal dose by (60" 8760). N4. The total integrated dose is for 60 years.

N5. Abnormal event is result of loss of offsite power from 100% power conditions. Event duration is for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and occurs once over plant operating life.

N6. Humidity may reach 95% during plant shutdown conditions (Reference 7).

Page 3 of 6

SERVICE ENVIRONMENT CHART Document No.: 1-NHY-300219 Revision No.: 28 Page: 49 of 542 EQ ZONE CB-6B -. Temperature Profile Data Table Post-LOCA Heat Up (Calculation 6.01.42.01)

Time (Sec) Temperature

__________ e F) 0.1 104 31536000 j 104 Notes:

1. This Zone is provided with safety-related ventilation.

SERVICE ENVIRONMENT CHART Page 4 of 6

Document No.: 1-NIIY-300219, Revision No.: 28 Page: 68 of 542 EQ ZONE CE-i (EQUIPMENT VAULT, CONTAINMENT ENCLOSURE FAN AREAEL. 21'-0")

NORMAL Notes/ ABNORMAL Notes/lAAEE VN DESIGN BASIS EVENT Notes/

CONDITIONS Ref. CONDITIONS Ref. PRMTRENTCONDITIONS Ref.

50 to 104 Ri 98 NS Peak Temperature HEB18R R4 (oF) MELB 150 R7 LOCA 154 N RB AT1 -2HELB 0.35 RS ATM (-) ATMPeak)PNissN2 NIPa rsue MELS 1.0 R7 R2 (psig)

LOCA (-)0.009 R2 HELB 100 RS 3 to 60 3 to 60 N2 Maximum Relative____

N6 R2 Humidity MELB 100 R7

()LOCA 18 R2 N/A N/A N/A N/A Water Spray HELE N/A N/A N/A N/A N/A N/A LOCA 8760 Hours (1 Year) RB Integrated 13Dose (reds) N/A 2.86E-03 N3 2.86E-03 N2 Maximum Dose Rate, y' LOCA N/A N/A (rlhr) 1.50E+03 1.50E+03 N2 LOCA 8760 Hours (1 Year) R8 N4 Integrated y Dose R3 (reds) 4.30E+06 Maximum Flood Height MELB NB NA NA NA (Ft. above floor) HELB 05R9

References:

RI. Calculation 6.01.53.07 R2. Calculation 6.01.53.13 R3. Calculation C-S-1-38017 R4, 86DCR724 RS. UE&C Report 9763-006-S-N-2 & Calculation 4.3.35.3F RB. MSVCS-FAG-16 R7. Calculation 9763-F-CP-05 RB. Calculation C-S-1-2B007 R9. TP-7, MELB Study Ri0. Calculation MS-MISC-32 Rl1. Structural Drawing No. 9763- F-l0i6i9 Notes:

Ni. ATM represents atmospheric pressure. Areas where the normal pressure is slightly negative or positive are identified as ATM (-)orATM(+).

N2. The normal environmental parameter is unchanged during the abnormal or design basis event. N3. Dose rate is the value calculated by dividing the 60 year integrated normal dose by (60* 6760).

N4. The total integrated dose is for 60 years.

NS. Abnormal event is result of loss of offsite power from 100% power conditions. Event duration is for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and occurs once over plant operating life.

N6. Humidity may reach 95% during plant shutdown conditions (Reference 10).

N7. Maximum space temperature with a maximum PCCW temperature of 126°F.

NB. The 6 inch flood height is because there is a 6 inch curb around the door at the north end at El. 21'-6" that prevents water from entering the stairwell that descends to the electrical and l&C equipment room at the south end of the east Main Steam and Feedwater Pipe Chase (Reference 9, Section 4*8.1 and Reference 11).

Page 5 of 6

SERVICE ENVIRONMENT CHART Document No.: 1-NIHY-300219, Revision No.: 28 Page: 70 of 542 EQ ZONE CE-i -Temperature Profile Data Table Composite HELB (UE&C Composite MELB Report 9763-006-S-N-2 (SBU-95078 & Post-LOCA Heat Up

& Calculation 4.3.3 5.3F) Calculation 9763-F-CP-05) (Calculation MSVCS-FAG- 16)

TemperatureTeprtrTmeaue Time (Sec) (oF) Time (Sec) Teprtr(oF) Time (Sec) TeprtrC0F) 0.1 104 0.1 104 0.1 104 90 108 1 150 1800 154 200 104 7201 150 261000 154 31536000 104 134641 104 520000 104 31536000 104 31536000 104 Notes:

1. PLHU profile divisions based on AR 00211544 response memo that seemed to imply 30 minute ramp up and 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ramp down after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months at peak.

2. Original MELB duration from 150 0 F to 104°F was 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months in SBU-95078. However, due to a math error in Attachment 1, the duration is actually 35.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

3. This Zone is provided with safety-related ventilation.

Page 6 of 6

v t e Letter Sequence Other
TAC:MF0837, (Approved, Closed)
Initiation Request Acceptance Administration Questions 4 December 2013 Answers Results Approval Other: ML14049A197, ML15181A269, ML15278A200, SBK-L-12212, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049), SBK-L-13038, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), SBK-L-13039, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), SBK-L-13157, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, SBK-L-13158, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, SBK-L-14041, Second Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), SBK-L-14042, 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), SBK-L-14153, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), SBK-L-14154, Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No EA- 12-05 1), SBK-L-15025, NextEra Energy Seabrook, Llc'S Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-1, SBK-L-15026, NextEra Energy Seabrook, Llc'S Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), SBK-L-15137, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events..., SBK-L-15138, 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), SBK-L-16011, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
MONTHYEAR2014-08-26 [Table View]

SBK-L-15138, 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)

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