View source for BSEP 13-0073, Response to Request for Additional Information Regarding Overall Integrated Plan Submitted in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-

{{Adams
| number = ML13219B117
| issue date = 07/22/2013
| title = Response to Request for Additional Information Regarding Overall Integrated Plan Submitted in Response to the Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-0
| author name = Hamrick G
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324, 05000325
| license number = 
| contact person = 
| case reference number = BSEP 13-0073, EA-12-051
| document type = Letter type:BSEP
| page count = 11
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:DUKE                                                                              George  T.Hamrick Vice President
: 40) ENERGYe                                                                       Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.457.3698 10 CFR 50.4 July 22, 2013 Serial: BSEP 13-0073 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information Regarding Overall Integrated Plan Submitted in Response to the Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

==References:==
: 1. Letter from Benjamin Waldrep to the U.S. Nuclear Regulatory Commission (Serial:
RA-1 3-002), CarolinaPower & Light Company's Overall IntegratedPlansin Response to March 12, 2012, Commission Order Modifying Licenses With Regard to Requirements for Reliable Spent Fuel Pool Instrumentation(OrderNumber EA-12-051), dated February 28, 2013, ADAMS Accession Number MLI 3086A096
: 2. NRC Letter from E. J. Leeds to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, Issuance of Orderto Modify Licenses With Regard to Reliable Spent Fuel Pool Instrumentation,dated March 12, 2012, ADAMS Accession Number ML12054A679
: 3. NEI 12-02, Industry Guidance for Compliance with NRC OrderEA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"Revision 1, dated August 2012, Adams Accession Number ML12240A307
: 4. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with OrderEA-12-051, OrderModifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012, ADAMS Accession Number MLI12221A339
: 5. NRC Letter from Christopher Gratton (USNRC) to Michael J. Annacone (Carolina Power
            & Light Company), Request for Additional Information Regarding Overall Integrated Plan in Response to the Commission Order Modifying Licenses with Regard to Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated May 23, 2013, ADAMS Accession Number ML13141A622 Ladies and Gentlemen:
By letter dated February 28, 2013 (i.e., Reference 1), Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company (CP&L), submitted an Overall Integrated Plan in response to the March 12, 2012, Commission Order modifying licenses with regard to xomL

U.S. Nuclear Regulatory Commission Page 2 of 3 requirements for reliable Spent Fuel Pool (SFP) Instrumentation (i.e., Reference 2) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. Further, the staff endorsed NEI 12-02 (i.e., Reference 3), with exceptions, as documented in Interim Staff Guidance (i.e.,
Reference 4).
On May 23, 2013, (i.e., Reference 5), the NRC provided a request for additional information (RAI) concerning the referenced Overall Integrated Plan. In addition, for any part of the information that is not available within the 60-day response period for the RAI, the NRC asked BSEP to provide the date the information would be submitted. The response to the NRC request for additional information is enclosed.
This letter contains no regulatory commitments.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 457-2487.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on July 22, 2013.
Sincerely, George T. Hamrick PSF/psf

==Enclosure:==
Response to Request for Additional Information

U.S. Nuclear Regulatory Commission Page 3 of 3 cc (with enclosure):
U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U. S. Nuclear Regulatory Commission ATTN: Mr. Christopher Gratton (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Ms. Michelle P. Catts, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510

BSEP 13-0073 Enclosure Page 1 of 8 Response to Request for Additional Information By letter dated February 28, 2013, Duke Energy Progress, Inc., formerly known as Carolina Power & Light Company (CP&L) submitted an Overall Integrated Plan (OIP) in response to the March 12, 2012, Commission Order modifying licenses with regard to requirements for reliable spent fuel pool (SFP) Instrumentation for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. Further, the staff endorsed NEI 12-02, with exceptions, as documented in Interim Staff Guidance.
On May 23, 2013, the NRC provided a request for additional information (RAI) concerning the referenced Overall Integrated Plan. In addition, for any part of the information that is not available within the 60-day response period for the RAI, the NRC asked BSEP to provide the date the information would be submitted. Responses to the NRC questions are provided below.
NRC RAI-1 Provide responses to the following:
a) The specific functional reasons for identification of the elevations within the SFP as levels 1, 2, and 3. For level 1, specify how the identified location represents the HIGHER of the two points described in the NEI 12-02 guidance for this level.
b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3 as well as the top of the fuel. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.
BSEP Response to RAI-1 As a result of responding to RAI-1, errors were identified in the Level 1, 2, and 3 values provided in BSEP's February 28, 2013, OIP. The original Level 1 value did not account for the minimum SFP operating water level. The original Level 2 and Level 3 values were based on highest point of any fuel assembly versus fuel rack. The following table provides corrected values for these levels.
Original Value                              Corrected Value Level 1         37 feet 9 inches                            37 feet 6 inches (116 feet 4 inches plant elevation)         (116 feet 1 inches plant elevation)
Level 2          105 feet 7 % inches plant elevation        105 feet 3 inches plant elevation Level 3         95 feet 7 % inches plant elevation          95 feet 3 inches plant elevation The following response provides the functional bases for the corrected Level 1, 2, and 3 values with the requested elevation view sketch.

BSEP 13-0073 Enclosure Page 2 of 8 INSTRUMENT CHANNEL DESIGN OVERVIEW/ BACKGROUND The SFP water level instrumentation for BSEP, Unit Nos. 1 and 2, will consist of two permanently fixed instrument channels per pool. The spatially separated channels will be used to monitor the SFP water level over the continuous span from normal operating level down to the level of the highest point of any fuel rack.
Each instrument channel will utilize through-air (non-contact) wave radar technology, which has a wave guided pipe and receiving horn located in the SFP area. The wave guided pipe and receiving horn contain no organic materials and are not susceptible to radiation induced degradation. The associated channel electronics will be remotely located, away from the SFP, in each unit's respective reactor building. Each channel will have a back-up battery and shall provide main control room (MCR) level monitoring capability.
a) The flow path for fuel pool cooling and cleanup begins with the fuel pool. The fuel pool overflows to the skimmer surge tanks. The fuel pool cooling pumps take suction from the skimmer surge tanks and discharge to the heat exchangers. The effluent of the heat exchangers may be returned to the fuel pool or to the fuel pool filter-demineralizers in radwaste, or both.
Level 1 The minimum water level required in the skimmer surge tank, with an inlet temperature of 200 0 F, for the fuel pool cooling pumps to maintain their minimum net positive suction head (NPSH) is at plant elevation 94 feet.
Section 3.7.7 of BSEP's Technical Specifications states that the spent fuel storage pool water level shall be > 19 feet 11 inches (i.e., 115 feet 8 3/4 inches plant elevation) over the top of the irradiated assemblies seated in the spent fuel storage racks.
The normal operating SFP water level is 37 feet 9 inches from the bottom of the SFP (i.e., 116 feet 4 inches plant elevation).
Level 1, as defined in NEI 12-02, is "the level which reliable suction loss occurs due to uncovering of the coolant inlet pipe, weir, or vacuum breaker." During normal operation, the weir for the skimmer surge tanks and SFP is positioned to maintain the level at or above the minimum value of 37 feet 6 inches (i.e., 116 feet 1 inch plant elevation). This level provides sufficient makeup to the skimmer surge tank to maintain skimmer surge tank water level at 94 feet plant elevation, thereby ensuring adequate fuel pool cooling pump NPSH. Therefore, Level 1 shall be at a height of approximately 37 feet 6 inches from the bottom of the SFP (i.e., 116 feet 1 inches plant elevation).
Level 2 Level 2, as defined in NEI 12-02, is "10 feet (+/- 1 foot) above the highest point of any fuel rack seated in the fuel pool." The highest point of any fuel rack in the SFP is approximately 16 feet 8 inches (i.e., 95 feet 3 inches plant elevation). Therefore, Level 2 shall be at a height of approximately 26 feet 8 inches in the SFP (i.e., 105 feet 3 inches plant elevation).

BSEP 13-0073 Enclosure Page 3 of 8 Level 3 Level 3, as defined in NEI 12-02, is "nominally (i.e., +/- 1 foot) to the highest point of any fuel rack seated in the spent fuel pool." The highest point of any fuel rack in the SFP is approximately 16 feet 8 inches (i.e., 95 feet 3 inches plant elevation). Therefore, Level 3 shall be at a height of approximately 16 feet 8 inches in the SFP (i.e., 95 feet 3 inches plant elevation).
b) See Figure 1, page 7, for the requested sketch.
NRC RAI-2 Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and back-up SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
BSEP Response to RAI-2 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-2 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.
NRC RAI-3 Please provide the following:
a) The design criteria that will be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.
c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.
BSEP Response to RAI-3 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-3 for BSEP in the August 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.

BSEP 13-0073 Enclosure Page 4 of 8 NRC RAI-4 Please provide the following:
a) A description of the specific method or combination of methods you intend to apply to demonstrate the reliability of the permanently installed equipment under Beyond-Design-Basis ambient temperature, humidity, shock, vibration, and radiation conditions.
b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (a) the level sensor mounted in the SFP area, and (b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment during and following seismic conditions to maintain its required accuracy.
BSEP Response to RAI-4 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-4 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.
NRC RAI-5 Please provide the following:
a) A description of how the two channels of the proposed level measurement system meet this requirement so that the potential for a common cause event to adversely affect both channels is precluded.
b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
BSEP Response to RAI-5 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-5 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-12-051.
NRC RAI-6 If the level measurement channels are to be powered through a battery system (either directly or through an uninterruptible power supply, 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 following the onset of the beyond design-basis (BDB) event for the minimum duration needed, consistent with the plant FLEX Program plans.

BSEP 13-0073 Enclosure Page 5 of 8 BSEP Response to RAI-6 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-6 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.
NRC RAI-7 Please provide the following:
a) An estimate of the expected instrument channel accuracy performance under both (a) normal SFP level conditions (approximately Level 1 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 3 datum points.
b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
BSEP Response to RAI-7 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-7 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-12-051.
NRC RAI-8 Please provide the following:
a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ.
b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
c) A description of how functional checks will be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to 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.

BSEP 13-0073 Enclosure Page 6 of 8 BSEP Response to RAI-8 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-8 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-12-051.
NRC RAI-9 Please provide the following:
a) The specific location for the primary and backup instrument channel display.
b) Ifthe primary or backup display location is other than the main control room, then provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.
c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.
BSEP Response to RAI-9 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-9 for BSEP in the February 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.
NRC RAI-10 Please provide a description of the standards, guidelines and/or criteria that will be utilized to develop procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments.
BSEP Response to RAI-10 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-10 for BSEP in the August 2014, Six Month Status Report for the Implementation of Order EA-1 2-051.
NRC RAI-11 Please provide the following:
a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

BSEP 13-0073 Enclosure Page 7 of 8 b) A description of how the guidance in NEI 12-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.
BSEP Response to RAI-1 1 Information is not available within the 60-day response period for this RAI. Duke Energy anticipates submitting a response to RAI-1 1 for BSEP in the August 2014, Six Month Status Report for the Implementation of Order EA-12-051.

BSEP 13-0073 Enclosure Page 8 of 8 POOL LEVELS AND REFERENCE (LEVEL RANGE MNMUM EL W- TO EL 114 PLANT ELEVATION
                                     -II-1'4"                F2 M RImnor;         Bidng vmmeu &Doem              Fuel Pool W4*j                                                    F.UUS RT; ftelw Eulng Awangmt A           &Dome Fud Pool 37.1gJr                                                    1.FP4SI1N,       AM;Pool Coaoi &CmwUp Fue Pool IHILO Le SwlM6 Ful U2374k7rV'                  - --- ll4r          (MT 2: w.&Tr 24U-mP41    U,w, Ful Poo cooq &Ckmo-Up Ful Pool HNLO Leve S*M sT4r-                   -.--           -. 1 11W                14114101A, U, Ful Pool COoing A C u-Up Fue Poo HILO Level Swilh VPP.SIRS. U;*Full Pol Cooi        &COem.Jp Fuel Poo HULO Levl Swileb 1OP.13, R*    Fuel PoovlCoogd COMup S              Opu        Prooedwr.
20-P13, Mr; Fe Pool Cooing and C1m0p S0m Op0eh                Prosd 14WP.42S, U&; Fuel Pool Cooing &ChwUJp Fuel Pool HYLO Level Swltch
                                       -- 11w-0"             2-4PwOM       w. Fue Pool Coowng &CkwUp Fue Poo hLO Laev Sawth
                                    - - 111-M.r              TEC SME AMIDUUIOT UNIT 1. R261; Technk*e SPeefciston Ainmulout Unit I TWO4 SPE Ak1ITM             MIT 2. Rt~t Technicel Speoillodlon AAnmW~~Unkl MMM42, R% SCel "u Pool Wevelim of Top of Ac"            Fuel
                                ---    10r-                  NO 1242 (Leve 3 +14n
                               ....       W'.3               2M24M2, I; Spent Fuel Pool EBevion of Top of AMiw Fuel O*W4S        .W NFNW UmoduAspy 15 Mke (MIT) Mie I & 2 O.FP4S5Z.        Spen" Fuel Morage Tube Type NU i1 & 2 O;
                                --- 7-78.7                   F429WS U; Remacor bding Arrangeet A Doakl Fuel pool F-29M R7,; ReAmto bi~dngkVagui  --- _.1i1 A b Fuel POol FIGURE 1 (Unit I & 2 SFP Elevation View with Levels indicated)}}