ML15069A229

Surry, Units 1 & 2 - 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)

ML15069A229
Person / Time
Site:	Surry
Issue date:	03/02/2015
From:	Sartain M D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-392A, EA-12-051
Download: ML15069A229 (22)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 2326110 CFR 2.202Order EA-12-051March 2, 2015Attention: Document Control Desk Serial No.: 14-392AU.S. Nuclear Regulatory Commission NL&OS/MAE: R3Washington, D.C. 20555-0001 Docket Nos.: 50-280/281License Nos.: DPR-32/37VIRGINIA ELECTRIC AND POWER COMPANYSURRY POWER STATION UNITS I AND 2SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12. 2012 COMMISSIONORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOLINSTRUMENTATION (ORDER NUMBER EA-12-051)

References:

1. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation," dated March 12, 20122. Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (Serial No. 12-167B)3. Virginia Electric and Power Company's Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27,2014 (Serial No. 12-167D)4. Virginia Electric and Power Company's Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28,2014 (Serial No.14-392)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order(Reference 1) to Virginia Electric and Power Company (Dominion). Reference 1 wasimmediately effective and directed Dominion to install reliable Spent Fuel Pool (SFP)Level Instrumentation (SFPLI).Reference 1 required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a statusreport at six-month intervals following submittal of the OIP.

Serial No. 14-392ADocket Nos. 50-280/281Fourth Six-Month Status Report Order EA-12-051Page 2 of 3Attachment 1 to this letter provides the fourth Six-Month Status Report and an update ofmilestone accomplishments since the submittal of the previous six-month status report(Reference 4), including any changes to the compliance method, schedule, or need forrelief and the basis. Attachment 2 to this letter provides the SFPLI request for additionalinformation (RAI) responses, with the exception of RAI 17. RAI 17 will be submittedwith the compliance letter for Order EA-12-051.If you have any questions, please contact Mr. Gary D. Miller at (804) 273-2771.Sincerely,Mark D. SartainVice President Nuclear EngineeringAttachments: 1. Six Month Status Report for the Implementation of Order EA-12-0512. Response to SFPLI RAIs and Safety Evaluation Review Item 1Commitments made by this letter: No new Regulatory CommitmentsCOMMONWEALTH OF VIRGINIA ))COUNTY OF HENRICO )The foregoing document was acknowledged before me, in and for the County andCommonwealth aforesaid, today by Mark D. Sartain who is Vice President Nuclear Engineeringof Virginia Electric and Power Company. He has affirmed before me that he is duly authorizedto execute and file the foregoing document in behalf of the Company, and that the statements inthe document are true to the best of his knowledge and belief.Acknowledged before me this ; day of ,2015.My Commission Expires: ".,6et--r 31)zeIt/'CRAIG D SLYI Notary PublicCommonwealth ofoVirginiaReg. # 7518653 ,,My Commission Expires December 31, 202yP(SEAL)

Serial No. 14-392ADocket Nos. 50-280/281Fourth Six-Month Status Report Order EA-12-051Page 3 of 3cc: Director of Office of Nuclear Reactor RegulationU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 13H16M11555 Rockville PikeRockville, MD 20852-2738U. S. Nuclear Regulatory Commission, Region IIRegional AdministratorMarquis One Tower245 Peachtree Center Ave., NESuite 1200Atlanta, Georgia 30303-1257Ms. K. R. Cotton GrossNRC Project Manager SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738Dr. V. SreenivasNRC Project Manager North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorSurry Power Station Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 1Six Month Status Report for the Implementation of Order EA-1 2-051.Order Modifying Licenses with Regard to Requirements forReliable Spent Fuel Pool InstrumentationFebruary 2015Virginia Electric and Power Company(Dominion)Surry Power Station Units I and 2 Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 1Page 1 of 4Six Month Status Report for the Implementation of Order EA-12-051Surry Power Station Units 1 and 21 IntroductionDominion developed an Overall Integrated Plan (OIP) (Reference 1) documenting therequirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI) inresponse to Order EA-12-051 (the Order) (Reference 2). This attachment provides anupdate of milestone accomplishments since submittal of the last status report(Reference 4), including any changes to the compliance method, schedule, or need forrelief/relaxation and the basis, if any.2 Milestone AccomplishmentsThe following milestones have been completed since the development of the SurryPower Station (SPS) OIP for Order EA-12-051 and are current as of January 31, 2015." Submit OIP" Commence Engineering and Design* Complete Engineering and Design* Complete Procurement of SFP Instruments" Commence Installation of SFP Instruments3 Milestone Schedule StatusThe following table provides an update to the milestone schedule supporting the OIP.This table provides the activity status of each item and the expected completion date,noting any change. The target completion dates are subject to change as design andimplementation details are developed.Milestone Target Activity Revised TargetCompletion Date Status Completion DateSubmit OIP Feb 2013 CompleteCommence Engineering and March 2013 CompleteDesignComplete Engineering and May 2014 CompleteDesign Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 1Page 2 of 4Milestone Target Activity Revised TargetCompletion Date Status Completion DateComplete Procurement of SFP August 2014 CompleteInstrumentsCommence Installation of SFP November 2014 CompleteInstrumentsLevel Measurement System December 2014 Started May 2015*Functional* The revised milestone target completion date for 'Level Measurement SystemFunctional' does not impact the Order implementation date for SPS.4 Changes to Compliance MethodThere are no changes to Dominion's compliance method with NEI 12-02 (Reference 5).5 Need for Relief/Relaxation and Basis for the Relief/RelaxationDominion expects to comply with the Order implementation date, and no requiredrelief/relaxation has been identified at this time.6 Open Items from Overall Integrated Plan and Interim Staff EvaluationNo open items were identified in the SPS OIP. However, Requests for AdditionalInformation (RAIs) were identified in the Interim Staff Evaluation (Reference 6).Responses to these SFPLI RAIs, with the exception of RAI 17, are provided inAttachment 2 to this letter. The response to SFPLI RAI 17 will be provided with theSurry compliance letter for Order EA-12-051.One additional item, identified as Safety Evaluation (SE) Review Item 1, was identifiedduring the January 2015 Onsite NRC Audit. SE Review Item 1 was a questionregarding the potential effect that Electro Magnetic Interference (EMI) may have on theSFPLI. The response to this item is also addressed in Attachment 2 of this letter.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 1Page 3 of 47 Potential Interim Staff Evaluation (ISE) ImpactsIn the second Six Month Status Report letter (Reference 3), Dominion reported achange in the SFPLI vendor and reported conclusions of a comparison between theWestinghouse SFPLI design and the design details previously provided to the staff thatwere included in the ISE (Reference 6).8 Supplemental InformationThis supplemental information provides details of the changes identified in the statusupdates above and addresses a revision to Milestone Task 'Level Measurement SystemFunctional.'a) SPS, Milestone Task 'Level Measurement System Functional': The revision to thescheduled milestone target completion date allows for approval of the finalized SPSFLEX Support Guidelines (FSGs). In accordance with Attachment 2 to Order EA-12-051, implementing procedures for use of the SFPLI system are required to be incompliance with the Order. FSG-1 1 is the implementing procedure for operation ofthe SFPLI system. Therefore, when FSG-1 1 is issued, the SFPLI system will beconsidered 'Functional' and in compliance with the Order.9 ReferencesThe following references support the update to the SFPLI OIP described inAttachment 1:1. Virginia Electric and Power Company's Overall Integrated Plan in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2013 (Serial No. 12-167B).2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard toReliable Spent Fuel Pool Instrumentation," dated March 12, 2012.3. Virginia Electric and Power Company's Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2014 (Serial No. 12-167D).4. Virginia Electric and Power Company's Second Six-Month Status Report inResponse to March 12, 2012 Commission Order Modifying Licenses with Regardto Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), datedAugust 28, 2014 (Serial No.14-392).

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 1Page 4 of 45. NEI 12-02 (Revision 1), Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel PoolInstrumentation," dated August 2012.6. Surry Power Station, Units 1 and 2: Interim Staff Evaluation and Request forAdditional Information Regarding Overall Integrated Plan for Implementation ofOrder EA-12-051, Reliable Spent Fuel Pool Instrumentation," dated November 1,2013.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Response to SFPLI RAIs and Safety Evaluation Review Item IVirginia Electric and Power Company(Dominion)Surry Power Station Units 1 and 2 Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 1 of 13Response to SFPLI RAIs and Safety Evaluation Review Item 1Spent Fuel Pool Level Instrumentation (SFPLI) RAIs 3. 8, 9, 10, 11, 12, 14, and 15Dominion Response:On November 1, 2013, Dominion received an Interim Staff Evaluation (ISE) andRequest for Additional Information Regarding the Overall Integrated Plan forImplementation of Order EA-12-051 for Surry Power Station (SPS) Units 1 and 2 in aletter from Ms. Karen Cotton to Mr. David Heacock (Reference 1). Responses to RAIs3, 8, 9, 10, 11, 12, 14, and 15 contained in the ISE were provided to the NRC inAttachment 2 to the second Six-Month Status Report dated February 27, 2014(Reference 4).SFPLI RAIs 1. 2. 4. 5. 6. 7. 13, 16. and 18SFPLI RAI No. 1Please provide a clearly labeled sketch or marked-up plant drawing of the plan view ofthe SFP area, depicting the SFP inside dimensions, the planned locations/placement ofthe primary and back-up SFP level sensor, and the proposed routing of the cables thatwill extend from these sensors toward the location of the read-out/display device.Dominion Response:A plan view sketch of the SPS Spent Fuel Pool (SFP) area is provided in the figurebelow. The sketch depicts the SFP inside dimensions, the planned locations/placementof the primary and back-up channel sensors, and the proposed cable routing thatextends the sensors toward the location of the electronics.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 2 of 13I-Surry Power Station SFPLI Plan View(EL. 47'-4")

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 3 of 13SFPLI RAI No. 2Provide the following:a) The design criteria that will be used to estimate the total loading on the mountingdevice(s), including static weight loads and dynamic loads. Describe the methodologythat will be used to estimate the total loading, inclusive of design basis maximumseismic loads and the hydrodynamic loads that could result from pool sloshing or othereffects that could accompany such seismic forces.b) A description of the manner in which the level sensor will be attached to the refuelingfloor and/or other support structures for each planned point of attachment of the probeassembly. Indicate in a schematic the portions of the level sensor that will serve aspoints of attachment for mechanical/mounting or electrical connections.c) A description of the manner by which the mechanical connections will attach the levelinstrument to permanent SFP structures so as to support the level sensor assembly.Dominion Response:a) The mounting device (mounting bracket) for the SFPLI system is designated asQuality Classification NSQ (Non-safety related, with special quality requirements) inaccordance with the Dominion Nuclear Quality Assurance Program (Reference 3). Themounting bracket design meets the SPS design requirements for Seismic Category Icomponents and includes consideration of static weight loads and hydrodynamic loads.The mounting bracket was qualified by analysis for the loading conditions, includingdesign basis maximum seismic loads and the hydrodynamic loads that could result frompool sloshing. The Surry-specific analysis of the mounting bracket was performed byWestinghouse (SFPLI equipment supplier) and the methods, design criteria, and resultsof the analysis are documented in a Westinghouse calculation (Reference 4).b) The level sensor consists of the braided stainless steel cable level probe, which isattached to the mounting bracket and extends into the pool. The attachment to thebottom of the mounting bracket and to the signal cable is made via a coaxial coupling.The mounting bracket is attached to the SFP structure at the concrete curb utilizingexpansion-type concrete anchor bolts. The probe is not attached to the floor of thepool.The following simplified drawings show a representation of the attachment of the probeand the sensor cable to the mounting bracket (launch plate) and mounting bracketattachment to the SFP structure.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 4 of 13Launch Plate is 1" Away IConcrete Fuel PoolCoupling(Bottom)c) The level sensor (probe) is designed to be attached near its upper end to themounting bracket, as described in the response to RAI #2b above. The mountingbracket is attached to the SFP concrete curb utilizing expansion-type concrete anchorbolts. The mounting bracket to the SFP structure concrete curb anchorage is designedto meet the requirements of the Surry design basis for Seismic Category I componentsincluding seismic loads, static weight loads and hydrodynamic loads.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 5 of 13SFPLI RAI No. 4For each of the mounting attachments required to attach SFP Level equipment to plantstructures, please describe the design inputs, and the methodology that was used toqualify the structural integrity of the affected structures/equipment.Dominion Response:As described in the responses to RAIs 2a, 2b, and 2c above, the level sensing probe isattached to the mounting bracket, which is anchored to the SFP structure at theconcrete curb using concrete expansion anchors. The anchorage to the SeismicCategory I SFP structure meets the design requirements described in the response toRAI 2c.Each of the additional SFPLI components required to be mounted / anchored are fixedto plant structures consistent with the Surry design and licensing bases for SeismicCategory I components, and include consideration of design basis maximum seismicloads and static weight loads.SFPLI RAI No. 5Please provide analysis of the maximum expected radiological conditions (dose rateand total integrated dose) to which the equipment (including transmitters, control boxes,and display panels) will be exposed. Also, please provide documentation indicating howit was determined that the electronics for the SFP level instrumentation is capable ofwithstanding a total integrated dose of 1E4 Rads. Please discuss the time period overwhich the analyzed total integrated dose was applied.Dominion Response:A radiation dose analysis was performed to support the radiological assessmentrequirements defined by NEI 12-02 (Reference 5) for the SFP, Auxiliary Building areas,and Cable Spreading Rooms. The results are provided in Calculation RA-0047,"Radiological Evaluation following a Beyond Design Basis SPS SFP Draindown for NEI12-02," (Reference 6). The results of the analysis provided integrated doses for 7-daysand dose rates post-event with SFP water level at one foot above the fuel rack. Theanalysis also provided dose rates and integrated doses for 40-year normal operation.The 7-day integrated doses and dose rates were based on the core inventories (spentfuel sources) at 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after shutdown as defined in NEI 12-02.In the SFP area where the coupler and coaxial cable are located, the dose analysisresulted in a 7-day integrated dose of 2.9E6 Rads and a 40-year integrated dose of 880Rads. In the Auxiliary Building where the SFPLI sensor transmitters are located, the Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 6 of 13dose analysis resulted in a 7-day integrated dose of 990 Rads and 40-year integrateddose of 880 Rads. In the Cable Spreading Rooms where the display cabinets arelocated, the dose analysis resulted in a 7-day integrated dose of 320 Rads and 40-yearintegrated dose of 270 Rads. These values were compared to the design criteria of 1 E7Rads for the SFP area and 1 E3 Rads for the areas outside of the SFP area and formedthe basis for demonstrating reliability of the permanently installed SFPLI.Reference 6 also calculated the highest dose rates, with Spent Fuel Pool water level atone foot above the fuel rack, experienced by the equipment inside the Spent Fuel pool,Auxiliary Building, and Cable Spreading Rooms. These dose rates are: Spent Fuel Poolarea: 1.7 E+04 R/hr; Auxiliary Building: 6 R/hr; Cable Spreading Room: 1.9 R/hr.Radiation test results supplied from Westinghouse in qualification summary test reportEQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel PoolInstrumentation System" (Reference 8), have qualified the coupler and coaxialconnecting cable to greater than 1 E7 Rads demonstrating reliability of this permanentlyinstalled equipment located in the SPS SFP. Westinghouse document EQ-QR-269 isavailable for review upon request. (Reference 18)The SFPLI electronics utilize Commercial-off-the-Shelf (COTS) components containingComplementary Metal Oxide Semiconductor (CMOS) devices which are capable ofwithstanding ionizing dose radiation levels of up to 1E3 Rads as described in EPRI1021067, "Nuclear Power Plant Equipment Qualification Reference Manual" Rev. 1, anddiscussed in RG 1.209, "Guidelines for Environmental Qualification of Safety-RelatedComputer Based Instrumentation and Control Systems in Nuclear Power Plants."Comparing the calculated integrated dose for both the short-term post-BDB event andthe long-term normal operating conditions to the industry accepted limit formed thebasis to demonstrate reliability of the permanently installed sensor transmitterequipment located within the Auxiliary Building under post-BDB event radiologicalconditions.SFPLI RAI No. 6Please provide information indicating:a) What are the temperature ratings and whether the temperature ratings for the systemelectronics (including transmitters, control boxes, and display panels) are continuousduty ratings; and,b) What will be the maximum expected ambient temperature in the rooms in which thesystem electronics will be located under BDB conditions in which there are no AC poweravailable to run Heating Ventilation and Air Conditioning (HVAC) systems?

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 7 of 13Dominion Response:a) The temperature rating for the electronic equipment located in the Auxiliary Buildingand the Cable Spreading Rooms (transmitter, control box, uninterruptable power supply(UPS), display) is 120 degrees F based on a continuous duty rating and 140 degrees Funder abnormal conditions. The basis for the temperature ratings is provided in Section4.6 of Westinghouse design specification WNA-DS-02957-GEN (Reference 9). Thetemperature rating test results for abnormal conditions are provided in Section 4.5 ofWestinghouse report EQ-QR-269, "Design Verification Testing Summary Report for theSpent Fuel Pool Instrumentation System" (Reference 8). Both WNA-DS-02957-GENand EQ-QR-269 are available for review upon request. (Reference 18)b) The electronic transmitter equipment is mounted within the Auxiliary Building oneelevation below the SFP Operating Deck. The displays, control box and UPS arelocated in the Cable Spreading Rooms which are one elevation above the Main ControlRoom (MCR). These areas are described in SU-EQUAL-00038-EZD, "EnvironmentalZone Description Surry Unit 1 and 2," (Reference 10). Worst case conditions are notexpected to exceed 105 degrees F (i.e., mild zone) during normal operations. Themaximum temperature under postulated BDB conditions in which there is no AC poweravailable to run heating, ventilation and air conditioning (HVAC) systems is notexpected to exceed 120 degrees F. The room temperatures were analyzed utilizingGOTHIC computational code for BDB conditions, and the results are included inAddendum OA to SPS calculation ME-0973, "Evaluation of Room Air TemperaturesFollowing Extended Loss of AC Power (ELAP)" (Reference 11). Calculation ME-0973has been previously provided to the staff and is available for their review. (Reference18)SFPLI RAI No. 7Please provide information indicating the maximum expected relative humidity in therooms in which the system electronics will be located under BDB conditions, in whichthere are no AC power available to run HVAC systems, and whether the sensorelectronics are capable of continuously performing its required functions under thisexpected humidity condition.Dominion Response:The electronic transmitter equipment is mounted within the Auxiliary Building oneelevation below the SFP Operating Deck. The displays, control boxes, and UPS arelocated in the Cable Spreading Rooms one elevation above the Main Control Room.The maximum humidity for SPS postulated BDB conditions in which there is no ACpower available to run heating, ventilation and air conditioning (HVAC) systems isexpected to be less than 95% relative humidity which was analyzed utilizing GOTHIC Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 8 of 13computational code, and the results are included in Addendum O0A to SPS calculationME-0973, "Evaluation of Room Air Temperatures Following Extended Loss of AC Power(ELAP)" (Reference 11). Equipment testing under normal and abnormal conditions withhumidity levels up to 95% was performed by Westinghouse and the results documentedin Section 4.5 of EQ-QR-269, "Design Verification Testing Summary Report for theSpent Fuel Pool Instrumentation System" (Reference 8). The results from testingperformed by Westinghouse compared to the maximum post BDB humidity level of 95%were found to be acceptable. This comparison formed the basis to demonstratereliability of the permanently installed electronic equipment located within the AuxiliaryBuilding and Cable Spreading Rooms under the BDB post event humidity conditions.Calculation ME-0973, Rev. 0, Add. O0A, has been previously provided to the staff and isavailable for review. Westinghouse document EQ-QR-269 is available for review uponrequest. (Reference 18)SFPLI RAI No. 13Please provide the following:a) A description of the electrical AC power sources and capabilities for the primary andbackup channels.b) Please provide the NRC staff with the final configuration of the power supply sourcefor each channel so that the staff may conclude that the two channels are independentfrom a power supply assignment perspective.Dominion Response:a & b) Each instrument channel is normally powered by 120V AC distribution panels tosupport continuous monitoring of the SFP level. The 120V AC distribution panels forthe primary and backup channels are powered by different 480V AC buses. Therefore,the loss of any one 480V AC bus will not result in the failure of both instrumentchannels. On loss of normal 120V AC power, each channel is equipped with a separateuninterruptible power supply (UPS) that will automatically transfer to a dedicated back-up battery. If normal power is restored, the channel will automatically transfer back tothe normal 120V AC power source. The backup batteries are maintained in a chargedstate by the associated UPS.The instrument channels can also be powered through a manually selected alternateAC power source. The Westinghouse SFPLI system design does not include anoptional external DC power input.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 9 of 13SFPLI RAI No. 16Please provide the following:a) For both SFP level instrumentation read-out/displays located outside the main controlroom, please describe the evaluation used to validate that the display location can beaccessed without unreasonable delay following a BDB event. Include the time availablefor personnel to access the display as credited in the evaluation, as well as the actualtime (e.g., based on walk-throughs) that it will take for personnel to access the display.Additionally, please include a description of the radiological and environmentalconditions on the paths personnel might take. Describe whether the display locationremains habitable for radiological, heat and humidity, and other environmentalconditions following a BDB event. Describe whether personnel are continuouslystationed at the display or monitor the display periodically.Dominion Response:The primary display location for the SFPLI system is located in the Unit 1 CableSpreading Room directly above the Main Control Room near the Appendix R remotemonitoring panels. This location was selected due to its proximity to a current AppendixR access path inside a seismic structure and proximity to the Main Control Room thatallows rapid access for the emergency response staff to and from the display.Radiological habitability at this location has been evaluated against the radiologicalconclusions in 1) Calculation 12846.38-RP-026, Revision 0, Addendum A, "SurryAuxiliary Building Radiation Zone Maps for the Post-LOCA Mitigation Phase (NoLetdown) Based on NUREG-0578," February 2009 (Reference 12), 2) Calculation12846.38-RP-031, Revision 0, Addendum A, "NUREG-0578 Shielding Review -SiteDose Rates following a LOCA," February 2009 (Reference 13), and 3) CalculationSU-CALC-PA-01 1, Revision 0, "Low Water Level Spent Fuel Pool Dose Rate," October1988 (Reference 14). Results of the evaluation have concluded that due to the physicaldistance from the SFP and shielding from structures, radiological exposure to personnelmonitoring SFP levels would remain less than emergency exposure limits allowable foremergency responders to perform this action, per the Surry Emergency Plan. Heat andhumidity from SFP boildown conditions have been evaluated for this location inCalculation ME-0973, Rev. 0, Add. OA, "Evaluation of Room Air TemperaturesFollowing Extended Loss of AC Power (ELAP)" (Reference 11). The location isphysically separated from the SFP by closed fire doors, and the entire Auxiliary Buildingsuch that heat and humidity from a boiling SFP would not compromise habitability at thislocation. Calculations 12846.38-RP-026, Revision 0, Addendum A, 12846.38-RP-031,Revision 0, and Calculation SU-CALC-PA-01 1, Revision 0 have been previouslyprovided to the staff and are available for their review (Reference 18).

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 10 of 13The secondary display location for the SFPLI system is in the Unit 2 Cable SpreadingRoom. This location is physically separated from the primary monitoring location toallow for scenarios where access to the primary control location is not desirable. Thesecondary monitoring location allows rapid access to and egress from the Main ControlRoom (MCR) via pathways that are enclosed within seismically qualified structures.This location has similar characteristics physically to the Unit 1 Cable Spreading Roomand would not be significantly different with regard to exposure during accidentscenarios or habitability from the primary location.Spent fuel pool level display monitoring will be primarily the responsibility of the ServiceBuilding Inside Operator, who will normally perform periodic monitoring at the locationwhere the primary display is mounted once dispatched from the MCR. Travel time fromthe MCR to the primary display is approximately one minute based on walkdowns.Travel time from the MCR to the secondary display location is approximately one minutebased on walkdowns. The transit routes to both displays are primarily contained withinthe MCR pressure boundary and due to both areas being physically directly above theMCR, there is no significant change associated with the travel path to the primary orsecondary display locations, and similar exposure rates would be expected based onsimilar distance from the Containment structures and Spent Fuel Pool.Diverse communications are accessible at both display locations. The Gai-tronicssystem is available at both locations if it survives the BDB event. If not, the creditedsound power phone receptacles are available as a backup. The Cable SpreadingRooms are considered Radio Frequency Interference Boundaries; therefore, the stationradio system would not normally be used in these areas, but could be evaluated asneeded by the Station Emergency Manager during station emergencies, since the unitswould already be shutdown, and there would be no risk of unit transient associated withtheir use at that time.SFPLI RAI No. 18Please provide the following:a) Further information describing the maintenance and testing program the licensee willestablish and implement to ensure that regular testing and calibration is performed andverified by inspection and audit to demonstrate conformance with design and systemreadiness requirements. Please include a description of the plans for ensuring thatnecessary channel checks, functional tests, periodic calibration, and maintenance willbe conducted for the level measurement system and its supporting equipment.b) Information describing compensatory actions when both channels are out-of-order,and the implementation procedures.

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 11 of 13c) Additional information describing expedited and compensatory actions in themaintenance procedure to address when one of the instrument channels cannot berestored to functional status within 90 days.Dominion Response:a) Operators will record the SFP level from both channels of the SFP level indicatorstwice daily as part of operations walkdowns (i.e., Operator Logs) and will check theUPS to ensure it is being supplied by the proper source and the batteries are fullycharged. The SFP level nominal operating range is >23.87 ft., but <24.37 ft. Thereadings taken from each SFP level indicator channel during the operations walkdownswill be compared to each other. There will be an established acceptable delta betweenthe values obtained. If either reading is outside of the nominal operating range or thedifference in the readings exceeds the established acceptable delta, the Control Roomwill be notified and corrective actions will be initiated to resolve the discrepancy. Whilethe SFP is operating within design basis and at normal level, the indicators may becompared to fixed marks within the SFP by visual observation to confirm indicated level.The periodic calibration verification will be performed within 60 days of a refuelingoutage considering normal testing scheduling allowances (e.g., 25%). Calibrationverification is not required to be performed more than once per 12 months. Thesecalibration requirements are consistent with the guidance provided in Section 4.3 of NEI12-02. Periodic calibration verification procedures provided by Westinghouse in WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure,"(Reference 16) are in place. Site specific calibration verification procedures have beendeveloped based on Westinghouse document WNA-TP-04709-GEN. Preventivemaintenance procedures, which include tests, inspection and periodic replacement ofthe backup batteries, have been provided by Westinghouse. The Recurring TaskEvaluations (RTEs) that prepare and implement the corresponding site specificpreventative maintenance (PM) activities using recommended vendor guidance havebeen approved and PM development is in progress.b & c) Provisions associated with out of service (OOS) or non-functional equipmentincluding Allowed Outage Times and compensatory actions are consistent with theguidance provided in Section 4.3 of NEI 12-02. If one OOS channel cannot be restoredto service within 90 days, appropriate compensatory actions, including the use ofalternate suitable equipment, will be taken. If both channels become OOS, actionswould be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels to operable status andto implement appropriate compensatory actions (e.g., use of alternate suitableequipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Additionally, if both channelsare OOS, a Condition Report will be initiated and addressed through Dominion'sCorrective Action Program.Surry will maintain sufficient spare parts for the SFPLI, taking into account the lead timeand availability of spare parts, in order to expedite maintenance activities, when Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 12 of 13necessary, to provide assurance that a channel can be restored to service within 90days.Safety Evaluation (SE) Review ItemSE#1Please provide an assessment of potential susceptibilities of EMI/RFI in the areaswhere the SFP instrument located and how to mitigate those susceptibilities.Dominion Response:The base configuration necessary to meet Criterion B (instrument will function beforeand after an Electro-Magnetic Compatibility (EMC) event) was confirmed during EMCqualification testing performed by Westinghouse. NRC representatives audited theWestinghouse test documents. As a result, Westinghouse specified materials,installation, and grounding requirements necessary to ensure the installed SFPLIsystem meets the tested EMI/RFI qualifications. These requirements and characteristicsare detailed in Westinghouse proprietary letter LTR-EQ-14-32, Rev. 2 dated August 1,2014 (Reference 17), which is available for review upon request. (Reference 18)Additionally, placards have been installed in the SPS Auxiliary Building. The placardsread, "Be aware that use of hand-held radios within 3 ft. may cause interference with theSFP level channels. The reading returns to normal when radio usage is stopped."

References:

1. Surry Power Station, Units 1 and 2: NRC Interim Staff Evaluation and Request forAdditional Information Regarding the Overall Integrated Plan for Implementation ofOrder EA-12-051, Reliable Spent Fuel Pool Instrumentation, dated November 1,2013 (ML13298A625).2. Surry Power Station Units 1 and 2, Second Six-Month Status Report in Response toMarch 12, 2012 Commission Order Modifying Licenses with Regard to ReliableSpent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 27,2014 (Serial No. 12-167D). (ML14069A010).3. Nuclear Facility Quality Assurance Program Description, Topical Report DOM-QA-1,Revision 18.4. 38-0-W893-CN-PEUS-14-3, "Seismic Analysis of the SFP Mounting Bracket forSurry Power Station, Millstone Power Station Unit 3, & North Anna Power Station."

Serial No. 14-392ADocket Nos. 50-280/281Order EA-12-051Attachment 2Page 13 of 135. NEI 12-02, Rev. 1, "Industry Guidance for Compliance with NRC Order EA-12-051,"To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"dated August 2012.6. CALC-RA-0047, Rev. 0, "Radiological Evaluation following a Beyond Design BasisSPS SFP Draindown for NEI 12-02," dated February 14, 2014.7. ETE-CPR- 2013-0004, "Calculation of SFP Elevation Boiloff and Refill Rates forShielding Purposes."8. Westinghouse document EQ-EE-269, "Design Verification Testing Summary Reportfor the Spent Fuel Pool Instrumentation System," dated September 2014.9. Westinghouse document WNA-DS-02957-GEN, "Spent Fuel Pool InstrumentationSystem-System Design Specification," dated March 2014.10. SU-EQUAL-00038-EZD, "Environmental Zone Description Surry Unit 1 and 2."11. Calculation ME-0973, Rev. 0, Add. OA, "Evaluation of Room Air TemperaturesFollowing Extended Loss of AC Power (ELAP)."12.Calculation 12846.38-RP-026, Revision 0, Addendum A, "Surry Auxiliary BuildingRadiation Zone Maps for the Post-LOCA Mitigation Phase (No Letdown) Based onNUREG-0578," February 2009.13.Calculation 12846.38-RP-031, Revision 0, Addendum A, "NUREG-0578 ShieldingReview -Site Dose Rates following a LOCA," February 2009.14.Calculation SU-CALC-PA-011, Revision 0, "Low Water Level Spent Fuel Pool DoseRate," October 1988.15. IEEE 338-1987, "IEEE Standard Criteria for the Periodic Surveillance Testing ofNuclear Power Generating Station Safety Systems."16.Westinghouse document WNA-TP-04709-GEN, "Spent Fuel Pool InstrumentationSystem Calibration Procedure," dated March 2014.17.Westinghouse letter LTR-EQ-14-32, Rev. 2, "Spent Fuel Instrumentation System -Hardware Configuration for EMC testing to satisfy Performance Criteria B," datedAugust 1, 2014.18. NRC letter to All Operating Reactor Licensees and Holders of Construction Permits,"Online Reference Portal for Nuclear Regulatory Commission Review of FukushimaNear-Term Task Force Related Documents," dated August 1, 2013 (ML13206A427).