ML15182A175

Joseph M. Farley, Unit 1 - Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation

ML15182A175
Person / Time
Site:	Farley
Issue date:	06/26/2015
From:	Pierce C R Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NL-1 5-0699
Download: ML15182A175 (30)

Text

Charles R. Pierce Southern NuclearRegulatory Affairs Director Operating

Company, Inc.40 Inverness Center ParkwayPost Office Box 1295Birmingham, AL 35201Tel 205.992.7872 11 wkJUN 2 6 2015 Fax 205.992.7601 A=Docket No.: 50-348 NL-1 5-0699U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Unit 1Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued OrderEA-1 2-051, Order Modifying Licenses with Regard to Reliable Spent Fuel PoolInstrumentation, to Southern Nuclear Operating Company (SNC). This Order waseffective immediately and directed the Farley Nuclear Plant (FNP) Units 1 and 2 toinstall reliable spent fuel pool instrumentation as outlined in Attachment 2 of theOrder. This letter, along with its enclosures, provides the notification required byItem IV.C.3 of the Order that full compliance with the requirements described inAttachment 2 of the Order has been achieved for FNP Unit 1.This letter contains no new NRC commitments.

If you have any questions, pleasecontact John Giddens at 205.992.7924.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern NuclearOperating

Company, is authorized to execute this oath on behalf of SouthernNuclear Operating Company and, to the best of his knowledge and belief, the factsset forth in this letter are true.Respectfull bm itted,C. R. PierceRegulatory Affairs DirectorCRP/JMG/GLS Sworn to and subscribed before me this "." -day of -114, -.._ ,2015.Notary PublicMy commission expires:

I Ao / o\,o- ý-

U.S. Nuclear Regulatory Commission NL-15-0699 Page 2

Enclosures:

1. Compliance with Order EA-12-051

2. NRC Requests for Information cc: Southern Nuclear Operating CompanyMr. S. E. Kuczynski,

Chairman, President

& CEOMr. D. G. Bost, Executive Vice President

& Chief Nuclear OfficerMs. C. A. Gayheart, Vice President

-FarleyMr. M. D. Meier, Vice President

-Regulatory AffairsMr. D. R. Madison, Vice President

-Fleet Operations Mr. B. J. Adams, Vice President

-Engineering Ms. B. L. Taylor, Regulatory Affairs Manager -FarleyRTYPE: CFA04.054 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. S. A. Williams, NRR Project Manager-FarleyMr. P. K. Niebaum, Senior Resident Inspector

-FarleyAlabama Department of Public HealthDr. D. E. Williamson, State Health Officer Joseph M. Farley Nuclear Plant Unit 1Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation Enclosure 1Compliance with Order EA-12-051 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Reference 2), to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directed the Farley Nuclear Plant (FNP) -Units 1 and 2 to install reliablespent fuel pool instrumentation as outlined in Attachment 2 of the Order. The compliance date for FNP Unit 1 was May 4, 2015. The information provided herein documents fullcompliance for FNP Unit 1 in response to the Order.COMPLIANCE Farley Nuclear Plant has installed two independent full scale level monitors on the Unit 1Spent Fuel Pool (SFP) in response to Reference

2. The FNP site has two fuel pools (onefor each unit) operated independently with Reference 13 written previously documenting full compliance of Unit 2 in response to this Order.In accordance with SNC letter dated February 27, 2013 (Reference 1), FNP fully expectedcompliance with Reference 2 would coincide with implementation of Order EA-12-049, Order to Modify Licenses with Regard to Mitigation Strategies for Beyond-Design-Bases External Events (Reference 3). By letter dated April 14, 2014, Relaxation of CertainSchedule Requirements for Order EA-12-049 (Reference 11), the NRC granted.

schedulerelief for FNP implementation of Reference

3. As a result, equipment required byReference 3 is not currently available as originally planned for compliance withReference

2. Specifically, the portable FLEX diesel generators for compliance withItem 1.6 of Attachment 2 to Reference 3 are not available to provide backup power to thespent fuel pool instrumentation as originally intended for compliance with Reference 2.Upon completion of the modifications required by Reference 3, the portable FLEX dieselgenerators will provide backup power supply for the spent fuel pool instrumentation asoriginally planned.

In the interim, a backup power supply, including procedures for its use,is provided for compliance with the requirements of Reference 2.Following SNC submittal of the FNP Overall Integrated Plan (Reference 1), the NRCprovided its interim staff evaluation and requested additional information necessary forcompletion of the review (Reference 9). The requested information previously provided tothe NRC is included in Enclosure 2.Compliance with Order EA-12-051 was achieved using the guidance in Nuclear EnergyInstitute (NEI) document NEI 12-02 (Reference

15) which has been endorsed by the NRC(Reference 16).IDENTIFICATION OF LEVELS OF REQUIRED MONITORING

-COMPLETEFNP-Unit 1 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051.

Until Order EA-12-049 is fully implemented, current plantprocedures conservatively direct Operations personnel to maintain SFP above the levelthat is adequate to support operation of the normal fuel pool cooling system using currentmakeup capabilities.

Once Order EA-12-049 is fully implemented, Operations procedures will be updated to integrate the full capability of the SFP level indication system.El-1 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 INSTRUMENT DESIGNED FEATURES

-COMPLETEThe design of the instruments installed at FNP Unit 1 complies with the requirements specified in Reference 2 and described in NEI 12-02 "Industry Guidance for Compliance with NRC Order EA-12-051

." The instruments have been installed in accordance with theIstation design control process.The instruments are arranged to provide reasonable protection against missiles.

Theinstruments are mounted to retain design configuration during and following the maximumexpected ground motion. The instruments are designed to be reliable at expectedenvironmental and radiological conditions including extended periods when the SFP is atsaturation.

The instruments are independent of each other and have separate and diversepower supplies.

The instruments are designed to maintain their designed accuracyfollowing a power interruption and to allow routine testing and calibration.

fThe SFP instrument display is readily accessible during postulated events and allowslevel information to be promptly available to decision makers.PROGRAM FEATURES

-COMPLETETraining for FNP Unit 1 is complete and was performed in accordance with an acceptedtraining process (Systematic Approach to Training) as recommended in NEI 12-02,Section 4.1.Operating and maintenance procedures for FNP Unit 1 have been developed andintegrated with existing procedures.

Procedures have been verified and are available foruse in accordance with the site procedure control program.Site processes have been established to ensure the instruments are maintained at theirdesign accuracy.

MILESTONE SCHEDULE

-ITEMS COMPLETEFNP Unit 1 Milestone Completion DateSubmit 20 Day Letter Acknowledging Receipt of Order March 27, 2012Submit Overall Integrated Plan February 27, 2013Unit 1 -Refueling Outage November 20131st 6 Month Update August 20132nd 6 Month Update February 2014Instrument Design Complete October 2014Receipt of Unit 1 SFP Instrument Channel July 20143rd 6 Month Update August 20144th 6 Month Update February 2015Complete Functional Test of Unit 1 SFPI January 28, 2015Procedures and Training Complete February 2015Unit 1 -Refueling Outage / Implementation Complete May 4,2015E1-2 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 Based on the above, the requirements of Order EA-12-051 have been achieved for FNPUnit 1. A summary of FNP Unit 1 compliance with the Order is provided as follows:COMPLIANCE ELEMENTS SUMMARYIn accordance with NRC Order EA-1 2-051, FNP shall have a reliable indication of thewater level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel:

(1) level that is adequate to support operation of the normal fuel pool coolingsystem,(2) level that is adequate to provide substantial radiation shielding for a personstanding on the spent fuel pool operating deck, and(3) level where fuel remains covered and actions to implement make-up wateraddition should no longer be deferred.

The FNP Unit 1 Spent Fuel Pool Level Indication System (SFPLIS) is capable ofmeasuring SFP level from approximately ten inches above the top of the fuel racks toapproximately one foot below the top of the SFP. A visual aid is included with the SFPLISdisplay units which indicates the three key SFP levels required by the Order.1. In accordance with NRC Order EA-12-051, the spent fuel pool levelinstrumentation shall include the following design features:

a. Instruments:

The instrumentation shall consist of a permanent, fixed primaryinstrument channel and a backup instrument channel.

The backupinstrument channel may be fixed or portable.

Two independent level detectors have been permanently installed in the Unit 1SFP. The level detectors are redundant and either may be used as the primarydevice with the other acting as the backup device.b. Arrangement:

The spent fuel pool level instrument channels shall bearranged in a manner that provides reasonable protection of the levelindication function against missiles that may result from damage to thestructure over the spent fuel pool. This protection may be provided bylocating the primary instrument channel and fixed portions of the backupinstrument

channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding frommissiles provided by existing recesses and corners in the spent fuel poolstructure.

The detectors are located in opposing sides of the SFP, separated by a distancegreater than the shortest length of a side of the pool, which provides reasonable protection of the level indicating function against missiles that may result fromdamage to the structure over the SFP.c. Mounting:

Installed instrument channel equipment within the spent fuel poolshall be mounted to retain its design configuration during and following themaximum seismic ground motion considered in the design of the spent fuelpool structure.

E1-3 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 The sensing elements, detectors and display units are seismically qualified andmounted, consistent with the FNP Unit 1 licensing bases.d. Qualification:

The primary and backup instrument channels shall be reliableat temperature,

humidity, and radiation levels consistent with the spent fuelpool water at saturation conditions for an extended period. This reliability shall be established through use of an augmented quality assurance process (e.g., a process similar to that applied to the site fire protection program).

The instrument channels are qualified to be reliable at temperature,

humidity, andradiation levels consistent with the SFP water at saturation conditions for anextended period. Westinghouse, supplier of the SFPLIS, has qualified theequipment through a quality assurance process.e. Independence:

The primary instrument channel shall be independent of thebackup instrument channel.The two instrumentation channels are independent.

No equipment is sharedbetween the two channels.

Each channel has independent conduit runs and theconduit runs inside the Auxiliary Building have been routed to provide adequatechannel separation.

f. Power supplies:

Permanently installed instrumentation channels shall eachbe powered by a separate power supply. Permanently installed and portableinstrumentation channels shall provide for power connections from sourcesindependent of the plant ac and dc power distribution

systems, such asportable generators or replaceable batteries.

Onsite generators used as analternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.The instrumentation channels are each powered from separate uninterruptable power supplies (UPS). The UPS for each channel is capable of powering theinstrument for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Onsite portable generators will be used tosupply power to the instruments should an extended loss of AC power occur. A 72hour battery life is sufficient time to obtain a portable generator and connect to theSFPLIS. The site acceptance test confirmed the ability of the batteries to powerthe channels for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.Interim backup power to the FNP Unit 1 SFPLIS is provided in accordance with therequirements of the Order as follows:i. Two 1 kW propane generators are available for supplying backup power tothe SFPLIS. One generator has sufficient capacity to supply bothinstrument channels.

ii. One of the two portable generators is stored in a robust structure (location identified in plant procedures).

iii. Three 20-pound propane tanks are stored in diverse locations throughout the plant site consistent with the reasonable protection requirements ofReference 3 and described in NEI 12-06. The location of the propaneEl -4 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 tanks is provided in Standing Order S-2014-009.

Procedures have beendeveloped for connecting and use of the portable generator to supplybackup power to the SFPLIS in the event of an extended loss of AC power.iv. The Operations Curriculum Review Committee (CRC) determined thatformal training is not required.

Skill of the craft and instructions provided inapproved procedures are adequate to monitor displays and to supplybackup power if needed. Training of Operations personnel has beenconducted to familiarize them with the location of the displays and theprocedures associated with this new system.v. Administrative controls in the form of procedures have been established inthe interim for use of any portable generator in lieu of the FLEX portablediesel generator.

vi. Preventive Maintenance Procedures are in place for maintaining andtesting the portable generators.

These procedures require that periodicload tests be performed.

vii. A timed validation of the generator hook-up and operation has beencompleted.

g. Accuracy:

The instrument channels shall maintain their designed accuracyfollowing a power interruption or change in power source withoutrecalibration.

The channels are designed to maintain accuracy following a power interruption.

This feature was confirmed during the site acceptance test.h. Testing:

The instrument channel design shall provide for routine testing andcalibration.

The channels are designed for routine testing and calibration.

These featureswere confirmed during the site acceptance test.i. Display:

Trained.personnel shall be able to monitor the spent fuel poolwater level from the control room, alternate shutdown panel, or otherappropriate and accessible location.

The display shall provide on-demand orcontinuous indication of spent fuel pool water level.The displays provide continuous level indication, are outside the spent fuel poolroom, and are located in an area that is easily accessible by operators.

2. In accordance with NRC Order EA-12-051, the spent fuel pool instrumentation shall be maintained available and reliable through appropriate development andimplementation of the following programs:

a. Training:

Personnel shall be trained in the use and the provision ofalternate power to the primary and backup instrument channels.

The Systematic Approach to Training process has been used to evaluate anddevelop personnel training for the SFPLIS.E1-5 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 I&C Technicians:

The CRC determined that current task training is adequate tosupport maintenance and calibration of the new level detection system.Accordingly, no additional training is required.

Operations:

CRC determined that formal training is not required.

Skill of thecraft and instructions within approved procedures are adequate to monitordisplays and to supply backup power, if needed. Training of Operations personnel was conducted to familiarize them with the location of the displaysand the procedures associated with this new system.b. Procedures:

Procedures shall be established and maintained for thetesting, calibration, and use of the primary and backup spent fuel poolinstrument channels.

The following procedures have been either updated or created for testing,calibration and use of the SFPLIS:o FNP-1 -SOP-54.0:

Spent Fuel Pit Cooling and Purification System" Section added to describe operation of the display unit* Section added to describe supplying power With a portable generator o FNP-1-SOP-36.4:

120V AC Instrumentation Distribution System0 Added power supply (alternate) locations for the new SFPLI systemo FNP-2-SOP-36.4:

120V AC Instrumentation Distribution SystemM Added power supply (primary) locations for the new SFPLI systemo FNP-1-AOP-36.0:

Loss of Shutdown Cooling* Added option to use new SFPLI for monitoring level.o FNP-1-STP-30.0:

Hot Shutdown Panel Instrumentation Channel Checks" Added monthly check/comparison of primary and alternate leveldisplays with the SFP ruler level." Added monthly check of UPS status.o NMP-OS-019-013:

BDB Equipment Unavailability Tracking* New procedure which provides instructions for tracking unavailability time of the new SFPLI systemc. Testing and Calibration:

Processes shall be established and maintained for scheduling and implementing necessary testing and calibration of theprimary and backup spent fuel pool level instrument channels tomaintain the instrument channels at the design accuracy.

o FNP-1-IMP-222.0: Unit 1 Spent Fuel Pool Level Instrumentation Calibration

• New procedure which provides instructions for calibration of newinstrument systemE1-6 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051 Task generated to periodically perform SFPLI channel check andcalibration REFERENCES The following references support the FNP Unit 1 compliance with the requirements ofOrder EA-12-051:

1. SNC letter NL-1 3-0171, Farley Nuclear Plant Units 1 and 2 Overall Integrated Plan inResponse to March 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051),

datedFebruary 27, 2013.2. NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent FuelPool Instrumentation, dated March 12, 2012.3. NRC Order EA-12-049, Order to Modify Licenses with Regard to Mitigation Strategies forBeyond-Design-Bases External Events, dated March 12, 2012.4. SNC letter NL-1 2-0618, Answer to the March 12, 2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA- 12-051), dated March 27, 2012.5. SNC letter NL-12-2150, Farley Nuclear Plant -Units 1 and 2 Initial Status Report inResponse to March 12, 2012 Commission Order Modifying Licenses with Regard toRequirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051),

dated October 23, 2012.6. NRC letter, Farley Nuclear Plant -Request for Additional Information Regarding OverallIntegrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-05 1), datedAugust 1, 2013.7. SNC letter NL-1 3-1734, Farley Nuclear Plant -Units 1 and2 Response to Request forAdditional Information Regarding Overall Integrated Plan for Reliable Spent Fuel PoolInstrumentation (Order EA-12-051),

dated August 20, 2013.8. SNC letter NL-1 3-1765, Farley Nuclear Plant -Units 1 and 2, First Six-Month Status Reportof Implementation of the Requirements of the Commission Order with Regard to ReliableSpent Fuel Pool Instrumentation (Order EA-12-051),

dated August 27, 2013.9. NRC letter, Interim Staff Evaluation and Request for Additional Information

-Farley NuclearPlant Units 1 and 2 Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel PoolInstrumentation (Order EA-12-05 1), dated October 30, 2013.10. SNC letter .NL-1 4-0183, Farley Nuclear Plant -Units 1 and 2, Second Six-Month StatusReport of Implementation of the Requirements of the Commission Order with Regard toReliable Spent Fuel Pool Instrumentation (Order EA- 12-051),

dated February 26, 2014.11. NRC Letter, Relaxation of Certain Schedule Requirements for Order EA-12-049, datedApril 14, 2014.E1-7 Enclosure 1 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Compliance with Order EA-12-051

12. SNC letter NL-14-1109, Farley Nuclear Plant -Units 1 and 2, Third Six-Month Status Reportof the Implementation of the Requirements for Commission Order with Regard to ReliableSpent Fuel Pool Instrumentation (Order EA-12-051),

dated August 26, 2014.13. SNC letter NL-1 5-0074, Joseph M. Farley Nuclear Plarit Completion of Required ActionOrder EA- 12-051 Reliable Spent Fuel Pool Level Instrumentation, for FNP Unit 2 datedJanuary 14, 2015.14. SNC letter NL-1 5-0239, Joseph M. Farley Nuclear Plant -Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order withRegard to Reliable Spent Fuel Pool Instrumentation (EA-12-05 1), dated February 26, 2015.15. NEI 12-02, Industry Guidance for Compliance with NRC Order EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 24, 2012.16. NRC issued an Interim Staff Guidance document (the ISG), JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (ADAMS Accession No.ML 12221A339),

dated August 29, 2012, to describe methods acceptable to the NRC stafffor complying with Order EA-12-051.

The ISG endorses, with exceptions and clarifications, the methods described in the Nuclear Energy Institute (NEI) guidance document NEI 12-02,Revision 1, Industry Guidance for Compliance with NRC Order EA-12-051.

E1-8 Joseph M. Farley Nuclear Plant -Unit 1Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation Enclosure 2NRC Requests for Information Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information The information provided below is generally a culmination of the previously provided SNCresponses to NRC letter, Interim Staff Evaluation and Request for Additional Information

-Farley Nuclear Plant Units 1 and 2 Regarding Overall Integrated Plan (0IP) for Reliable SpentFuel Pool Instrumentation (Order EA-12-051),

dated October 30, 2013. Some information hasbeen updated and/or revised including RA #11 Unit 1 power supplies and other statuscompletions.

Requests for Information (RAI) numbers 4, 10, and 14 were not included in theNRC letter dated October 30, 2013 and are identified as "Not Applicable" below.NRC RAI 1:Please provide clarification on the elevation identified as Level 2, the elevation of thehighest point of any fuel rack seated in the SFP, and the elevation identified as Level 3.SNC Response to RAI 1:Level 3 is the nominal Top of Rack elevation at 129'-3.5".

Level 2 is 10 feet above atelevation 139'-3.5".

NRC RAI 2:Please identify the final SFP level instrumentation measurement range appropriate to theresolution of the Levels identified in the response to RAI #1 above.SNC Response to RAI 2:The SFP level instrumentation measurement range is 153'-10.0" to 130'-1.5"

(+/- 1 ft. ofthe top of the fuel rack, per NEI 12-02).NRC RAI 3:Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of theSFP area, depicting the SFP inside dimensions, the planned locations/placement of theprimary and back-up SFP level sensor, and the proposed routing of the cables that willextend from these sensors toward the location of the read-out/display device.SNC Response to RAI 3:A plan view sketch of the SFP area is provided as Figure 1. The sketch depicts the SFPinside dimensions, locations/placement of the primary and alternate level sensors, and therouting of cables that extend toward the location of the electronics.

Physical separation ofthe primary and alternate

channels, to the extent practicable and comparable to the shortside of the pool, is used to provide reasonable protection of the level indication functionagainst missiles that may result from the damage to the structure over the SFP.E2-1 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information NRC RAI 4:Not Applicable NRC RAI 5:Please provide 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 themethodology that will be used to estimate the total loading, inclusive of designbasis maximum seismic loads and the hydrodynamic loads that could result frompool sloshing or other effects that could accompany such seismic forces.b) A description of the manner in which the level sensor (and stilling well, ifappropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.

Indicate in aschematic 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 thelevel instrument to permanent SFP structures so as to support the level sensorassembly.

SNC Response to RAI 5:a) The analyses used to verify the design criteria and methodology for seismictesting of the SFP instrumentation and the electronics units, including, designbasis maximum seismic loads and the hydrodynamic loads that could result frompool sloshing or other effects that could accompany such seismic forces areprovided in the 'Westinghouse Status of Spent Fuel Pool Level Instrumentation for the Joseph M. Farley Nuclear Plant" provided in the Attachment.

b) The mounting bracket is attached to the SFP concrete floor utilizing expansion-type concrete anchor bolts. The level sensor consists of a stranded stainless steel cable level probe that is threaded on the top end. The probe attaches(threads) into a coupling that is secured to the mounting bracket launch plateand extends down into the pool. The attachment to the signal cable is via acoaxial connection on the top side of the launch plate coupling.

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

The Farley SFP does not have a raisedconcrete curb and as such, the mounting bracket does not utilize the curb forsupport.E2-2 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Launch Plate¶Coupling(Bottom)Cable Probe -..jc) The level sensor (probe) is attached near its upper end to the mounting bracket,as described in the response to RAI # 3b above. The mounting bracket isattached to the SFP concrete floor utilizing expansion-type concrete anchorbolts. The mounting bracket to the SFP concrete floor anchorage is designed tomeet the requirements of the Farley design and licensing basis for SeismicCategory I components including seismic loads, static weight loads andhydrodynamic loads.NRC RAI 6:For RAI 5(a) above, please provide the analyses used to verify the design criteria andmethodology for seismic testing of the SFP instrumentation and the electronics units,including, design basis maximum seismic loads and the hydrodynamic loads that couldresult from pool sloshing or other effects that could accompany such seismic forces.E2-3 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information SNC Response to RAI 6:The analyses used to verify the design criteria and methodology for seismic testing of theSFP instrumentation and the electronics units, including, design basis maximum seismicloads and the hydrodynamic loads that could result from pool sloshing or other effects thatcould accompany such seismic forces, are provided in the Attachment.

NRC RAI 7:For 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.

SNC Response to RAI 7:The design inputs and methodology used to qualify the structural integrity of the affectedstructures/equipment for each of the mounting attachments required to attach SFP Levelequipment to plant structures are provided in the Attachment.

NRC RAI 8:Please provide the following:

a) A description of the specific method or combination of methods you intend toapply to demonstrate the reliability of the permanently installed equipment underBDB ambient temperature,

humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provideassurance that the equipment will perform reliably under the worst-case credibledesign 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 levelinformation 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 usedto confirm the reliability of the permanently installed equipment such thatfollowing a seismic event the instrument will maintain its required accuracy.

E2-4 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information SNC Response to RAI 8:a) A description of the specific method or combination of methods applied todemonstrate the reliability of the permanently installed equipment under BDBambient temperature,

humidity, shock, vibration, and radiation conditions isprovided in the Attachment.

b) A description of the testing and/or analyses conducted to provide assurance thatthe level sensors will perform reliably under the worst-case credible design basisloading at the location where the equipment is mounted is provided in theAttachment.

Any control boxes, electronics, or read-out and re-transmitting devices employed to convey the level information from the level sensor to theplant operators or emergency responders is installed per DCP, utilizing SiteSSE, and ASME & IEEE codes as described in the Farley FSAR.c) A description of the specific method or combination of methods used to confirmthe reliability of the permanently installed equipment such that following aseismic event the instrument will maintain its required accuracy is provided in theAttachment.

NRC RAI 9:For RAI #8 above, please provide the results for the selected

methods, tests and analysesused to demonstrate the qualification and reliability of the installed equipment inaccordance with the Order requirements.

SNC Response to RAI 9:The results for the selected

methods, tests and analyses used to demonstrate thequalification and reliability of the installed equipment in accordance with the Orderrequirements are provided in the Attachment.

NRC RAI 10:Not Applicable NRC RAI 11:Please provide the NRC staff with the final configuration of the power supply source foreach channel so that the staff may conclude that the two channels are independent from apower supply assignment perspective.

E2-5 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information SNC Response to RAI 11:The Farley power supplies are assigned as follows:Channel PanelU2 Primary N2R22L0002 U2 Backup N1R19L0001G U1 Primary N2R19L0596 U1 Backup NIR19L0582 NRC RAI 12:Please provide the results of the calculation depicting the battery backup duty cyclerequirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.SNC Response to RAI 12:The results of the calculation for determining the battery backup duty cycle requirements necessary to demonstrate its capacity is sufficient to maintain the level indication functionuntil offsite resource availability is reasonably assured are provided in the Attachment.

NRC RAI 13:Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BDB values. Please demonstrate that thechannels will retain these accuracy performance values following a loss of power andsubsequent restoration of power.SNC Response to RAI 13:Analysis verifying that the proposed instrument performance is consistent with theseestimated accuracy normal and BDB values, along with demonstration that the channelswill retain these accuracy performance values following a loss of power and subsequent restoration of power, is provided in the Attachment.

NRC RAI 14:Not Applicable E2-6 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information NRC RAI 15:Please provide the following:

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

b) For any SFP level instrumentation displays located outside the main controlroom, please describe the evaluation used to validate that the display locationcan be accessed without unreasonable delay following a BDB event. Include thetime available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take forpersonnel to access the display.

Additionally, please include a description of theradiological and environmental conditions on the paths personnel might take.Describe whether the display location remains habitable for radiological, heatand humidity, and other environmental

,conditions following a BDB event.Describe whether personnel are continuously stationed at the display or monitorthe display periodically.

SNC Response to RAI 15:a) See Figure 2 for SFPLIS equipment proposed location sketches.

The proposed location of the Ul and U2 Primary display panels is inroom 2452 on EL 155' of the Aux Building.

The proposed location of the Ul andU2 Alternate display panels is in room 345 on EL 139' of the Aux Building.

b) The locations have been evaluated within the DCP considering the accidentconditions described in NEI 12-02 and NEI 12-06, using design inputs fromWestinghouse, existing Station Blackout evaluations and NUMARC-8700, "Guidelines and Technical Bases for NUMARC Initiatives Addressing StationBlackout at Light Water Reactors",

November 20, 1987. The results of theevaluation performed, to determine accessibility of the SFPLI displays following an ELAP event, indicate the displays can be accessed without unreasonable delay and without placing station personnel at undue risk with regards totemperature,

humidity, and radiation levels.The selected location of the Ul and U2 Primary display panels inroom 2452 on EL 155' of the Aux Building is approximately 180 feet from theWest exit of the Control Room. The selected location of the Ul and U2 Alternate display panels in room 345 on EL 139' of the Aux Building is approximately 220feet from the West exit of the Control Room. Using a conservative walking paceof 1 mph, Primary & Alternate display locations would each require less than 10minutes to access the display location, perform local function and return to theControl Room. With the displays located outside the Radiation Controlled Area,the substantial structures between the SFP and the pathway to the display,E2-7 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information combined with the short transient

duration, personnel traveling the pathwaysshown on Figure 2 will not require heroic means with the SFP at Level 3 orabove. The display location remains habitable considering the: (1) minimal timerequired to periodically access the displays, (2) distance from the SFP andsubstantial structures, and (3) the lack of heat producing equipment within theroom during accident conditions.

Accordingly, both the Primary and Alternate SFPLI panel locations allow prompt, non-heroic access to the displays from theControl Room necessary to allow periodic monitoring of the SFP level.NRC RAI 16:Please provide a list of the procedures addressing operation (both normal and abnormalresponse),

calibration, test, maintenance, and inspection procedures that will bedeveloped for use of the SFP instrumentation.

The licensee is requested to include a briefdescription of the specific technical objectives to be achieved within each procedure.

SNC Response to RAI 16:Procedures have been developed to ensure the following objectives:

IProcedure Objectives to be achieved1) System Inspection

2) Calibration and Test3) Maintenance

4) Repair5) Operation

6) Responses To verify that system components are in place,complete, and in the correct configuration, and thatthe sensor probe is free of significant deposits ofcrystallized boric acid.To verify that the system is within the specified

accuracy, is functioning as designed, and isappropriately indicating SFP water level.To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.

To specify troubleshooting steps and component repair and replacement activities in the event ofsystem malfunction.

To provide sufficient instructions for operation anduse of the system plant operation staff.To define the actions to be taken uponobservation of system level indications, including actions to be taken at the levels defined in NEI12-02.E2-8 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information NRC RAI 17:Please provide further information describing the maintenance and testing program thelicensee will establish and implement to ensure that regular testing and calibration isperformed and verified by inspection and audit to demonstrate conformance with designand system readiness requirements.

Include a description of your plans for ensuring thatnecessary channel checks, functional tests, periodic calibration, and maintenance will beconducted for the level measurement system and its supporting equipment.

SNC Response to RAI 17:While the 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 refueling outageconsidering normal testing scheduling allowances (e.g., 25%). Calibration verification willnot be required to be performed more than once per 12 months. These calibration requirements are consistent with the guidance provided in NEI 12-02 section 4.3. Periodiccalibration verification procedures have been developed based on information provided byWestinghouse in WNA-TP-04709-GEN,.

"Spent Fuel Pool Instrumentation SystemCalibration Procedure."

Preventive maintenance procedures include tests, inspection, and periodic replacement of the backup batteries based on recommendations fromWestinghouse.

E2-9 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Figure 1Sketch on section from drawings:

Unit 1: D176039 Unit 2: D2060391mE2-10 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Figure 2Sketch on section of drawing:Aux Building EL 155' Unit 1: D1 76039 Unit 2: D206039Aux Building EL 139' Unit 1: D176038345I IE2-11 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Attachment

-Design Requirements for Structural Integrity and Reliability Westinghouse

1. Topic Summary Reference Additional Comment Test or AnalysisDocument

1. 1 Design Specification SFPIS Requirements WNA-DS-02957-GEN Contains technical SFPIS N/Aderived from requirements based on NRCReferences 1, 2, & 3 order, NEI guidance, and theISG listed above.2 Test Strategy Per Requirements.

WNA-PT-00188-GEN Strategy for performing the N/Atesting and verification of theSFPIS and pool-side bracket.3 Environmental 500 F to 1400 F, EQ-QR-269, Rev. 2 Results are summarized in Test passed conditions qualification for 0 to 95% RH and EQ-QR-269, Rev. 2 and described.

electronics enclosure WNA-TR-03149-GEN WNA-TR-03149-GEN.

with Display for all conditions.

TID < 1E03 R ynormal (outside SFP Radiation Aging verification area) summarized in Section 5 ofWNA-TR-03149-GEN.

TID 5 1E03 R yabnormal (outsideSFP area)4 Environmental 500 F to 212' F and EQ-QR-269, Rev. 2 Testing summarized in PassedTesting for Level 100% humidity Section 5.7.Sensor components in SFP area-Saturated Steam & 1E03 R y normal (SFP WNA-TR-03149-GEN Thermal Aging & radiation PassedRadiation area) aging verification summarized in Sections 4.1 and 5 (entiresystem) of WNA-TR-03149-GEN.E2-12 Enclosure 2 to NL-1 5-0699Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Parameter Westinghouse

1. Topic Summary Reference Additional Comment Test or AnalysisDocumentC#SmResults 1 E07 R y BDB (SFP EQ-QR-269, Rev. 2 Additional radiation aging Passedarea) testing documented inSection 5.3.5 Environmental 500 F to 1400 F, EQ-QR-269, Rev. 2 Testing summarized in PassedTesting for Level 0 to 95% RH Section 5.5.Sensor Electronics Housing -outside 100% RH WNA-TR-03149-GEN 100% humidity addressed in PassedSFP Section 7.5.TID -1E03 R y WNA-TR-03149-GEN Radiation Aging verification Passednormal (outside SFP summarized in Section 5.area)TID< 1E03 R yabnormal (outsideSFP area)6 Thermal & Radiation 1 E03 R y normal (SFP EQ-QR-269, Rev. 2 Thermal Aging & radiation PassedAging -organic area) and WNA-TR-03149-aging verification summarized components in SFP GEN in Sections 4.1 and 5 (entirearea system) of WNA-TR-03149-GEN.1 E07 R y BDB (SFP EQ-QR-269, Rev. 2 Additional radiation aging Passedarea) testing documented inSection 5.3.E2-13 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Parameter Westinghouse Test or Analysis# Topic Reference Additional Comment# opcSummary Dcmn#, Results______________Document'#

7 Basis for Dose SFP Normal LTR-SFPIS-13-35 and Explanation of Basis for Passed for allRequirement Conditions:

WNA-DS-02957-GEN Radiation Dose Requirement conditions 1 E03 R y TID (above (includes the clarification ofpool) production equivalency ofelectronics enclosure used for1E09 R y TOD (1V Seismic and EMC Testing)above fuel rack)SFP BDBEConditions:

1 E07 R y TID (abovepool)< 1E07 R y TID (1'above fuel rack)8 Seismic Qualification Per Spectra in WNA- EQ-QR-269, Rev. 2 Documented in Section 5.4. PassedDS-02957-GEN WNA-TR-03149-GEN WNA-TR-03149-G EN Passedprovides high level summaryof the pool-side bracketanalysis and optional RTD.EQ-QR-269, Rev. 2 Seismic Pull test for new Passedconnectors documented inSection 4.4.9 Sloshing N/A LTR-SEE-1I-13-47 Calculation to demonstrate Passedthat probe will not be sloshedout of the SFP.E2-14 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Parameter

ýWestinghouse

1. Topic Reference Additional Comment Test or AnalysisSummary' Document

1. ResultsWNA-TR-03149-GEN Sloshing is also addressed in PassedSection 7.2.10 Spent Fuel Pool Acceptance Criteria WNA-TP-04613-GEN Test procedure used to See applicable EQ test.Instrumentation for Performance demonstrate that SFPIS meetSystem Functionality during EQ testing its operational and accuracyTest Procedure requirements duringEquipment Qualification Testing programs.

11 Boron Build-Up Per requirement in WNA-TR-03149-GEN Boron build up demonstrated PassedWNA-DS-02957-GEN through Integrated Functional Test (IFT).12 Pool-side Bracket N/A CN-PEUS-14-7, Rev. 1 Also includes hydrodynamic PassedSeismic Analysis forces, as appropriate.

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

and Electronics Enclosure) 14 Shock & Vibration WNA-DS-02957-GEN WNA-TR-03149-GEN Section 7 provides rationale N/Aand summary of RTD.15 Requirements Maps Requirements to WNA-VR-00408-GEN, The RTM maps the CompleteTraceability Matrix documentation

/ Rev. 1 requirements of the NRCevidence that order, NEI guidance, ISG toRequirement is met the applicable technical requirements in the SFPISdesign specification andmaps the design specification requirements to thedocumentation demonstrating the requirement is met.E2-15 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Westinghouse

1. Topic Parameter

-Reference Additional Comment RestsSummary Document

1. Results16 Westinghouse IFT Functional WNA-TP-04752-GEN The Integrated Functional Pilot IFTFactory Acceptance Requirements from Test (IFT) demonstrates executed/passed Test, including testing WNA-DS-02957-GEN functionality of thte full systemof dead-zones for each customer's FAT,which includes calibration of Vogtle functional each channel.

checks executed/

passed12" dead-zone at top WNA-TP-04752-GEN Dead-zone tests are in N/Aof probe Section 9.6.2.4" dead-zone

.atbottom of probe17 Channel Accuracy

+/- 3 inches per WNA- WNA-CN-00301-GEN Channel accuracy from PassedDS-02957-GEN measurement to display.18 Power Consumption 3 day battery life WNA-CN-00300-GEN N/A Passed(minimum) 0.257 Amps powerconsumption 19 Technical Manual N/A WNA-GO-00127-GEN Information and instructions-N/Afor Operation, Installation, use, etc. are included here.20 Calibration Routine WNA-TP-04709-GEN Also, includes preventative N/ATesting/calibration maintenance actions such asverification and those for Boron buildup andCalibration method cable probe inspection.

21 Failure Modes and N/A WNA-AR-00377-GEN Addresses mitigations for the N/AEffects Analysis potential failure modes of the(FMEA) system.E2-16 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information Parameter Westinghouse Test or Analysis# Topic Summary Reference Additional Comment Results____Topi

_____ _ummary_______Document

1. _ _Results22 Emissions Testing RG 1.180 R1 test EQ-QR-269, Rev. 2 Documented in Section 5.6. Passedconditions

References:

1) ML12056A044, NRC Order EA-12-051, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOLINSTRUMENTATION,"

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 toReliable Spent Fuel Pool Instrumentation" August, 2012.3) ML12221A339, Revision 0, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation",

August 29, 2012,Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate.

4) Westinghouse Proprietary

Document, WNA-DS-02957-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System DesignSpecification,"

Revision 4 reviewed by NRC in April 2014; current revision is Revision 4.5) Westinghouse Proprietary

Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy,"

Revision 1 reviewed by NRC in February 2014; NRC did not review in April; current revision is Revision 3.6) Westinghouse Proprietary

Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation,"

Revision 1 reviewed by NRC in April 2014; current revision is Revision 2.7) Westinghouse Proprietary

Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report,"

Revision 1reviewed by NRC in April 2014; current revision is Revision 1.8) Westinghouse Proprietary

Document, LTR-SFPIS-13-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency ofElectronics Enclosure Used for Seismic Testing,"

Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision isRevision 1.9) Westinghouse Proprietary

Document, LTR-SEE-II-13-47, "Determination if the Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out ofthe Spent Fuel Pool during a Seismic Event," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision isRevision 0.10) Westinghouse Proprietary

Document, WNA-TP-04613-GEN, "Spent Fuel Pool Instrumentation System Functionality Test Procedure,"

Revision 5reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 5.11) Westinghouse Proprietary

Document, CN-PEUS-14-7, "Seismic Analysis of the SFP Mounting Bracket at Farley Nuclear Plant and Vogtle ElectricGenerating Station,"

Revision 1; not reviewed by the NRC.12) Westinghouse Proprietary

Document, WNA-VR-00408-GEN, "Spent Fuel Pool Instrumentation System Requirement Traceability Matrix,"Revision 0 reviewed by the NRC in April 2014; current revision is Revision 1.E2-17 Enclosure 2 to NL-15-0699 Joseph M. Farley Nuclear Plant -Unit 1Responses to NRC Requests for Information

13) Westinghouse Proprietary

Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional TestProcedure,"

Revision I reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 2.14) Westinghouse Proprietary

Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis,"

Revision 0reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 2.15) Westinghouse Proprietary

Document, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation,"

Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.16) Westinghouse Proprietary

Document, WNA-GO-00127-GEN, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual,"Revision 1 reviewed by the NRC in April 2014; current revision is Revision 3.17) Westinghouse Proprietary

Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure,"

Revision 3 wasreviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.18) Westinghouse Proprietary

Document, WNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis,"

Revision 2 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.E2-18