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{{Adams
#REDIRECT [[NLS2013091, Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)]]
| number = ML13294A027
| issue date = 10/14/2013
| title = Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)
| author name = Limpias O A
| author affiliation = Nebraska Public Power District (NPPD)
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000298
| license number = DPR-046
| contact person =
| case reference number = EA-12-051, NLS2013091
| document type = Letter
| page count = 7
| project =
| stage = Response to RAI
}}
 
=Text=
{{#Wiki_filter:H Nebraska Public Power District Always there when you need us NLS2013091 October 14, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
 
==Subject:==
Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA- 12-05 1)Cooper Nuclear Station, Docket No. 50-298, DPR-46
 
==References:==
 
I. NRC Order Number EA- 12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 2. NPPD Letter to NRC, Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (NLS2013026)
: 3. Email from Lynnea Wilkins, NRC, to David Van Der Kamp, NPPD, RAIfor Cooper Re: Reliable Spent Fuel Pool Instrumentation Order Response (Overall Integrated Plan) (MF0971), dated September 12, 2013
 
==Dear Sir or Madam:==
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order for Reliable Spent Fuel Pool Instrumentation (SFPI) (Reference
: 1) to Nebraska Public Power District (NPPD). Reference I required submission of a SFPI Overall Integrated Plan (OIP) for Cooper Nuclear Station (CNS) which was provided by Reference
: 2. In Reference 3, the NRC issued a request for information (RAI) regarding the SFPI OIP submitted in Reference 2.The attachment to this letter provides NPPD's response to Reference
: 3. The NRC indicated in Reference 3 that if requested information is not available at the time of submittal, NPPD is to provide the date the information will be submitted.
NPPD has started the design phase for the SFPI OIP and expects to complete the final design by July 2014. Based on this schedule, the RAIs cannot be fully answered at this time. The requested information will be provided in the August 2014, six-month status update, or sooner if available, as indicated in the individual RAI responses.
This letter contains no new regulatory commitments.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone:
(402) 825-3811 / Fax: (402) 825-5211 www.nppd.com NLS2013091 Page 2 of 2 Should you have any questions regarding this report, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.I declare under penalty of perjury that the foregoing is true and correct.Executed on: O -Sincer(7 y, Oscar .Limpias Vice President
-Nuclear and Chief Nuclear Officer/bk
 
==Attachment:==
 
Cooper Nuclear Station's Response to Request for Additional Information for Reliable Spent Fuel Pool Instrumentation (Order EA- 12-051)cc: Regional Administrator, w/attachment USNRC -Region IV Director, w/attachment USNRC -Office of Nuclear Reactor Regulation Cooper Project Manager, w/attachment USNRC -NRR Project Directorate IV-1 Senior Resident Inspector, w/attachment USNRC -CNS NPG Distribution, w/attachment CNS Records, w/attachment NLS2013091 Attachment Page 1 of 5 Attachment Cooper Nuclear Station's Response to Request for Additional Information (RAI) for Reliable Spent Fuel Pool Instrumentation (SFPI) (Order EA-12-051)
Nuclear Regulatory Commission (NRC) RAI-]: Please provide a clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of instrument channel consisting ofpermanent 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 racks. 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.Nebraska Public Power District (NPPD) Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NRC RAI-2: Please provide the following:
a) 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 sensors, and the proposed routing of the cables that will extend from the sensors toward the location of the local electronics cabinets and read-out/display devices in the main control room or alternate accessible location.b) In Figure 1 of your submittal, it appears that the sensors will be separated by a distance comparable to the longest side of the pool, however your text states that they will be "separated by a distance that is comparable to the shortest side of the pool." Please clarify this discrepancy.
NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
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.
NLS2013091 Attachment Page 2 of 5 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.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
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 (BDB) 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 such that following a seismic event the instrument will maintain its required accuracy.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NRC RAI-5: Please provide the following:
a) A description of how the two channels of the proposed level measurement system in each pool meet this requirement so that the potentialfor a common cause event to adversely affect both channels is minimized to the extent practicable.
b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels NLS2013091 Attachment Page 3 of 5 is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NRC RAI-6: Please provide the following:
a) A description of the electrical AC power sources and capacities for the primary and backup channels.b) If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), please provide the design criteria that will be applied to size the batter in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BDB event for the minimum duration needed, consistent with the plant mitigation strategies for BDB external events (Order EA-12-049).
NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NRC RAI-7: Please provide the following:
a) An estimate of the expected instrument channel accuracy performance (e.g., in % of span) 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.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NLS2013091 Attachment Page 4 of 5 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 calibration tests and functional checks will be performed and the frequency at which they will be conducted.
Discuss how these surveillances will be incorporated into the plant surveillance program.d) A description of what preventive 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.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The final design will include aspects such as procedure guidance, maintenance, and testing requirements.
The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NRC RAI-9: Please provide the following:
a) The specific location for the primary and backup instrument channel display.b) If the primary and backup display locations are not in the main control room, please provide a description of the display location that addresses primary and alternate access route evaluation, continuous habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for verbal communications with decision makers for the various SFP drain down scenarios and external events.c) The reasons justifying why the locations selected will enable the information from these instruments to be considered
'"promptly accessible." Include consideration of various drain-down scenarios.
NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The requested information will be provided with the August 2014, six-month status report, or sooner if available.
NLS2013091 Attachment Page 5 of 5 NRC RAI-IO: Please provide the following:
a) A list of the operating (both normal and abnormal response) procedures, calibration/test procedures, maintenance procedures, and inspection procedures that will be developed for use of the spent fuel pool instrumentation in a manner that addresses the order requirements.
b) A brief description of the specific technical objectives to be achieved within each procedure.
Ifyour plan incorporates the use ofportable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable components when needed.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The final design will include aspects such as procedure guidance, maintenance, and testing requirements.
The requested information will be provided with the August 2014, six-month status report, or sooner if available.
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 the plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
b) A description of how the guidance in NEI 12-02 Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of the compensatory actions to be taken in the event that one of the instrument channels cannot be restored to functional status within 90 days.NPPD Response:
NPPD has started the design phase for the SFPI Order and expects to have final design completion by July 2014. The final design will include aspects such as procedure guidance, maintenance, and testing requirements.
The requested information will be provided with the August 2014, six-month status report, or sooner if available.}}

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