ET 15-0014, Operating Corporation'S Compliance Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Operating Corporation'S Compliance Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

ML15190A337
Person / Time
Site:	Wolf Creek
Issue date:	06/30/2015
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, ET 15-0014
Download: ML15190A337 (30)

Text

WVp-LEF CREEK

'NUCEAROPERATING CORPORATION Jaime H. McCoy Vice President Engineering June 30, 2015 ET 15-0014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1) Letter dated March 12, 2012, from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation"

2) NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation,"

Revision 0, dated August 29, 2012

3) NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," Revision 1, dated August 2012

4) Letter ET 12-0028, dated October 29, 2012, from J. P. Broschak, WCNOC, to USNRC

5) Letter WO 13-0015, dated February 28, 2013, from R. A. Smith, WCNOC, to USNRC

6) Letter ET 13-0026, dated August 28, 2013, from J. P. Broschak, WCNOC, to USNRC

7) Letter ET 14-0010, dated February 26, 2014, from J. P. Broschak, WCNOC, to USNRC

8) Letter ET 14-0025, dated August 21, 2014, from C. 0. Reasoner, WCNOC, to USNRC

9) Letter ET 15-0006, dated February 24, 2015, from J. H. McCoy, WCNOC, to USNRC

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's Compliance Report for the Implementation of Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"

.4oDl P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET

ET 15-0014 Page 2 of 4 Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Wolf Creek Nuclear Operating Corporation (WCNOC). Reference 1 was immediately effective and directs WCNOC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an Overall Integrated Plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 4 provided the WCNOC initial status report for Wolf Creek Generating Station (WCGS) regarding mitigation strategies, as required by Reference 1. Reference 5 provided the WCNOC OIP. References 6, 7, 8, and 9 provided the first, second, third, and fourth six-month status report for the implementation of Order EA-1 2-051, respectively.

Reference 1 requires submission of a report to the NRC when full compliance with the requirements described in Attachment 2 or Attachment 3 of Reference 1 is achieved. The purpose of this letter is to provide the full compliance report pursuant to Section IV, Condition C.3, of Reference 1. The report in Attachment I of this letter provides the full compliance report.

Attachment II of this letter transmits responses to the NRC Request for Additional Information (RAI) as described in Attachment I. Attachment III contains the design bridge document comparing the instrumentation vendor assumptions to the site.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4171, or Mr. Bill T. Muilenburg at (620) 364-4186.

Sincerely, Jaime H. McCoy JHM/rlt Attachments: I Wolf Creek Nuclear Operating Corporation's Spent Fuel Pool Instrumentation Compliance Report in Response to Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation" II Wolf Creek Nuclear Operating Corporation's Response to Request for Additional Information III Wolf Creek Nuclear Operating Corporation's Design Bridge Document

ET 15-0014 Page 3 of 4 cc: M. L. Dapas (NRC), w/a C. F. Lyon (NRC), w/a A. A. Rosebrook (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 15-0014 Page 4 of 4 STATE OF KANSAS ))ss COUNTY OF COFFEY )

Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Jaime H. cCoy Vice Pre ident Engineering SUBSCRIBED and sworn to before me this 96 day of .ZJ./ ,2015.

-* GAYLE SHEPHEARDl Noar blic

ŽL&-,J E Notary Public - State of Kansas My Ap~t. Expir To Expiration Date____________

Attachment I to ET 15-0014 Page 1 of 3 Wolf Creek Nuclear Operating Corporation's Spent Fuel Pool Instrumentation Compliance Report in Response to Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation"

1. Introduction Wolf Creek Nuclear Operating Corporation (WCNOC) developed an Overall Integrated Plan (OIP) (Reference 1), documenting the modification with regard to Reliable Spent Fuel Pool (SFP) Instrumentation in response to Reference 2. Reference 2 directed licensees to implement reliable means of remotely monitoring wide-range Spent Fuel Pool (SFP) levels to support effective prioritization of event mitigation and recovery actions in the event of a beyond-design-basis external event.

This attachment documents full compliance with the requirements described in Attachments 2 and 3 of Reference 2.

2. Request for Additional Information (RAI) Resolution The Nuclear Regulatory Commission (NRC) issued an initial set of Requests for Additional Information (RAI)'s in Reference 3. WCNOC provided responses to the RAI in Reference 4.

Subsequently, the NRC issued an Interim Staff Evaluation (ISE) and a RAI (Reference 5) regarding the OIP (Reference 1), on October 29, 2013. Reference 6 announced the transition to an audit based review process, and notified each licensee participating in the audit not to formally submit their RAI response on the docket but, instead, put their response and any other supporting information on their ePortals by the date identified in their ISE to support the staffs review process. Attachment II to this letter provides the response to the RAI (Reference 5).

3. Milestone Schedule Status The following table lists the milestones identified in the OIP (Reference 1). The table reflects the status of each milestone on the required compliance date, May 3, 2015, when the unit startup was commenced.

Attachment I to ET 15-0014 Page 2 of 3 Milestone Activity Status Commence Engineering and Design Complete Complete Generic Design Complete Submit 6 Month Updates:

Update 1 Complete Update 2 Complete Update 3 Complete Update 4 Complete Receipt of SFP Instruments Complete Complete Site Specific Design Complete Complete SFP Instrumentation Procedures Complete

& Training SFP Instruments Operational Complete

4. Summary of Compliance Elements for Order EA-12-051 WCNOC compliance with Order EA-12-051 was achieved using the guidance in Nuclear Energy Institute (NEI) document NEI 12-02 (Reference 7) which has been endorsed by the NRC (Reference 8). The significant compliance elements were addressed as described below.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE WCNOC has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051, as indicated on Reference 9.

INSTRUMENT DESIGNED FEATURES - COMPLETE The design of the instruments installed at WCGS comply with the requirements specified in Order EA-12-051 and described in NEI 12-02. The instruments have been installed in accordance with the station configuration control process.

The instruments have been arranged to provide reasonable protection against missiles. The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable for environmental and radiological conditions when the SFP is at saturation for extended periods.

PROGRAM FEATURES - COMPLETE Training for WCNOC has been completed in accordance with an accepted training process as recommended in Section 4.1 of Reference 7.

Operating and maintenance procedures are developed and integrated with existing site processes for WCGS.

Attachment I to ET 15-0014 Page 3 of 3

References:

1. WCNOC Letter WO 13-0015, "Wolf Creek Nuclear Operating Corporation Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements For Reliable Spent Fuel Pool Instrumentation (Order EA-12-051," February 28, 2013. ADAMS Accession No. ML13071A419.

2. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," March 12, 2012. ADAMS Accession No. ML12054A679.

3. Letter from C. F. Lyon, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Request for Additional Information RE: Overall Integrated Plan in Response to Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation' (TAC NO. MF0781),"

July 17, 2013. ADAMS Accession No. ML13197A205.

4. WCNOC Letter ET 13-0025, "Wolf Creek Nuclear Operating Corporation's Response to Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Level Instrumentation (Order EA-12-051)," August 15, 2013. ADAMS Accession No. ML13232A008.

5. Letter from C. F. Lyon, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0781)," October 29, 2013. ADAMS Accession No. ML13295A681.

6. Letter from J. R. Davis, USNRC, to A. C. Heflin, WCNOC, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051," March 26, 2014. ADAMS Accession No. ML14083A620.

7. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," Revision 1, August 2012. ADAMS Accession No. ML122400399.

8. JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, August 29, 2012. ADAMS Accession No. ML12221A339.

9. Wolf Creek Drawing J-481A-00071, Revision W01, "Full Range Level Measurement."

Attachment II to ET 15-0014 Page 1 of 11 Wolf Creek Nuclear Operating Corporation's Response to Request for Additional Information Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) Overall Integrated Plan (OIP). Reference 2 provided a Nuclear Regulatory Commission (NRC) Interim Staff Evaluation and Request for Additional Information (RAI) related to the OIP. Provided below are the responses to the questions in Reference 2. The specific request is provided in italics followed by WCNOC's response.

RAI No. 1 Pleaseprovide the results of the calculation used to determine the water elevation necessary for the pump's requiredNPSH to confirm that Level 1 has been adequately identified.

Response: The existing calculation, EC-48, "Minimum Safety Limit for LSL-57 & 58"concludes that the Spent Fuel Pool (SFP) water elevation that is sufficient for the pump's required Net Positive Suction Head (NPSH) is EL. 2043'-6". Level 1 indication is at the normal SFP water operating level of EL. 2046'-0". This confirms that Level 1 has sufficiently covered the calculated level to maintain the pump's required NPSH.

RAI No. 2 Please provide the following:

a) The plant-specific performance evaluation result and a brief summary of the proposed wireless technology that will be used in the primary and backup measurement systems to addressthe criteriasummarized in Section 3. 1 of NEI 12-02.

b) A description of the proposed wireless SFP instrumentation connections. Indicate whether the proposed SFP wireless instrumentation will use an existing wireless network or would use a dedicatedpoint-to-point transmissionpath.

c) Furtherinformation on how the proposed SFP wireless instrumentation will be designed and installed to address electromagnetic interference/radiofrequency interference (EMIIRFI) emissions/susceptibilityissues under BDB event conditions.

d) A description of the manner by which the proposed SFP wireless instrumentation will be operable and available under BDB event conditions.

Response: For items a) through d) above, WCNOC has opted to use hardwired Spent Fuel Pool Instrumentation System (SFPIS) instead of wireless during final design development.

RAI No. 3 Please provide additional information describing how the proposed arrangementof the routing of the cabling between the sensor probes in the SFP to the wireless transmitters meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.

Attachment II to ET 15-0014 Page 2 of 11 Response: The primary element is located at the North end of the pool at the East corner. The element terminates into a 90 degree metal coupler. The coupler is connected into liquid tight EMI/RFI resistant flex conduit, transitioning into rigid metal conduit. The rigid metal conduit is first routed horizontally close to the fuel pool floor and then routed vertically, up the North wall before turning West and running horizontally before exiting the fuel handling building into the auxiliary building.

The backup element is located at the North end of the pool at the West corner. Like the primary element, the backup element terminates into a 90 degree metal coupler. The coupler is connected into liquid tight EMI/RFI resistant flex conduit, transitioning into rigid metal conduit.

The rigid metal conduit is first routed horizontally close to the fuel pool floor and maintains this above floor level route before turning West and running horizontally before exiting the fuel handling building into the auxiliary building.

A separation distance of greater than 16' is maintained between primary and backup conduits routed in the fuel handling building.

By routing primary and backup cables in flex and rigid conduit and providing significant physical separation between primary and backup cables in the fuel handling building, missiles will not disable both primary and backup systems of the SFPIS.

RAI No. 4 Please provide the results of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

Response: Analysis results: The mounting bracket for the sensing probe was designed according to the plant design basis for Safe Shutdown Earthquake (SSE) seismic hazard curve at the pool deck elevation. Loads that were considered in the evaluation of the bracket and its mounting are: 1) Static loads including the dead weight of the mounting bracket in addition to the weight of the level sensing instruments and cabling; 2) Dynamic loads including the seismic load due to excitation of the instruments dead weight in addition to the hydrodynamic effects resulting from the excitation of the SFP water.

A response spectra analysis was performed for the seismic evaluation of the mounting bracket using GT STRUDL. Hydrodynamic effects on the mounting bracket were evaluated using Reference 5 and added to the GT STRUDL model. Plant acceptance criteria and applicable codes were used for the design of the bracket and its anchorage. All members' results were shown to be adequate for the loads and load combinations used in the analysis. Welded and bolted connections were evaluated and were shown to be adequate with significant margin.

Base plate of the mounting bracket and anchorage to concrete were evaluated using Plate Wizard in GT STRUDL and designed to meet the plant criteria for base plates and anchors.

Seismic testinq results: Seismic testing results analyses are provided in the response for RAI 8.

The seismic testing for the Westinghouse SFPIS demonstrated that the SFPIS operates reliably per the seismic requirements.

RAI No. 5 For each of the mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structuralintegrity of the affected structures/equipment.

Attachment IIto ET 15-0014 Page 3 of 11 Response: The design input and qualification methodology is consistent with the current seismic design for existing plant structures/equipment. As stated in Reference 6, industry standards, such as those published by the American Society for Testing and Materials (ASTM),

are used whenever possible to specify material properties, testing procedures, fabrication, and construction methods. The applicable standards used within the Auxiliary and Fuel Building are discussed in Reference 6, Section 3.8.3.6. For example, embedded anchor bolt materials conform to the applicable requirements of ASTM A540 for Alloy Steel bolting Materials for Special Applications.

The mounting attachments are qualified by analysis. With the exception of the level sensor probe mounting bracket, all the system equipment is seismically qualified by testing. The outputs of the seismic test of all equipment were used as the design input for the qualification of the mounting for that specific equipment.

The mounting bracket for the sensing probe was designed according to the plant design basis for SSE seismic hazard curve at the appropriate plant elevation. Loads that were considered in the evaluation of the bracket and its mounting are: 1) Static loads including the dead weight of the mounting bracket in addition to the weight of the level sensing instruments, pipe guard and cabling; 2) Dynamic loads including the seismic load due to excitation of the dead weight of the system in addition to the hydrodynamic effects resulting from the excitation of the SFP water.

A response spectra analysis was performed for the seismic evaluation of the mounting bracket using Finite Element Analysis (FEA) software and using floor response spectrum at the operating deck elevation. Hydrodynamic effects on the mounting bracket were evaluated using Reference 5. Plant acceptance criteria and applicable codes were used for the design of the bracket and its anchorage.

RAI No. 6 Please provide the following:

a) Information describing the temperature ratings for all system electronics (including sensor electronics, system electronics, level and wireless transmitter, wireless receiver and display) and whether the ratingsare continuous duty ratings; and, b) Information describing what will be the maximum expected temperature and relative humidity conditions in the room(s) in which the sensor electronics and wireless technologies will be located under BDB conditions in which there is no ac power available to run Heating Ventilation and Air Conditioning(HVAC) systems.

c) Analysis of the maximum expected radiologicalconditions (dose rate and total integrated dose) to which the equipment will be exposed. Also, please provide documentation indicating the radiological dosage amount that the electronics for this equipment is capable of withstanding. Please discuss the time period over which the analyzed total integrateddose was applied.

Attachment II to ET 15-0014 Page 4 of 11

Response

a) Components in the Fuel Building (the probe, cable assembly and coupler for the level sensors) are qualified for Beyond Design Basis (BDB) conditions of 212°F at atmospheric pressure.

For components in the Auxiliary Building, the sensor electronics are rated for and were tested at 140°F at atmospheric pressure.

These ratings are continuous duty ratings.

b) The equipment qualifications delineated in Reference 7 are not exceeded in the location of the sensor electronics.

Qualitatively, due to the lack of water sources in the rooms, the increasing temperatures in the rooms will cause the relative humidity of the rooms to decrease relative to their starting humidity.

There is no non-Heating Ventilation and Air Conditioning (HVAC) flowpath into the Auxiliary Building HVAC Area rooms (Room 1501 and Room 1512) or Personal Hatch Area (Room 1507), so there will be minimal outside influence to the room humidity if the HVAC fails.

The sensor electronics are located at the 2047' elevation in the Auxiliary Building Control Room HVAC Equipment Rooms (Room 1501 and Room 1512) and the Personal Hatch Area (Room 1507). There are no high energy lines located on the 2047' elevation of the Auxiliary Building. The sensor electronics are rated for humidity of 0-95% (non-condensing). The normal temperature for these three rooms is 104 0 F. Without ventilation and no significant heat sources, the temperatures will not exceed the 140°F temperature used by Westinghouse as the operating temperature of the equipment.

The Fuel Building is connected to the Auxiliary Building on the 2047' elevation by a pressure door (Door 15071). As a pressure boundary door, it is designed to limit leakage. Leakage through the pressure boundary door would be diluted by the large volume of the hallways. Therefore, environmental conditions in Rooms 1501, 1507, and 1512 are expected to remain within equipment qualification parameters.

Components in the Fuel Building (level sensors and their respective cables) are qualified for BDB conditions of 100% humidity (saturated steam).

c) A summary of the radiological conditions to which the equipment is qualified is provided below. Vendor tests and analysis demonstrating the qualifications of the equipment installed are detailed in Westinghouse proprietary documents References 9 and 10.

Radiologqical conditions for the SFPIS components in the SFP area:

The coaxial cable, the coupler, the pool-side bracket, and the probe in the SFP area are required to operate reliably in the service radiological conditions specified in the table below.

Attachment II to ET 15-0014 Page 5 of 11 Parameter Normal Beyond Design Basis Radiation Total Integrated 1E03 Rads y 1E07 Rads y Dose (TID) (above pool)

Radiation TID (12" above < 1E09 Rads y (probe 1E07 Rads y top of fuel rack) & weight only) II The SFP area radiological conditions are detailed in Reference 9.

Radioloqical conditions outside of the SFP area:

The level sensor electronics, sensor electronics bracket, indicators, and the electronics enclosures outside of the spent fuel pool area are required to operate reliably in the service environmental conditions specified in the table below.

Parameter Normal Beyond Design Basis Radiation TID < 1E03 Rads y < 1E03 Rads y There are no active electronics in the Fuel Building. The transmitter electronics are physically located in the Auxiliary Building and therefore are not subjected to the same post-event (BDB) radiological conditions as identified in Section 3.4, "Qualifications" of Reference 11.

During a BDB event, the expected radiological conditions (dose rate and total integrated dose) in the Auxiliary Building are consistent with normal operating conditions identified in Attachment A and Attachment B of Reference 12 based on the following:

• During a BDB event, the Reactor Coolant System remains intact and the Mitigating Strategies per EA-12-049 maintain core cooling.

• SFP makeup capabilities (>250 gpm) exceed calculated full core offload boil off of approximately 136 gpm.

RAI No. 7 Please provide the following:

a) Information describing the evaluation of the sensor electronics design, the shock test method, test results, and forces applied to the sensor electronics applicable to its successful tests demonstrating that the testing provides an appropriate means to demonstratereliability of the sensor electronics under the effects of severe shock.

b) Information describing the evaluation of the sensor electronics design, the vibration test method, test results, the forces and their frequency ranges and directions applied to the sensor applicable to its successful tests, demonstrating that the testing provides an appropriatemeans to demonstrate reliability of the sensor electronics under the effects of high vibration.

Attachment II to ET 15-0014 Page 6 of 11 Response: Reference 13 documents an audit by the NRC of the Westinghouse SFP Instrumentation in support of the review of the Watts Bar Nuclear (WBN) Plant Integrated Plan in response to Order EA-12-051. Reference 13 states, "The review of the audit activities and results summarized in this report apply to WBN and other licensees using Westinghouse's level instrumentation technology."

a) Item 5 of Reference 13 provides information describing the evaluation of the sensor electronics design, the shock test method, test results, and forces applied to the sensor electronics applicable to its successful tests.

b) Item 5 of Reference 13 provides information describing the evaluation of the sensor electronics design, the vibration test method, test results, the forces and their frequency ranges and directions applied to the sensor applicable to its successful tests.

RAI No. 8 Please provide analysis of the seismic testing results and show that the instrument (including wireless technology) performance reliability, following exposure to simulated seismic conditions representative of the environment anticipatedfor the SFP structures at Wolf Creek Generating Station has been adequately demonstrated. Include information describing the design inputs and methodology used in any analyses of the mountings of electronic equipment onto plant structures,as requested in RAI No. 4 above.

Response: Item 2 of the audit report enclosed with Reference 13 addresses the seismic testing results.

RAI No. 9 Please provide the NRC staff with the final configuration of the power supply source for each channel so that the staff may conclude that the two channels are independent from a power supply assignmentperspective.

Response: The primary and backup SFPIS channels are powered by separate Alternating Current (AC) buses. One of the channels is powered by Class 1E electrical bus NG01A via non-Class 1 electrical panel PN07, while the other channel is powered by Class 1E electrical bus NG02A via non-Class 1 electrical panel PN08.

Each SFPIS channel of equipment has an independent Uninterruptible Power Supply (UPS) with 24V battery backup that ensures at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of battery power without AC.

Additionally, an interface is provided for an alternate power supply, such as a FLEX generator.

The SFP level can be continuously monitored for at least 3 days under station blackout conditions with battery power only and for the required 7 days with an alternate power supply (References 14, 15, and 16).

RAI No. 10 Please provide the following:

a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

Attachment IIto ET 15-0014 Page 7 of 11 b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availabilityis reasonablyassured.

Response

a) The primary and backup SFPIS channels are powered by separate AC buses. One of the channels is powered by Class 1E electrical bus NG01A via non-Class 1 electrical panel PN07, while the other channel is powered by Class 1 E electrical bus NG02A via non-Class 1 electrical panel PN08.

Each SFPIS channel of equipment has an independent UPS with 24V battery backup that ensures at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of battery power without AC. Additionally, an interface is provided for an alternate power supply, such as a FLEX generator. The SFP level can be continuously monitored for at least 3 days under station blackout conditions with battery power only and for the required 7 days with an alternate power supply (References 14, 15, and 16).

b) Power consumption calculation Reference 18 demonstrates that the SFPIS will last for greater than 3 days from a fully charged battery after AC power loss. The calculation includes design and aging margin.

RAI No. 11 Please provide the following:

a) An estimate of the expected instrument channel accuracy performance under both (a) normal SFP level conditions (approximately Level I or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 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 calibrationprocedure to flag to operators.

Response

a) Channel accuracy for each SFPIS instrument channel is +/- 3 inches for the full level measurement span. This span extends from the normal SFP surface level or higher to within six inches of the fuel assembly under both normal and BDB conditions. More details describing measurement accuracy are described in References 7 and 19.

Attachment II to ET 15-0014 Page 8 of 11 b) Channel accuracy requirements are identified in Reference 7 and demonstrated by Reference 19. Both SFP primary and backup redundant sensor electronics require periodic calibration verification to check that the channel's measurement performance is within the specified tolerance (+/- 3 inches). If the difference is larger than the allowable tolerance during the verification process, an electronic output calibration will be required.

If the electronic output calibration does not restore the performance, a troubleshooting Work Request will be generated for further adjustments or parts replacement.

The electronic output verification/calibration will verify electronics are working properly using simulated probe signals.

The calibration adjustment is performed to restore level measurement accuracy to within the acceptance criteria at 0%, 25%, 50%, 75%, and 100% points of the full span.

The calibration verification and calibration acceptance criteria and procedures are defined in the proprietary Westinghouse procedure Reference 20.

RAI No. 12 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 SPF level instrumentation.

c) A description how calibration tests and functional checks will be performed and the frequency at which they will be conducted. Please discuss how these surveillances will be incorporatedinto the plant surveillanceprogram.

d) A description 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.

Response

a) Reference 13 documents an audit by the NRC of the Westinghouse SFP Instrumentation in support of the review of the Watts Bar Nuclear (WBN) Plant integrated plan in response to Order EA-12-051. Reference 13 states, "The review of the audit activities and results summarized in this report apply to WBN and other licensees using Westinghouse's level instrumentation technology." Item 6 of Reference 13 describes the capability and provisions the proposed level sensing equipment will have.

Attachment IIto ET 15-0014 Page 9 of 11 b) Channel comparisons, comparing level indication on one channel against the level indication on the other channel, will be performed on a daily basis.

c) The SFPIS calibration tests and functional checks are summarized in part a) above and in more detail in Reference 20. The periodic calibration tests and functional checks will be performed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g., 25%). This calibration check is not required to be performed more than once per 12 months.

d) Preventive maintenance tasks include the periodic calibration tests and functional checks described above. These tasks will be performed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g., 25%).

Additionally, this task will inspect the probe to ensure no frays or nicks have occurred since the last task performance and to remove any significant accumulation of boron.

The indication and other electronics will also be checked or calibrated at the same frequency as the functional checks described in the response to c) above.

RAI No. 13 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 readinessrequirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration,and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of the in-situ calibrationprocess at the SFP location that will result in the channel calibrationbeing maintainedat its design accuracy.

c) A description of what compensatory actions are planned in the event that the non-functioning instrument channel cannot be restored to functional status within 90 days.

Response

a) The maintenance and testing program will ensure that regular testing and calibration is performed and verified. Calibration and testing for the instruments will be based on Reference 20, as adapted to specific site procedures.

Site specific procedures will define the periodicity for Operator rounds to compare the primary and backup instrument channel indications to determine if more immediate action is required for calibration, maintenance or compensatory action implementation.

The periodic testing recommended to validate the functionality of the installed instrument channel will be performed within 60 days of a planned refueling outage with a normal testing allowance of 25% but not more than once per 12 month period.

b) Reference 13 documents an audit by the NRC of the Westinghouse SFP Instrumentation in support of the review of the Watts Bar Nuclear (WBN) Plant integrated plan in response to Order EA-12-051. Reference 13 states, "The review of the audit activities and results summarized in this report apply to WBN and other licensees using

Attachment II to ET 15-0014 Page 10 of 11 Westinghouse's level instrumentation technology." Item 6 of Reference 13 addresses the in-situ calibration process.

c) If the non-functioning instrument channel cannot be returned to service within the 90 day period, enhanced monitoring through operator rounds will be performed to compare the available instrument channel indications to existing SFP level. The determination for time frames for enhanced monitoring will be defined as procedure development is finalized.

References:

1. WCNOC Letter WO 13-0015, "Wolf Creek Nuclear Operating Corporation Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements For Reliable Spent Fuel Pool Instrumentation (Order EA-12-051," February 28, 2013. ADAMS Accession No. ML13071A419.

2. Letter from C. F. Lyon, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station - Interim Staff Evaluation and Request for Additional Information Regarding Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC No. MF0781)," October 29, 2013. ADAMS Accession No. ML13295A681.

3. Bechtel Calculation, EC-48, "Minimum Safety Limit for LSL-57 & 58."

4. GTSTRUDL, Structural Design & Analysis Software.

5. TID-7024, "Nuclear Reactors and Earthquakes," dated 1963.

6. Wolf Creek Updated Safety Analysis Report (USAR), Rev. 28 (03/11/2015)

7. Westinghouse Proprietary Document WNA-DS-02957-GEN, Revision 4; Wolf Creek Document Number J-481A-00043.

8. Specification A-081, Pressure Resistant Doors

9. Westinghouse Proprietary Document WNA-TR-03149-GEN; Wolf Creek Document Number J-481 A-00052.

10. Westinghouse Proprietary Document EQ-QR-269; Wolf Creek Document Number J-418A-00032.

11. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," Revision 1.

12. Wolf Creek Equipment Qualification Design Basis Document EQSD-1.

13. Tennessee Valley Authority Letter "Watts Bar Nuclear Plant, Units 1 and 2 - Report for the Westinghouse Audit in Support of Reliable Spent Fuel Instrumentation Related to Order EA-12-051 (TAC NOS. MF0951 and MF1178)," August 18, 2014. ADAMS Accession No. ML14211A346.

14. Wolf Creek Drawing E-11PNO1, Revision 5, "Instrument A.C. Power (Non Class 1E PWR System)."

15. Wolf Creek Drawing E-13PNO1, Revision 19, "Non-Class 1E Instrument AC Three-Line Meter & Relay Diagram."

Attachment IIto ET 15-0014 Page 11 of 11

16. Wolf Creek Drawing E-13PN01A, Revision 24, "Non Class 1E Instrument AC Three-Line Meter & Relay Diagram."

17. IEEE Standard 323-2003, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations."

18. Westinghouse Proprietary Document, WNA-CN-00300-GEN; Wolf Creek Document Number J-481A-00040.

19. Westinghouse Proprietary Document, WNA-CN-00301-GEN; Wolf Creek Document Number J-481A-00041.

20. Westinghouse Proprietary Document, WNA-TP-04709-GEN; Wolf Creek Document Number J-481A-00049.

Attachment III to ET 15-001 Page 1 of 12 Wolf Creek Nuclear Operating Corporation's Design Bridge Document Parameter Westinghouse Test or Analysis Licensee Evaluation PSummary Reference Additional Comment Results Document #

1 Design Spent Fuel Pool WNA-DS-02957- Contains technical N/A Wolf Creek Nuclear Operating Specification Instrumentation GEN SFPIS requirements Corporation (WCNOC) has determined System (SFPIS) based on Nuclear that WNA-DS-02957-GEN bounds the Requirements Regulatory Commission Wolf Creek Generating Station (WCGS) derived from (NRC) order, Nuclear requirements from References 1, 2, References 1, 2, Energy Institute (NEI) and 3.

and 3 guidance, and the Interim Staff Guidance (ISG) listed.

2 Test Strategy Per Requirements WNA-PT-00188- Strategy for performing N/A WCNOC has determined WNA-PT-GEN the testing and 00188-GEN to be acceptable for the verification of the SFPIS current design.

and pool-side bracket.

3 Environmental 50°F to 140°F EQ-QR-269 and Results are summarized Test passed Temperature is < 140°F and humidity is Qualification for WNA-TR-03149- in EQ-QR-269 and conditions 5 95% RH for abnormal conditions in Electronics 0 to 95% relative GEN for all WNA-TR-03149-GEN. described. Room 1501 and Room 1512 of the Enclosure with humidity (RH) conditions. Auxiliary Building (Reference 4). The Display above values are bounded by the values in Section 3.3 of WNA-TR-03149-GEN.

Total Integrated EQ-QR-269 and Radiation aging Test passed The normal and abnormal TID of < 1E3 Dose (TID) 5 1E3 WNA-TR-03149- verification summarized conditions R y from Reference 4 for Auxiliary R y normal GEN for all in Section 5 of WNA- described. Building Room 1501 and Room 1512, (outside Spent conditions. TR-03149-GEN is bounded by the justification for TID Fuel Pool (SFP)) less than 1E3 Rad from Section 5.1.3

Attachment III to ET 15-001 Page 2 of 12 Westinghouse Test or Analysis Parameter Reference Additional Comment Results Licensee Evaluation STopic Summary Document #

area) of WNA-TR-03149-G EN.

TID 1E3 R y Aging Tests - Westinghouse has abnormal (outside completed its aging qualification of SFP area) SFPIS to 10 years. Westinghouse has provided an interim position regarding the aging qualification and the open item from Steris. WCNOC will complete the test report reviews when provided.

4 Environmental 50'F to 212'F and EQ-QR-269 Testing summarized in Passed The temperature and humidity values of Testing for Level 100% humidity Section 5.7 of EQ-QR- 212'F and 100% RH from Reference 5 Sensor 269, with additional are bounded by Section 3.2 of WNA-Components in clarifications/explanation TR-03149-GEN.

SFP Area - in Section 5.2 of WNA-Saturated Steam TR-03149-GEN and

& Radiation LTR-SFPIS-1 5-34.

1E3 R y normal WNA-TR-03149- Thermal aging and Passed The generic radiation analysis (SFP area) GEN radiation aging documented in WNA-TR-03149, verification summarized Section 5.0, contains significant in Sections 3 and 4 conservatism with the intention to (entire system) of WNA- bound sites installing the system. The TR-03149-GEN. normal operating dose in the SFP area determined in Section 5.1.2 of WNA-TR-03149-GEN is 1E3 R y. Justification that the system components are inherently resistant to radiation effects is provided in Section 5.1.1 of WNA-TR-03149-GEN.

1E7 R y BDB EQ-TP-354 Additional thermal and Additional aging The Beyond Design Basis (BDB)

(SFP area) (procedure) radiation aging program is in radiation value to which the EQ-QR-269 (10 programs were progress to Westinghouse equipment is qualified to

Attachment III to ET 15-001 Page 3 of 12

1. opcParameter Westinghouse Test or Analysis To Summary Reference Document # Additional Comment Results Licensee Evaluation year completed under rest achieve longer is 1E9 R y for the probe, stainless steel thermal/radiation procedure EQ-TP-354. life. cable and weight and 1 E7R y for the testing completed) The results are captured equipment above the pool, per Section in Sections 5.2 and 5.3 5.1.2 of WNA-TR-03149-GEN. This of EQ-QR-269 with generic analysis contains significant additional conservatism with the intention of clarification/explanation bounding plants installing this system.

in Sections 3 and 4 of With SFP water level at Level 3, the WNA-TR-03149-GEN only components of the SFPIS that are and LTR-SFPIS-1 5-34. exposed to high radiation are the stainless steel probe and the stainless steel anchor. The materials with which the probe and the anchor are manufactured are resistant to radiation effects.

The justification that the system components are inherently resistant to radiation effects is provided in Section 5.1.1 of WNA-TR-03149-GEN.

10466-J-830 states that the TID basis for all electrical equipment and instrumentation outside of containment is 1E7 R. Section 5.3 of EQ-QR-269 demonstrates that the test specimens were subjected to a minimum TID of 11.00 Mrad. Section 5.1.1 of WNA-TR-03149-GEN states that "Westinghouse engineering evaluation saw no reasonable way to exceed 10 MR for the beyond design basis TID."

Aging Tests - Westinghouse completed its aging qualification of SFPIS to 10 vears. Westinghouse has Drovided an

Attachment III to ET 15-001 Page 4 of 12 Parameter Westinghouse Test or Analysis Topic Summaryam Reference Additional Comment Results Licensee Evaluation opic Summary Document # eut interim position regarding the aging qualification and the open item from Steris. WCNOC will complete the test report reviews when provided.

5 Environmental 50°F to 140'F EQ-QR-269 Testing summarized in Passed Temperature is < 140°F and the Testing for Level Section 5.5 of EQ-QR- humidity is -<95% RH for abnormal Sensor 0% to 95% RH 269 with additional conditions in Auxiliary Building Electronics clarifications/explanation Personal Hatch Area Room 1507 from Housing - Outside in Section 5.2 of WNA- Reference 4. The above values are SFP TR-03149-GEN and bounded by the values in Section 3.3 of LTR-SFPIS-1 5-34. WNA-TR-03149-GEN.

100% RH WNA-TR-03149- 100% humidity Passed The humidity is < 100% RH for GEN addressed in Section abnormal conditions in Auxiliary 7.5 of WNA-TR-03149- Building Personal Hatch Area Room GEN 1507 from Reference 4.

TID < 1E3 R y WNA-TR-03149- Radiation aging Passed The normal and abnormal TID of normal (outside GEN verification summarized < 1E3 R y from Reference 4 (for SFP area) in Section 4 of WNA- Auxiliary Building Personal Hatch Area TR-03149-GEN Room 1507) is bounded by Section TID < 1E3 R y 5.1.3 of WNA-TR-03149-GEN.

abnormal (outside SFP area) 6 Thermal & 1E3 R V normal EQ-QR-269 and Thermal aging & Passed WCNOC has determined EQ-QR-269 Radiation Aging - (SFP area) WNA-TR-03149- radiation aging and WNA-TR-03149-GEN to be Organic GEN verification summarized acceptable for WCGS installation. See Components in in Sections 5.2 and 5.3 response to Item 4 above.

SFP Area of EQ-QR-269 and Sections 3 and 4 (entire system) of WNA-TR-03149-GEN

Attachment III to ET 15-001 Page 5 of 12 Parameter Westinghouse Test or Analysis Licensee Evaluation

1. Topic Sumara e Reference Additional Comment Results cSummary Document #

1E7 R y Beyond EQ-TP-354 Additional thermal and Additional aging Aging Tests - Westinghouse completed Design Basis (procedure) radiation aging program was its aging qualification of SFPIS to 10 Event (BDBE) EQ-QR-269 (10 programs were completed to years. Westinghouse has provided an (SFP area) year completed under rest achieve longer life interim position regarding the aging thermal/radiation procedure EQ-TP-354. - 10 years at qualification and the open item from testing completed) The results are captured maximum normal Steris. WCNOC will complete the test in Sections 5.2 and 5.3 operating report reviews when provided.

of EQ-QR-269 with temperature of additional 140°F clarification/explanation in Sections 3 and 4 of WNA-TR-03149-GEN and LTR-SFPIS-1 5-34.

7 Basis for Dose SFP Normal LTR-SFPIS-13-35 LTR-SFPIS-13-35 Passed for all WCNOC has determined the basis Requirement Conditions: and WNA-DS- contains the explanation conditions documents to be acceptable.

02957-GEN of basis for radiation 1E3 R y TID dose requirement The radiation analysis documented in (above pool) See also Section (includes the WNA-TR-03149, Section 5.0, contains 4.1.1 of WNA-TR- clarification of significant conservatism with the 1E9 R y TID (1' 03149-GEN production equivalency intention of bounding sites installing the above fuel rack) of electronics used for system.

the seismic and SFP BDBE electromagnetic With SFP water level at Level 3, the Conditions: capability (EMC) testing) only components of the SFPIS that are exposed to high radiation are the 1E7 R y TID The radiation dose basis stainless steel probe and the stainless (above pool) has been incorporated steel anchor. The materials with which into Section 4.1.1 WNA- the probe and the anchor are

< 1E7 R y TID (1' TR-03149-GEN. manufactured are resistant to radiation above fuel rack) effects.

The justification that the system components are inherently resistant to radiation effects is provided in Section

Attachment III to ET 15-001 Page 6 of 12 rWestinghouse Test or Analysis PSummary Reference Additional Comment Results Licensee Evaluation

1. _____c Summary Document# Results 5.1.1 of WNA-TR-03149-GEN.

10466-J-830 states that the TID basis for all electrical equipment and instrumentation outside of containment is 1E7 R. Section 5.3 of EQ-QR-269 demonstrates that the test specimens were subjected to a minimum TID of 11.00 Mrad. Section 5.1.1 of WNA-TR-03149-GEN states that "Westinghouse engineering evaluation saw no reasonable way to exceed 10 MR for the beyond design basis TID."

8 Seismic Per spectra in EQ-QR-269 Section 5.4 of EQ-QR- Passed The spectra in Reference 5 for the Qualification WNA-DS-02957- 269 summarizes the pool-side mounting brackets bounds GEN testing performed by WCGS for meeting the requirements to Westinghouse withstand a SSE. Instrument panel mounting is qualified by Reference 5.

WNA-TR-03149- Section 6 of WNA-TR- Passed GEN 03149-GEN provides high level summary of the pool-side bracket analysis and optional Resistance Temperature Detector (RTD) in addition to the overall system and the various options for improved EMC performance.

Attachment III to ET 15-001 Page 7 of 12 Parameter Westinghouse Test or Analysis

1. Topic Reference Additional Comment Licensee Evaluation

1. Topic Summary Document # Results EQ-QR-269 Seismic pull test for new Passed connectors documented in Section 4.4 of EQ-QR-269.

9 Sloshing N/A LTR-SEE-II-13-47 Calculation to Passed WCNOC has determined WNA-TR-demonstrate that the 03149-GEN to be acceptable.

probe will not be Adequate sloshing forces (inclusive of sloshed out of the SFP vertical and horizontal impact forces, hydrodynamic forces) were accounted WNA-TR-03149- Sloshing is also Passed to calculate the overall sloshing forces.

GEN addressed in Section These forces were added to design the 7.2 of WNA-TR-03149- bracket anchorage, to ensure the probe GEN with further will not be sloshed due to a BDB clarification in LTR- seismic event.

SFPIS-1 4-70 10 Spent Fuel Pool Acceptance WNA-TP-04613- Test procedure used to See applicable WCNOC has determined WNA-TP-Instrumentation Criteria for GEN demonstrate that SFPIS environmental 00189-GEN "Integrated Functional Test System Performance meets its operational qualification (EQ) Plan" to be acceptable.

Functionality Test during EQ Testing and accuracy test.

Procedure requirements during Equipment Qualification Testing programs.

11 Boron Build-up Per Requirement WNA-TR-03149- Section 7.4 of WNA-TR- Passed WCNOC has determined WNA-TP-in WNA-DS- GEN 03149-GEN 00189-GEN "Integrated Functional Test 02957-GEN Plan" to be acceptable Boron build up demonstrated through Integrated Functional Test (IFT)

Attachment III to ET 15-001 Page 8 of 12 Parameter Westinghouse Test or Analysis

1. Topic #PTopicmSummar Summary Reference Document # Additional Comment ResultsLicensee Evaluation 12 Pool-side Bracket N/A CN-PEUS-1 3-32 Also includes Passed WCGS seismic requirements to Seismic Analysis hydrodynamic forces, as withstand a SSE are bounded by appropriate Reference 6 for the pool-side mounting brackets.

13 Additional N/A WNA-DS-02957- Weights provided to N/A WCGS has evaluated the seismic Brackets (Sensor GEN licensees for their own mounting requirements. Instrument Electronics and evaluation panel mounting is qualified by Electronics Reference 6.

Enclosure) 14 Shock & Vibration WNA-DS-02957 WNA-TR-03149- Section 7 of WNA-TR- N/A WCNOC has determined the GEN 03149-GEN provides Westinghouse evaluation of shock and rational and summary of vibration in WNA-TR-03149-GEN is RTD acceptable.

15 Requirements Maps WNA-VR-00408- The RTM maps the Complete WCNOC has reviewed the compliance Traceability Matrix Requirements to GEN requirements of the matrix provided by Westinghouse.

(RTM) Documentation / NRC order, NEI Evidence that guidance, and ISG to Requirement is the applicable technical Met requirements in the SFPIS design specification and maps the design specification requirements to the documentation demonstrating the requirement is met.

16 Westinghouse IFT Functional WNA-TP-04752- The IFT demonstrates Pilot IFT WCGS has reviewed the final test Factory Requirements GEN functionality of the full executed/passed reports and found them to be Acceptance Test, from WNA-DS- system for each acceptable.

Including Testing 02957-GEN customer's Factory WCGS IFT Acceptance Test (FAT),

Attachment III to ET 15-001 Page 9 of 12 Parameter Westinghouse Test or Analysis PTopic Summarya Reference Additional Comment Test Licensee Evaluation Document Results of Dead-zones which includes executed/passed calibration of each channel.

12" Dead-zone at WNA-TP-04752- Dead-zone tests are in N/A Top of Probe or GEN Section 9.6.2 of WNA-14" dead-zone at TP-04752-GEN top of probe for cables > -230 feet 4" Dead-zone at Bottom of Probe 17 Channel Accuracy +/- 3 inches per WNA-CN-00301 - Channel accuracy from Passed WCGS has reviewed WNA-DS-02957-WNA-DS-02957- GEN measurement to display GEN and WNA-CN-00301-GEN and GEN found that channel accuracy Additional clarification requirements are met. WCGS provided in LTR-SFPIS- calculated channel accuracy is14-136, Rev. 1 +/- 3 inches.

18 Power 3 Day Battery Life WNA-CN-00300- N/A Passed WCGS has reviewed WNA-CN-00300-Consumption (Minimum) GEN GEN and concluded that battery life of

> 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is available for 0.257 Amps Westinghouse display enclosure and Power meets the Order requirements. The Consumption 0.257 Amps loading does not challenge the WCGS electrical distribution system.

19 Technical Manual N/A WNA-GO-001 27- Information and N/A WCGS will utilize WNA-GO-00127-GEN instructions for GEN as input for procedure operation, installation, preparation.

use, etc. are included here.

Attachment III to ET 15-001 Page 10 of 12

1. Parameter Westinghouse Test or Analysis Topic Summary Reference Additional Comment Results Licensee Evaluation ummaryDocument #

20 Calibration Routine WNA-TP-04709- Includes preventative N/A WCGS will utilize WNA-TP-04709-GEN Testing/Calibration GEN maintenance actions as input for procedure preparation.

Verification and such as those for Boron Calibration buildup and cable probe Method inspection.

21 Failure Modes N/A WNA-AR-00377- Addresses mitigations N/A WCGS will utilize WNA-AR-00377-GEN and Effects GEN for the potential failure as input for procedure preparation.

Analysis (FMEA) modes of the system 22 Emissions Testing Reg. Guide 1.180, WNA-TR-03149- Documented in Section Passed WCNOC has reviewed the test report Rev. 1 Test GEN 2 of WNA-TR-03149 and found it meets requirements for Conditions EQ-QR-269 and Section 5.6 of EQ- radiated emissions limits and criterion B QR-269 for susceptibility testing based on the modifications implemented.

23 Splash Testing / Temporary WNA-TR-03149- Section 7.5 of WNA-TR- Passed WCGS has reviewed the final test Submersion GEN 03149-GEN - Standard reports and found them to be With Option for configuration withstands acceptable.

Longer the temporary Submersion submersion.

Option available for longer submersion.

Attachment III to ET 15-001 Page 11 of 12

References:

1. Letter from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "Issuance of Order to Modify Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation," March 12, 2012. ADAMS Accession No. ML12056A044.

2. NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation'," Revision 1, August 2012. ADAMS Accession No. ML122400399.

3. JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, August 29, 2012. ADAMS Accession No. ML12221A339.

4. Wolf Creek Document EQSD-1, Revision 7, "Equipment Qualification Design Basis Document," August 21, 2014.

5. Westinghouse Proprietary Document CN-PEUS-13-32, Revision 1, "Seismic Analysis of the SFP Mounting Bracket for Wolf Creek Generating Station," November 13, 2014.

6. Westinghouse Proprietary Document WNA-VR-00408-GEN, Revision 2, "Spent Fuel Pool Instrumentation System Requirement Traceability Matrix," April 2015.

7. Westinghouse Proprietary Document WNA-DS-02957, Revision 4, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System Design Specification," May 2014; Wolf Creek Document Number J-481A-00043.

8. Westinghouse Proprietary Document WNA-PT-00188-GEN, Revision 3, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy," May 2014; Wolf Creek Document Number J-481A-00047.

9. Westinghouse Proprietary Document EQ-QR-269, Revision 1, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation," April 2014; Wolf Creek Document Number J-481A-00032.

10. Westinghouse Proprietary Document WNA-TR-03149-GEN, Revision 1, "SFPIS Standard product Final Summary Design Verification Report," April 2014; Wolf Creek Document Number J-481A-00052.

11. Westinghouse Proprietary Document EQ-TP-351, Revision 2, "Environmental Qualification Test Procedure for the Spent Fuel Pool Instrumentation System Coaxial Cable and Connectors inside the Spent Fuel Pool Area," November 2014.

12. Westinghouse Proprietary Document EQ-TP-354, Revision 0, "Mechanical Preconditioning, Thermal Aging, and Radiation Aging Procedure for the Spent Fuel Pool Instrumentation System Coaxial Cables and Couplers," December 2013.

13. Wolf Creek Document 10466-J-830, Revision 2, "Technical Specification for Environmental Qualification Requirements for Safety-Related Control and Instrument Devices for the Standardized Nuclear Unit Power Plant System (SNUPPS)," November 23, 1977.

14. Westinghouse Proprietary Document LTR-SFPIS-13-35, Revision 1, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronic Enclosure Used for Seismic Testing," March 1, 2014.

Attachment III to ET 15-001 Page 12 of 12

15. Westinghouse Proprietary Document LTR-SEE-II-13-47, Revision 0, "Determination if the Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out of the Spent Fuel Pool during a Seismic Event," January 15, 2014.

16. Westinghouse Proprietary Document WNA-TP-04613-GEN, Revision 5, "Spent Fuel Pool Instrumentation System Functionality Test Procedure," November 2013.

17. Westinghouse Proprietary Document WNA-DC-00252-SAP, Revision 0, "Spent Fuel Pool Instrumentation System Compliance Matrix - Wolf Creek," June 2014; Wolf Creek Document Number J-481A-00042.

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

March 2014; Wolf Creek Document Number J-481A-00050.

19. Westinghouse Proprietary Document WNA-CN-00301-GEN, Revision 2, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis," June 2014; Wolf Creek Document Number J-841A-00041.

20. Westinghouse Proprietary Document WNA-CN-00300-GEN, Revision 0, "Spent Fuel Pool Instrumentation System Power Consumption Calculation," October 2013; Wolf Creek Document Number J-481A-00040.

21. Westinghouse Proprietary Document WNA-GO-00127-GEN, Revision 3, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual," July 2014; Wolf Creek Document Number J-481A-00044.

22. Westinghouse Proprietary Document WNA-TP-04709-GEN, Revision 4, "Spent Fuel Pool Instrumentation System Calibration Procedure," March 2014; Wolf Creek Document Number J-481A-00049.

23. Westinghouse Proprietary Document WNA-AR-00377-GEN, Revision 4, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis," May 2014; Wolf Creek Document Number J-481A-00039.

24. Westinghouse Proprietary Document LTR-EQ-14-163, Revision 0, "Interim Position for Radiation Aging of the Spent Fuel Pool Instrumentation System," October 24, 2014.

25. Westinghouse Proprietary Document EQ-TP-353, Revision 0, "Static Pull Test Procedure for Spent Fuel Pool Instrumentation System Connector," December 2013.

26. Westinghouse Proprietary Document WNA-TP-00189, Revision 3, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Plan," July 2014.