ML13239A238
| ML13239A238 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/20/2013 |
| From: | Ventosa J A Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-13-103, TAC MF0737, TACMF0738, EA-12-051 | |
| Download: ML13239A238 (20) | |
Text
EinSEntergyEntergy Nuclear NortheastIndian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 10511-0249Tel 914 734 6700John A. VentosaSite Vice PresidentAdministrationNL-13-103August 20, 2013U.S. Nuclear Regulatory CommissionATTN: Document Control Desk11545 Rockville Pike, TWFN-2 F1Rockville, MD 20852-2738SUBJECT:REFERENCES:Response to Request for Additional Information (RAI)Regarding Reliable Spent Fuel Pool (SFP) Instrumentation(Order No, EA-12-051) (TAC NOS. MF0737 AND MF0738)Indian Point Unit Numbers 2 and 3Docket Nos. 50-247 and 50-286License Nos. DPR-26 and DPR-64NRC Order Number EA-1 2-051, Order Modifying Licenses withRegard to Reliable Spent Fuel Pool Instrumentation, datedMarch 12, 2012 (RA-12-038) (ML12054A682)1.2. Entergy letter to NRC, Overall Integrated Plan in Responseto March 12, 2012, Commission Order Modifying LicenseWith Regard To Reliable Spent Fuel Pool Instrumentation(Order No. EA-12-051), dated February 27 2013 (NL-13-043)3. NRC letter to Entergy, Request for Additional InformationRegarding Reliable Spent Fuel Pool Instrumentation, Order No. EA-12-051 (TAC NOS. MF0737 AND MF0738), dated June 25, 2013,Dear Sir or Madam:On March 12, 2012, the NRC issued an order (Reference 1) to Entergy NuclearOperations, Inc (Entergy). Reference 1 required submission of an Overall IntegratedPlan which was provided via Reference 2. By Reference 3, the NRC issued arequest for additional information (RAI) due within 60 days of the date of Reference3. The attachment provides the responses to these RAIs for Indian Point EnergyCenter (IPEC). The RAI responses provided in Attachment 1 are based on thecurrent preliminary design information/vendor input which is subject to change as thedesign is finalized. Where requested information was not available for this RAIresponse it will be included in the upcoming 6-month updates, as it becomesavailable.AocDI NL-13-103Dockets 50-247 and 50-286Page 2 of 2Attachment 2 to this letter summarizes the commitment made in this response.. If you haveany questions regarding this report, please contact Mr. Robert Walpole, Manager, Licensing at(914) 254-6710.I declare under penalty of perjury that the foregoing is true and correct; executed on August20.() , 2013.Sincerely,JAV/spAttachments:1. Indian Point Energy Center Response to Request for AdditionalInformation on Reliable Spent Fuel Pool Instrumentation2. List of Regulatory Commitmentscc:Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORLMr. William M. Dean, Regional Administrator, NRC Region INRC Resident Inspector's Office Indian PointMs. Bridget Frymire, New York State Department of Public ServiceMr. Francis J. Murray, Jr., President and CEO, NYSERDA ATTACHMENT 1 TO NL-13-103INDIAN POINT ENERGY CENTERRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONON RELIABLE SPENT FUEL POOL INSTRUMENTATIONENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3DOCKET NOS. 50-247 and 50-286 Attachment 1NL-13-103Dockets 50-247 and 50-286Page 1 of 15RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)RAI-1Please provide the following:a) For level 1 in both Units 2 and 3, identify the functional reasons for selection of thesuction pipe identified and verify that it is the HIGHER of the two points described in theNEI 12-02 guidance for this level.b) A clearly labeled sketch depicting the elevation view of the proposed typical mountingarrangement for the portions of instrument channel consisting of permanentmeasurement channel equipment (e.g., fixed level sensors and/or stilling wells, andmounting brackets). Indicate on this sketch the datum values representing Level 1, Level2, and Level 3 as well as the top of the fuel. Indicate on this sketch the portion of thelevel 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.RAI 1 Response:a) Level 1 is the level adequate to support operation of the normal fuel pool cooling system. Itis the higher of the following two points:(1) The level at which reliable suction loss occurs due to uncovering the coolant inletpipe or any weirs or vacuum breakers associated with suction loss.a. For the Unit 2 SFP, the elevation associated with this level is 89'-5 3/8", andcorresponds to the level where the suction pipe for the Aux. Coolant System(Drawing 9321-F-2577-25, Section C-C) begins to uncover. The introduction ofair into the spent fuel pit suction piping may interfere with pump performance.b. For the Unit 3 SFP, the elevation associated with this level is 89'-5 3/8", andcorresponds to the level where the suction pipe for the Aux. Coolant System(Drawing 9321-F-25773, Section C-C) begins to uncover. The introduction of airinto the spent fuel pit suction piping may interfere with pump performance.(2) The level at which the normal fuel pool cooling pumps lose required NPSH assumingsaturated conditions in the pool.a. For the Unit 2 SFP, the level where the spent fuel pit pumps lose required NPSHis 87'-4" for a design basis pool temperature of 200'F (Calculation FPX-0001 7).b. For the Unit 3 SFP, the level where the spent fuel pit pumps lose required NPSHis 63'-2" for a pool temperature of 212°F (Calculation CWBS-C-287).
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 2 of 15Therefore, the Level 1 elevation is 89'-5 3/8" for both Unit 2 and Unit 3.b) The requested information is provided in Figure 1 for Indian Point Unit 2 and Figure 2 forIndian Point 3. The figures indicate Levels 1, 2, and 3 as well as the approximate locationof the proposed mounting bracket incorporating the Seismic Category I attachment. Thesensor is a perforated tubular coaxial waveguide that provides continuous levelmeasurement axially and is sensitive over its entire length. These figures apply to boththe primary and backup channels.The spent fuel pool (SFP) level lower instrument span or probe bottom extends down toat least three inches below the upper limit of the range of Level 3 to account for channelaccuracy or instrument loop uncertainty. Therefore, the SFP level probe bottom/spanextends down to at least elevation 70 feet 51/4 inches for Unit 2 and 70 feet 41/2 inchesfor Unit 3 (see Figures 1 and 2). The SFP level upper instrument span, at a minimum,includes normal water level high alarm. Note that Level 3 is shown in accordance withNuclear Energy Institute (NEI) 12-02 Revision 1 guidance relative to the top of the rack;the top of the fuel is not shown.RAI-2Please 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 the methodologythat will be used to estimate the total loading, inclusive of design basis maximum seismicloads and the hydrodynamic loads that could result from pool sloshing or other effectsthat could accompany such seismic forces.b) A description of the manner in which the level sensor (and stilling well, if appropriate) willbe attached to the refueling floor and/or other support structures for each planned pointof attachment of the probe assembly. Indicate in a schematic the portions of the levelsensor that will serve as points of attachment for mechanical/mounting or electricalconnections.c) A description of the manner by which the mechanical connections will attach the levelinstrument to permanent SFP structures so as to support the level sensor assembly.RAI 2 Response:a) The loading on the probe mount and probe body includes both seismic andhydrodynamic loading using seismic response spectra that bound the IPEC design basismaximum seismic loads applicable to the installation location(s). The static weight loadis also accounted for in the modeling described below but is insignificant in comparisonto seismic and hydrodynamic loads. Analytic modeling is being performed by theinstrument vendor using Institute of Electrical and Electronic Engineers IEEE 344-2004methodology.
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 3 of 15The simple unibody structure of the probe assembly makes it a candidate for analyticmodeling and the dimensions of the probe and complex hydrodynamic loading terms inany case preclude meaningful physical testing.A detailed computational SFP hydrodynamic model has been developed for theinstrument vendor by Numerical Applications, Inc., author of the GOTHIC computationalfluid dynamics code. The computational model accounts for multi-dimensional fluidmotion, pool sloshing, and loss of water from the pool.Seismic loading response of the probe and mount is separately modeled using finiteelement modeling software. The GOTHIC-derived fluid motion profile in the pool at theinstallation site and resultant distributed hydrodynamic loading terms are added to thecalculated seismic loading terms in the finite element model to provide a conservativeestimate of the combined seismic and hydrodynamic loading terms for the probe andprobe mount, specific to the chosen installation location for the probe.b) The proximal portion of the level probe is designed to be attached near its upper end(refer to vendor schematic Figure 3) to a Seismic Category I mounting bracketconfigured to suit the requirements of a particular SFP. The bracket may be boltedand/or welded to the SFP deck and/or SFP liner/wall according to the requirements ofthe particular installation per Seismic Category I requirements.c) See RAI-2.b response above.RAI-3Please provide the following:a) A description of the specific method or combination of methods that you intend to applyto demonstrate the reliability of the permanently installed equipment under Beyond-Design-Basis (BDB) ambient temperature, humidity, shock, vibration, and radiationconditions.b) A description of the testing and/or analyses that will be conducted to provide assurancethat the equipment will perform reliably under the worst-case credible design basisloading at the location where the equipment will be mounted. Include a discussion of thisseismic reliability demonstration as it applies to (a) the level sensor mounted in the SFParea, and (b) any control boxes, electronics, or read-out and re-transmitting devices thatwill be employed to convey the level information from the level sensor to the plantoperators or emergency responders.c) A description of the specific method or combination of methods that will be used toconfirm the reliability of the permanently installed equipment following seismic conditionsto maintain its required accuracy.RAI 3 Response:a) As stated in NEI 12-02, "Components in the area of the SFP will be designed for thetemperature, humidity, and radiation levels expected during normal, event, and post-Attachment 1NL-13-103Dockets 50-247 and 50-286Page 4 of 15event conditions...." Components in other areas are planned to be designed for theircorresponding maximum conditions. The discussion below describes the testing andqualification intended to demonstrate equipment reliability as needed for the expectedconditions associated with the SFP level channel active components (signal processorand probe assembly including vendor-supplied hard-line coaxial cable pigtail). Class1 E nuclear-qualified interconnecting coaxial cable is planned to be utilized between thevendor-supplied probe coaxial cable pigtail and the signal processor / display.Temperature:Signal processor: Designed for mild environment installation. Physical testing inan environmental chamber to demonstrate normal operation at the operatingtemperatures specified for the instrument.Probe assembly: Qualification by materials properties and use history ofsubstantially similar probe designs in steam generator applications at significantlyhigher temperatures and pressures and saturated steam environments.Humidity:Signal processor: Designed for mild environment installation. Physical testing inan environmental chamber to demonstrate normal operation at the operatinghumidity specified for the instrument.Probe assembly: Qualification by materials properties and use history as notedabove.Shock:Signal processor: Physical testing to commercial and/or military standards usingshake-table and drop testing.Probe assembly: Finite element analysis in conjunction with seismic modelingdescribed above.Vibration:Signal processor: Physical testing to applicable commercial and/or militarystandards using shake-table and drop testing.Probe assembly: The probe assembly and bracket together form a simple staticunibody structure with intrinsic vibration resistance that is additionally subject tosubstantial damping due to the surrounding water medium. This is planned to bemodeled using finite element modeling in conjunction with seismic modelingdescribed above.Radiation:Signal processor: The signal processor is installed in a mild environment withradiation levels similar to background radiation, with the acknowledgement that Attachment 1NL-13-103Dockets 50-247 and 50-286Page 5 of 15the radiation limit for the signal processor is similar to other commercial-gradecomplementary-metal-oxide-semiconductor (CMOS)-based electronics.Radiation testing is not planned. It should be noted that the instrument performsself-diagnostics before measurements are obtained and the electronics are easilyaccessible for periodic replacement.Probe assembly: Materials properties qualification is used.b) Signal processor (electronics): Triaxial shake-table testing is planned to be performedby the vendor to envelope seismic category 1 safe shutdown earthquake (SSE)conditions or IPEC design basis maximum seismic loads (relative to the location wherethe equipment is mounted) using IEEE 344-2004 methodology.Probe assembly (level sensor): Seismic and hydrodynamic finite element analysis isperformed by the vendor using relevant IEEE 344-2004 methodology (usingenveloping seismic category 1 SSE conditions or IPEC design basis maximumseismic loads relative to the location where the equipment is mounted), as described inthe RAI-2.a response above.c) With respect to the probe assembly, combined seismic and hydrodynamic analysis willbe used to demonstrate that the probe waveguide's geometric dimensions do notchange significantly as a result of the seismic conditions. In the absence of alterationto the geometric configuration of the probe waveguide there is no mechanism forseismic excitation of the probe assembly to alter system accuracy.The accuracy of system electronics will be demonstrated following seismic excitationas part of the seismic testing protocol.RAI-4Please provide the following:a) A description of how the two channels of the proposed level measurement system meetthis requirement so that the potential for a common cause event to adversely affect bothchannels is precluded.b) Further information on how each level measurement system, consisting of level sensorelectronics, cabling, and readout devices will be designed and installed to addressindependence through the application and selection of independent power sources, theuse of physical and spatial separation, independence of signals sent to the location(s) ofthe readout devices, and the independence of the displays.RAI 4 Response:a) The primary instrument (Channel A) will be in the southeast corner of the SFP and thebackup instrument (Channel B) will be in the northwest corner of the SFP. Locating thenew instruments in the corners of the SFP takes advantage of missile and debrisprotection inherent in the corners. Channel A cable will be routed along the east FuelStorage Building (FSB) wall and then along the south FSB wall to enter the Fan House,while Channel B is routed along the west FSB wall until it enters the Fan House, Attachment 1NL-13-103Dockets 50-247 and 50-286Page 6 of 15maintaining physical separation in FSB. Channel A and B displays will both be locatedon Hydrogen Recombiner panels in each unit's Fan House. The Hydrogen Recombinerpanels are designed to Seismic Category I standards.The conceptual design provides two level instruments in the Spent Fuel Pool (SFP)within the Fuel Storage Building, with cabling routed to two electronics packagesmounted on Hydrogen Recombiner panels in each unit's Fan House to provide leveldisplay. Power for each channel is provided from independent existing 120V alternatingcurrent (AC), 60 Hz power sources in the general area of the electronics packages. Asstated in the OIP, the primary channel will receive power from a different 480V bus thanthe backup channel. Backup power for each channel is provided by a separate batterycapable of providing continuous display operation for at least three days. The batterypower will be provided to the display/processor. The design prevents failure of a singlechannel from causing the alternate channel to fail.b) The design provides two identical non-safety related wide-range level instruments whichfeed two physically and electrically independent trains of non-safety / seismicallymounted cable and indicators to provide a highly reliable remote display of SFP waterlevel in the Fan House. Physical separation of the two channels will be accomplished byseparately routing cable and conduit as much as practical. The use of raceways (i.e.conduit or covered trays where appropriate for existing hazards) will provide additionalprotection from damage due to debris during a BDB event.Independent power sources are provided such that the loss of power to one channel willnot result in the loss of power to the other channel. Each channel is also provided withan independent backup power source.Each display/processor in the Fan House will have a battery installed adjacent to thedisplay enclosure which is capable of providing power for at least three days. Theseparation of the display is consistent with the existing plant design basis separationcriteria.RAI-5If the level measurement channels are to be powered through a battery system (either directlyor through an UPS, please provide the design criteria that will be applied to size the battery in amanner that ensures, with margin, that the channel will be available to run reliably andcontinuously following the onset of the BDB event for the minimum duration needed, consistentwith the plant FLEX Program plans.RAI 5 Response:The sample rate estimates have been developed by the vendor using conservative instrumentpower requirements and measured battery capacity with draw-downs during and followingexposure of the batteries to their maximum operating temperature for up to seven days. Theinstrument configuration is planned to be established for an automated sample rate when underbattery power consistent with seven days continuous operation. Permanent installed batterycapacity for seven days continuous operation is planned consistent with NEI 12-02 durationwithout reliance on or crediting of potentially more rapid FLEX Program power restoration.
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 7 of 15Batteries are readily replaceable via spare stock without the need for recalibration to maintainaccuracy of the instrument. These measures ensure adequate power capacity and margin.RAI-6Please provide the following:a) An estimate of the expected instrument channel accuracy performance under both (a)normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDBconditions (i.e., radiation, temperature, humidity, post-seismic and post-shockconditions) that would be present if the SFP level were at the Level 2 and Level 3 datumpoints.b) A description of the methodology that will be used for determining the maximum alloweddeviation from the instrument channel design accuracy that will be employed undernormal operating conditions as an acceptance criterion for a calibration procedure to flagto operators and to technicians that the channel requires adjustment to within the normalcondition design accuracy.RAI 6 Response:a) The instrument channel level accuracy will be specified as +/- 3.0 inches for all expectedconditions. The expected instrument channel accuracy performance would beapproximately +/-1% of span (based on the sensitive range of the detector). This is aconservative bounding instrument channel accuracy with the vendor estimating expectedinstrument channel accuracy is approximately one-third of the above bounding accuracy.b) In general relative to normal operating conditions, any applicable calibration proceduretolerances (or acceptance criterion) are planned to be established based onmanufacturer's stated/recommended reference accuracy (or design accuracy). Themethodology used is planned to be captured in plant procedures and/or programs.RAI-7Please provide the following:a) A description of the capability and provisions the proposed level sensing equipment willhave to enable periodic testing and calibration, including how this capability enables theequipment to be tested in-situ.b) A description how such testing and calibration will enable the conduct of regular channelchecks of each independent channel against the other, and against any otherpermanently installed SFP level instrumentation.c) A description of how calibration and functional checks will be performed, and thefrequency at which they will be conducted. Describe how calibration tests will beperformed, and the frequency at which they will be conducted. Provide a discussion asto how these surveillances will be incorporated into the plant surveillance program.
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 8 of 15d) A description of what preventative maintenance tasks are required to be performedduring normal operation, and the planned maximum surveillance interval that isnecessary to ensure that the channels are fully conditioned to accurately and reliablyperform their functions when needed.RAI 7 Response:a) The level instrument automatically monitors the integrity of its level measurement systemusing in-situ capability. Deviation of measured test parameters from manufactured oras-installed configuration beyond a configurable threshold prompts operator intervention.Periodic calibration checks of the signal processor electronics to extrinsic NationalInstitute of Standards and Technology (NIST)-traceable standards can be achievedthrough the use of standard measurement and test equipment.The probe itself is a perforated tubular coaxial waveguide with defined geometry and isnot calibrated. It is planned to be periodically inspected electromagnetically using time-domain reflectometry (TDR) at the probe hardline cable connector to demonstrate thatthe probe assembly meets manufactured specification and visually to demonstrate thatthere has been no mechanical deformation or fouling.b) Each instrument electronically logs a record of measurement values over time in non-volatile memory that is compared to demonstrate constancy, including any changes inpool level, such as that associated with the normal evaporative loss/refilling cycle. Thechannel level measurements can be directly compared to each other (i.e., regular cross-channel comparisons). The two displays are installed in close proximity to each other,thus simplifying cross channel checks. Direct measurements of SFP level may be usedfor diagnostic purposes if cross-channel comparisons are anomalous.c) Performance tests (functional checks) are automated and/or semi-automated (requiringlimited operator interaction) and are performed through the instrument menu softwareand initiated by the operator. There are a number of other internal system tests that areperformed by system software on an essentially continuous basis without userintervention but which can also be performed on an on-demand basis with diagnosticoutput to the display for the operator to review. Other tests such as menu button tests,level alarm, and alarm relay tests are only initiated manually by the operator.Performance checks are described in detail in the Vendor Operator's Manual, and theapplicable information is planned to be contained in plant operating procedures.Performance tests are planned to be performed periodically as recommended by theequipment vendor, for instance quarterly but no less often than the calibration interval oftwo years.Channel functional tests per operations procedures with limits established inconsideration of vendor equipment specifications are planned to be performed atappropriate frequencies established equivalent to or more frequently than existing spentfuel pool instrumentation.Manual calibration tests are as described above in RAI-7.a and b.
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 9 of 15Manual calibration and operator performance checks are planned to be performed in aperiodic scheduled fashion with additional maintenance on an as-needed basis whenflagged by the system's automated diagnostic testing features.Channel calibration tests per maintenance procedures with limits established inconsideration of vendor equipment specifications are planned to be performed atfrequencies established in consideration of vendor recommendations.d) Periodic (e.g., quarterly or monthly) review of the system level history and log files androutine attention to any warning message on the system display is recommended by thevendor. Formal calibration checks are recommended by the vendor on a two-yearinterval to demonstrate calibration to external NIST-traceable standards. Formalcalibration check surveillance interval and timing would be established consistent withapplicable guidance [i.e., NEI 12-02 Section 4.3; on a refueling outage interval basis andwithin 60 days of a planned refueling outage]. Items such as system batteries areplanned to be assessed under the Preventive Maintenance (PM) program forestablishment of replacement frequency. Surveillance/PM timing/performance areplanned to be controlled via tasks in the PM program.RAI-8Please provide the following:a) Since the "credited" primary and backup display location is other than the main controlroom, provide justification for prompt accessibility to displays including primary andalternate route evaluation, habitability at display location(s), continual resourceavailability for personnel responsible to promptly read displays, and provisions forcommunications with decision makers for the various SFP drain down scenarios andexternal events.b) The reasons justifying why the locations selected enable the information from theseinstruments to be considered "promptly accessible" to various drain-down scenarios andexternal events.c) Describe how the reliability of the "remote" display addresses the criteria in the Orderand the guidance in NEI 12-02. Identify any deviations from that guidance.RAI 8 Response:a) The current design entails mounting both the primary and backup displays in the FanHouse Building. The Overall Integrated Plan will be updated to reflect this change. Thefollowing attributes apply to the display of SFP water level in the Fan House:AccessibilityInformation from the accessibility evaluation is scheduled to be included in the six-monthupdate due on February 27, 2014.Habitability Attachment 1NL-13-103Dockets 50-247 and 50-286Page 10 of 15Information from the habitability evaluation is scheduled to be included in the six-monthupdate due on February 27, 2014.Resource AvailabilityThe FLEX staffing plan is currently scheduled for completion in December 2013. Theinformation from the FLEX staffing plan is scheduled to be included in the six-monthupdate due on February 27, 2014.CommunicationsPortable radios will be used to transmit the SFP water level to key decision makers.b) Information from the accessibility evaluation is scheduled to be included in the six-monthupdate due on February 27, 2014.c) The current design no longer employs the use of a remote display. The OIP will beupdated to reflect this change.RAI-9Please provide a description of the standards, guidelines and/or criteria that will be utilized todevelop procedures for inspection, maintenance, repair, operation, abnormal response, andadministrative controls associated with the SFP level instrumentation, as well as storage andinstallation of portable instruments.RAI 9 Response:Vendor recommended inspection, maintenance, and repair procedures for the liquid levelmeasurement system have been developed through the vendor's 30-year experiencedeveloping and manufacturing liquid level measurement and cable testing instrumentation.These are for the most part specific to the system's proprietary electronics, subject to relevantindustry standards for electronics fabrication and inspection and vendor's quality managementsystem.Where relevant, standards for naval shipboard liquid level indicating equipment have been usedto develop procedures for operation, abnormal response, and administrative controls..Portable instrumentation is not utilized. Both primary and backup SFPI channels incorporatepermanent hard-wired installation.The specific procedures to be used to capture the required activities described in this RAIresponse have not yet been developed but are planned to be developed in accordance with thevendor recommendations and Entergy processes and procedures.
0Attachment 1NL-13-103Dockets 50-247 and 50-286Page 11 of 15RAI-10Please provide the following:a) Further information describing the maintenance and testing program the licensee willestablish and implement to ensure that regular testing and calibration is performed andverified by inspection and audit to demonstrate conformance with design and systemreadiness requirements. Include a description of your plans for ensuring that necessarychannel checks, functional tests, periodic calibration, and maintenance will be conductedfor the level measurement system and its supporting equipment.b) A description of how the guidance in NEI 12-02 section 4.3 regarding compensatoryactions for one or both non-functioning channels will be addressed.d) A description of what compensatory actions are planned in the event that one of theinstrument channels cannot be restored to functional status within 90 days.RAI 10 Response:a) See RAI-6, 7, and 9 responses above for related descriptions of associated maintenanceand testing program details. SFPI channel/equipment maintenance/preventativemaintenance and testing program requirements to ensure design and system readinessare planned to be established in accordance with Entergy's processes and proceduresand in consideration of vendor recommendations to ensure that appropriate regulartesting, channel checks, functional tests, periodic calibration, and maintenance isperformed. Subject maintenance and testing program requirements are planned to bedeveloped during the SFPI modification design process.b) Both primary and backup SFPI channels incorporate permanent installation (with noreliance on portable, post-event installation) of relatively simple and robust augmentedquality equipment. Permanent installation coupled with stocking of adequate spare partsreasonably diminishes the likelihood that a single channel (and greatly diminishes thelikelihood that both channels) is (are) out-of-service for an extended period of time.Planned compensatory actions for unlikely extended out-of-service events aresummarized as follows:#l Compensatory Action if RequiredChannel(s) Required Restoration Action Restoration Action not completedOut-of- within Specified TimeRestore channel to functional Immediately initiate action instatus within 90 days (or if channel accordance with Note below.1 restoration not expected within 90days, then proceed to-Compensatory Action).Initiate action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Immediately initiate action in2 restore one channel to functional accordance with Note below.status, and restore one channel to Attachment 1NL-13-103Dockets 50-247 and 50-286Page 12 of 15# Compensatory Action if RequiredChannel(s) Required Restoration Action Restoration Action not completedOut-of- within Specified TimeServicefunctional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.Note: Present a report to the on-site safety review committee within the following 14days. The report shall outline the planned alternate method of monitoring, the cause ofthe non-functionality, and the plans and schedule for restoring the instrumentationchannel(s) to functional status.c) The requested information is provided in the RAI-10.b response.
Attachment 1NL-13-103Dockets 50-247 and 50-286Page 13 of 15POOL LEVELS AND REFERENCESMOUNTING BRACKETELF VA11ON.. .L ....9'0II--..-F- -E ---- ------ ---- ----- ---- --- -- ---. 94'-3 "... ... .. nO_. D-. L) ... .93'-B"I-------------- .L M ------------- ------------- 93'-31-S 3-1 ---------------9-------------- 92"-2----------- Y & S,. M MQtt G ------------- ---- _$.PL1*U 1_ -.... 89'-5 W9'"111 111111111111111 1 801-8 14"...... ...-- -- -- --1 T ---LE -- ---L- ---- ---- ---- --- 70"-5 114"-- -- -- --PV UW -- -- ----.-- --- --. 69'-8 1/4"BOTTOM OF POOL LEVELREFERENCE9321-F-2514-19 FSB General Arrangement Plans & Elev.2-ARP-SGF (Alarm Response Procedure) & 9321-F-70439321-F-2514-19 FSB General Arrangement Plans & Elev:9321-F-7043 (LC-650 in Section B-B)2-ARP-SGF (Alarm Response Procedure) & 9321-F-7043TS 3.7.11 Spent Fuel Pit Level9321-F-2577. FSB Aux Coolant System Sections, Section C-CNEI 12-02 (Level 3 + 10')Bottom Minr Sensitive Range, 3' below LEVEL 3 upper limit9321-F-1388 & HOLTEC #397 to 4089321-F-2514-19 FSB General Arrangement Plans & Elev.54.'-7I IFIGURE 1 (Unit 2 SFP Elevation View with Levels Indicated)Figure 1 Attachment 1NL-13-103Dockets 50-247 and 50-286Page 14 of 15POOL LEVELS AND REFERENCESMOiJNTIN3 BRACKETELEVATIONMIE. ..95 ..0.-..- ------------ ....94'-2"--.. .... ----n A V ------- ---------------- ---- ------ -93'-8".... .------- --- -------- ------ ------ --- --- -93'-2"-- ..- 91 '--8--FP-- -C T 2----PIPNG _ ----------------- ----- F_.LEL- 1- 89-5 31W'8 SENSOR----------------------- --------- ..... 80'-7 112"-.-........ --TF- ---L- ---ff.L ... -, L --------------70'-7 1/2"------------------------- ---------------- 70U-4 1/2"-.-.....- ..- ..- 1PJ BV" L -4 ---_ 69'-7 1/2'0 1L LEVE11111111I BOTTOM OF POOL LEVELREFERENCE9321-F-20277 RO Fuel Storage Building El. 95'-0" Plans,Sections and Details Mechanical3-ARP-013 (Alarm Response Procedure) & 9321-F-704339321-F-20277 RO Fuel Storage Building El. 95'-0" Plans, Sectionsand Details Mechanical 9321-F-70443 (LC-650 In Section B-B)3-ARP-013 (Alarm Response Procedure) & 9321-F-70433TS 3.7.14 Spent Fuel Pit Level9321-F-25773, FSB Aux Coolant System Sections (Plan Z', Section C-C)NEI 12-02 (Level 3 + 10')Bottom MIn. Sensitive Range, 3" below LEVEL 3 upper limitIP3V-1684-0004, IP3V-1684-000329321-C-1 1023 RI Proposed FSB Mat. Pre-Permit Const.I I ---54'-7'FIGURE 2 (Unit 3 SFP Elevation View with Levels Indicated)Figure 2 Attachment 1NL-13-103Dockets 50-247 and 50-286Page 15 of 15, CABLE,,-PROBE HEADFLANGE MOUNTFigure 3 ATTACHMENT 2 TO NL-1 3-103LIST OF REGULATORY COMMITTMENTSENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3DOCKET NOS. 50-247 and 50-286 Attachment 2NL-13-103Dockets 50-247 and 50-286Page 1 of 1List of Regulatory CommitmentsThe following table identifies those actions committed to by Entergy in this document. Any otherstatements in this submittal are provided for information purposes and are not considered to beregulatory commitments.TYPE(Check One) SCHEDULEDCOMPLETIONCOMMITMENT ONE- CONTINUING DATETIME COMPLIANC (I TEACTION E (If Required)Where requested information was notavailable for this RAI response in NL-13- Six month intervals103 it will be included in the upcoming 6-month updates, as it becomes available.