RS-13-029, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13059A306
Person / Time
Site:	Clinton
Issue date:	02/28/2013
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-13-029
Download: ML13059A306 (11)

Text

Exelon Generation Order No. EA-12-051 RS-13-029 February 28, 2013 u.s. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012

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 August24,2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGG) . Reference 1 was immediately effective and directs EGC 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 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan. The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan complying with the guidance for the purpose of ensuring a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of required wide range pool water level conditions by trained personnel .

U.S. Nuclear Regulatory Commission Commission Integrated Plan Report Report toto EA-12-051 EA-12-051 February 28, 2013 28,2013 Page Page 22 Reference Reference 44 provided provided the the EGC EGC initial initial status report regarding status report regarding reliable reliable spent spentfuelfuel pool pool instrumentation, instrumentation, as required by as required by Reference Reference 1. 1.

Reference Reference 3, 3, Appendix Appendix A-2A-2 contains the specific contains the specific reporting reporting requirements requirements for for the the Overall Overall Integrated Integrated Plan.

Plan. TheTheinformation information inin the the enclosure enclosureprovides providesthe theClinton ClintonPower PowerStation, Station,UnitUnit11Overall Overall Integrated Integrated PlanPlan pursuant pursuant to to Appendix Appendix A-2 Reference3.3. The A-2ofofReference The enclosed Integrated Plan enclosed Integrated Plan isis based based on on conceptual conceptual design information. Final design information. Final design design details details andand associated procedure guidance, associated procedure guidance, as as well well as any revisions as any revisions to to the the information information contained contained inin the theEnclosure, Enclosure,willwill be beprovided providedinin the the 6-month 6-month Integrated Integrated Plan Plan updates required by updates required by Reference Reference 1. 1.

This letter This letter contains contains no new regulatory no new regulatory commitments.

commitments. If If you you have have any any questions questionsregarding regarding this this

report, report, please contact David please contact David P. P. Helker Helker at at 610-765-5525.

610-765-5525.

II declare under penalty declare under penalty ofof perjury perjury that that the the foregoing foregoing isis true and correct.

true and correct. Executed Executedon onthe the28th 28thday day of of February 2013.

February 2013.

Respectfully submitted, Glen T. Kaegi Director - Licensing Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1.

1. Clinton Clinton Power Power Station, Unit 11 Reliable Station, Unit Reliable Spent Fuel Pool Spent Fuel Pool Instrumentation Instrumentation (SFPI)

(SFPI) Overall Overall Integrated Plan Integrated Plan cc: Director, Office of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region Region III'"

NRC Senior Resident InspectorInspector -- Clinton Clinton Power PowerStation, Station,UnitUnit11 NRC Project Manager, NRR NRR -- Clinton Clinton Power Power Station, Station,Unit Unit11 Mr. Robert J.

Mr. J. Fretz, Jr, NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, Mr. NRRIDSS/SCVB, NRC NRC Illinois IllinoisEmergency Emergency Management Management Agency Agency -- Division Division of of Nuclear Nuclear Safety Safety

Enclosure 11 Enclosure Clinton Power Clinton Power Station, Station, Unit Unit 11 Reliable Spent Reliable Spent Fuel Fuel Pool PoolInstrumentation Instrumentation(SFPI)

(SFPI)

Overall Integrated Overall Integrated Plan Plan (8 pages)

(8 pages)

Clinton Clinton Power Power Station, Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan Applicability:

Applicabil ity:

This integrated plan This integrated plan applies applies to Clinton Power to Clinton Power Station, Station, UnitUnit 11 and is based and is based on on current current conceptual conceptual design design information.

information. This This plan plan willwillbeberevised revisedas as necessary necessary as as detailed detailed designdesign engineering engineering proceeds. Consistentwith proceeds. Consistent with the therequirements requirementsof ofOrder Order EA-12-051 EA-12-051 (Reference (Reference 1)

1) and and the the guidance guidance ininNEI NEI 12-0212-02(Reference (Reference3), 3),Exelon's Exelon'ssix-month six-month reports reportswill will delineate delineate progress progress made, made, anyany proposed proposed changes changesin in compliance compliance methods, methods, updates updates to to the the schedule schedule and, and, ifif needed, needed, requests requestsfor for relief relief and and the the basis.

basis.

General

Description:

Clinton Clinton Power Power Station Station isis a single unit a single unit BWR BWR 6 with aa Mark 6 with Mark IIIIll containment.

containment. The The unitunit has has an Upper Containment an Upper Containment Fuel Fuel Storage Storage Pool Pool located located in in the the Containment Containment Building Building and and aa Spent Fuel Pool Spent Fuel Pool (SFP)

(SFP) andand FuelFuel Cask CaskStorage StoragePool Poollocated locatedininthetheFuel FuelBuilding.

Building. During During

normal, normal, on-line on-line operation operation irradiated irradiatedfuel fuelisisonly onlystored storedininthe the SFP SFP and not in and not in either either thethe Upper Upper Containment Containment Fuel Fuel Storage Storage Pool Pool or or the the Fuel Fuel Cask Cask Storage Pool. The Storage Pool. The SFP SFPfloorfloor is is at the 712' at the 712' elevation.

elevation. Normal Normal fuel fuel pool pool water level is water level is at at the the 754' 754' elevation elevation andandthe thetoptopofof the fuel rack the fuel rack is is 727.31' 727.31' elevation.

elevation. All All references references are plant elevations are plant elevations with with respect respect to to mean mean seasea level.

level.

Schedule:

The installation of The installation reliable level of reliable level instrumentation instrumentation for for the the SFP associated with SFP associated with UnitUnit 11isis scheduled scheduled for for completion completion by by thethe end end of of C1C1 R15 R15 (Spring (Spring2015) 2015)based based onon the the endend of of the the second refueling outage second refueling outage following following submittal submittal of of this this integrated integrated plan. Unit 11irradiated plan. Unit irradiated fuel fuel is is discharged discharged to to the SFP via the SFP via the the Upper Upper Containment Containment Fuel Fuel Storage Storage Pool.

Pool. During Duringnormal,normal, on-line on-line operation operation this pool contains this pool contains no no irradiated irradiated fuel.

fuel. Although Although Clinton Clinton is licensed to is licensed to store fuel in store fuel in the Fuel Cask the Fuel Cask Storage Storage Pool,Pool, there thereareareno nofuel fuelracks racksininthis thispool poolatatthis thistime.

time.

Should Should itit be decided at be decided at aalater latertime time to to add addfuelfuelracks racksininthisthispool, pool,only onlyirradiated irradiated fuel fuel discharged discharged from from thethe reactor reactor for for more more thanthan 55 years years willwill bebe stored stored here. Thus, the here. Thus, theUpper Upper Containment ContainmentFuel FuelStorage Storage Pool Pool andand the Fuel Cask the Fuel Storage Pools Cask Storage Pools are are not not considered considered spent fuel pools spent fuel pools per per NRC NRC JLD-ISG-2012-03 JLO-ISG-2012-03 (Reference (Reference 2) 2) and and NEINEI 12-02 12-02 (Reference (Reference 3). 3).

The current milestone milestone schedule schedule isis as as follows:

follows:

• Complete Conceptual Design Design (CD) (CD) forfor Pilot PilotPlant Plant(Limerick)

(Limerick) Complete

• Complete CD Follow-up Walkdowns at Remaining Remaining 99 Exelon Exelon Sites Sites Complete

• Submit Initial 60-day Status Status Report Report Complete 1

1

Clinton Clinton Power Power Station, Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan

• Develop Request for Proposal for for Detailed Detailed Engineering Engineering Complete Complete Design Services

• Submit Integrated Plan Complete with this submittal submittal

• Begin Detailed Engineering Design Design 3rd Quarter 2013

• Complete Complete and Issue Spent and Issue Spent Fuel Fuel Pool Pool Instrumentation Instrumentation 11st Quarter 2014 st Quarter (SFPI)

(SFPI) Modification Modification Package Package

• Procure SFP Instrumentation 11st st Quarter 2015

• Begin SFPI Installation 11st st Quarter 2015

• Complete SFPISFPI Installation and Put Into Service 2nd Quarter 2015 Identification Identification of Spent Fuel of Spent Fuel Pool PoolWater Water Levels:

Levels:

Key spent fuel pool water water levels levels will will be be identified identifiedas asfollows:

follows:

Level Level adequate adequate to support operation to support operation of normal fuel of the normal cooling system fuel pool cooling system (Level (Level 1):1): Indicated Indicated level on either level on either primary primary oror backup backup instrument instrument channel channel of of greater greater than feet 88 1/4 than 26 feet  % inches inches (elevation (elevation 754')

754') plus instrument accuracy plus instrument accuracy above the the top top ofof the storage the storage racks racks based basedon onthe thedesign designaccuracy accuracyofofthe theinstrument instrumentchannel channel (which (which is is to be to be determined) determined) and and aaresolution resolution better betterthan than11footfoot for for both both the the primary primary and and backup backup instrument instrument channels. This is based This is based on on the theheight height of of the theSFPSFPweir, weir, demonstrating demonstrating that aa water water level level ofof 26 26 feet feet 881/4% inches inches (elevation 754') is adequate adequatefor fornormal normalfuel fuel pool pool cooling cooling system system operation.

operation. All All references references are plant elevations are plant elevations with with respect respect to to sea sea level.

Level adequate Level adequate to to provide substantial radiation radiation shielding shielding for a person person standing standing the spent on the spent fuel fuel pool pooloperating operating deck deck(Level (Level 2): 2): Indicated Indicated level level on either the on either the primary or primary or backup backup instrument instrument channel channel of of greater greater than than 1010 feet feet (elevation (elevation 737.31')

737.31') plus plus instrument channel accuracy above the top of the storage racks based on instrument channel accuracy above the top of the storage racks based on specification of specification of this this level level as adequateininNRC as adequate NRCJLD-ISG-2012-03 JLD-ISG-2012-03 and andNEI NEt 12-02, 12-02,the the accuracyof specified design accuracy of the theinstrument instrumentchannel, channel,and andthe therelatively relativelylowlowsensitivity sensitivity of dose rates of rates toto changes changesininwater waterdepth depthatatthis thislevel.

level.This Thismonitoring monitoring levellevel ensures ensures there is an adequate water level to provide substantial radiation shielding for there is an adequate water level to provide substantial radiation shielding for aa person standing person standing on on the thespent spentfuelfuelpool pooloperating operatingdeck deckfrom fromdirect directgamma gammaradiation radiation irradiated fuel.

from irradiated fuel.

22

Clinton Power Clinton Power Station, Station,Unit Unit 11 Reliable Spent Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall IntegratedIntegrated Plan Plan Level where Level where fuel fuel remains remains covered covered (Level(Level 3):3): Indicated Indicated level level onon either either the the primary primary or backup instrument channel of greater than 0 feet (elevation 727.31 ') plus or backup instrument channel of greater than 0 feet (elevation 727.31') plus instrument channel instrument channelaccuracy accuracyabove abovethe the top top of of the storage racks the storage racks based based upon upon thethe design accuracy design accuracy (which(which is is to to bebe determined) determined) of of the the instrument instrument channel channel for for both both the the primary and primary and backup instrument channels.

backup instrument channels. ThisThismonitoring monitoring level level assures assuresthat waterisis thatwater covering the covering irradiated fuel the irradiated fuel seated seated in in the the racks.

racks.

Instruments:

The design The design of of the theinstruments instruments will will bebe consistent consistent withwith the the guidelines guidelines of of NRC NRC JLD-ISGJLD~ISG~-

2012~03 and 2012-03 and NEI NEI12~02. Specifically, the 12-02. Specifically, the channels channels will will be be designed designed as as discussed discussedbelow: below:

Primary Primary (fixed) instrument channel:

(fixed) instrument channel: The The primary primary instrument instrument channel level sensing channel level sensing components components will will bebe located located and and permanently permanently mounted mounted in in the the SFP.

SFP. The Theprimary primary instrument channel will instrument channel will provide provide continuous level indication continuous level indication overover a minimum range a minimum range of of approximately 26.86 approximately 26.86 feet feet from from the the high high pool level elevation pool level elevation of of 754.17' 754.17' to to the the top top ofof the spent the spent fuel fuel racks racks at at elevation elevation 727.31'.

727.31'. This This continuous continuous levellevel indication indication will will be be provided provided by by aa guided guided wavewave radar radar system, submersible pressure system, submersible pressure transducer, transducer, or or other other appropriate appropriate level level sensing technology that sensing technology that will will be be determined determined during during the the detailed detailed engineering design phase engineering design phaseof of the the project.

project.

Backup instrument channel:

Backup instrument channel: The The backup backup instrument instrument channel channel level level sensing sensing components components will also be will also be located located and and permanently permanently mounted mounted in in the the SFP.

SFP. The The backup backup instrument channel will instrument channel will provide provide continuous level indication continuous level indication overover aa minimum minimum range range of of approximately approximately 26.86 26.86 feet feet from from the the high high pool pool level level elevation elevation of 754.17' to of 754.17' the top to the top ofof the spent fuel the spent fuel racks racks at at elevation elevation 727.31'.

727.31'. This continuous level This continuous level indication indication will be will be provided provided by by the the same level sensing same level sensing technology technology as asthe theprimary primary instrument instrument channel.

channel.

Reliability:

Reliability:

Reliability Reliabilityofofprimary primaryand andbackup backup instrument instrument channels channels will will be be assured assured by by conformance conformance with with the the guidelines guidelines of of NRC JLD-ISG-2012-03and NRC JLD~ISG~2012~03 and NEINEI 12"02 12-02 as discussed below as discussed below under under Design Design Features Features and and Program Program Features.

Features. Both Bothprimary primaryand andbackup backuplevel level instrumentation instrumentation channels channels willwill bebe functional functional at at all all times times when there is when there is irradiated irradiated fuel fuel in in the the SFP,SFP,with with allowances allowances for for testing, testing, maintenance or repair per NEI 12-02. Reliability will be maintenance or repair per NEI 12-02. Reliability will be established established through through the the use use ofof an an augmented quality assurance augmented quality process (e.g.,

assurance process (e.g., aa process process similar similar to to that that applied applied to to the the site site fire fire protection protection program).

program).

33

Clinton Power Power Station, Station, Unit Unit11 Reliable Spent Fuel Pool Instrumentation Instrumentation Overall Integrated Plan Design Features Design Features Instrument Instrument Channel Channel Design:Design : Instrument Instrument channel channel designdesign willwill be be consistent consistent with with the the guidance guidance of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 and and NEI NEI 12-02.

12-02.

Arrangement: The Arrangement: current proposed The current proposed plan plan is is to install SFP to install level sensors SFP level sensors in in the the southwest southwest corner cornerand and onon thethe east side of east side of the the SFP SFP separated separated in in excess excess of of 20 20 feet.

feet.

The sensors themselves The sensors themselveswill will be be mounted, mounted, to to the the extent extent practical, practical, nearnearthe thepool pool walls walls and and belowbelow thethe pool pool curbcurb to to minimize minimize theirtheir exposure exposure to damaging debris to damaging debris and and notnot interfere interfere with withSFP SFP activities. Instrument channel activities. Instrument channel electronics electronics and and power powersupplies supplieswill will be located in be located in seismic seismic and and missile missile protected protected areas areas either either below below the the SFP SFP operating operating floor floor or in buildings or in buildings other other than than thethe Fuel FuelBuilding.

Building. The areas to The areas to bebeselected selectedwill will provide provide suitable radiation shielding suitable radiation shielding and and environmental environmental conditionsconditions for for the the equipment equipment consistent consistent with with instrument instrument manufacturer's manufacturer's recommendations.

recommendations. Equipment Equipmentand andcabling cabling for for power power supplies supplies and and indication indication for for each channel will each channel will be separated equivalent be separated equivalent to to that provided for that provided for redundant redundant safetysafety related services.

related services.

Mounting: Design Mounting: Design of of the the mounting mountingof ofthe the sensors sensors in in the SFP shall the SFP shall be be consistent consistent with with the the seismic seismic ClassClass II criteria.

criteria. Installed Installedequipment equipmentwill will be be verified verified to to be be seismically seismically adequate adequate for for the the seismic seismic motions motions associated associated with with the themaximum maximum seismic seismic ground ground motion considered in the design of the plant area in which it is installed.

motion considered in the design of the plant area in which it is installed.

Qualification: Reliability Qualification: Reliabilityofofboth both instrument instrument channels channels will willbe be demonstrated demonstrated via via anan appropriate combination of appropriate combination of design, analyses, operating design, analyses, operating experience, experience, and/or and/ortesting testingof of channel components for channel components for the the following following sets of parameters:

sets of parameters:

• • conditions conditionsinin the area of the area of instrument instrument channel channel component component use use for for all all instrument instrument components, components,

• • effects of effects of shock shock and and vibration vibration on on instrument instrument channelchannel components components used used during and during following any and following any applicable applicable event,event, andand

• • seismic effects seismic effects on on instrument instrument channel channel components components used usedduring duringand andfollowing following aa potential potential seismic seismic event.

event.

Temperature, humidity Temperature, humidityand and radiation radiationlevels levels consistent consistent with with thethe conditions conditions in in the the vicinity of vicinity of the SFP and the SFP and the the area area ofof use useconsidering consideringnormal normaloperation, operation, eventeventand andpost-post-event conditions for no fewer than seven days post-event or event conditions for no fewer than seven days post -event or until until off-site off-site resources resources can be can be deployed deployedby bythethemitigating mitigating strategies strategiesresulting resultingfromfrom Order Order EA-1EA-12-049 (FLEX) 2-049 (FLEX)

(Reference 4)

(Reference will be

4) will addressed in be addressed in the the detailed detailed designdesign engineering engineering phase phase of of the the 44

Clinton Clinton Power Power Station,Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan project.

project. Examples Examples of of post-event (beyond-design-basis) conditions post-event (beyond-design-basis) conditions to to be considered be considered are:

are:

• radiological radiological conditions conditions for for aa normal normal refueling refueling quantity quantity of of freshly freshly discharged discharged (100 (100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) hour) fuel fuel with with 8FPSFP water level 3 water level as described 3 as describedininOrderOrderEA-12-051, EA-12-051,

• • temperature temperature of 212 degrees of 212 degreesFFand and100%

1000/0relative relativehumidity humidity environment, environment,

• boiling boiling water water and/or and/or steam environment, steam environment,

• the impact of FLEX mitigating strategies.

Components Components of the instrument of the instrument channelschannels will will be be qualified qualified forfor shock shock and and vibration vibration using using one one oror more more of of the the following following methods:

methods:

• • components components are supplied by are supplied by manufacturers manufacturers using using commercial commercial quality quality programs programs (such (such as 1809001, "Quality as ISO9001, "Quality management management systems systems -

Requirements") with shock and vibration requirements included in Requirements") with shock and vibration requirements included in the the purchase specification at purchase specification levels commensurate at levels commensurate with with portable portable hand-held hand-held devices devices or or transportation transportation applications; applications;

• • components components have havesubstantial substantialhistoryhistoryofofoperational operationalreliability reliability inin environments environments with with significant significantshock shock and vibration loadings, and vibration loadings, suchsuch as as portable portable hand-held hand-held devices devices or or transportation transportation applications; applications; or or

• • components are components are inherently inherently resistant resistant toto shock shock and and vibration vibration loadings, loadings, suchsuch asas cables.

cables.

For For seismic seismic effects effects on on instrument instrument channelchannel components components used used after after aapotential potential seismic seismic event for event for only only installed installed components components (with (with the exception of the exception of battery battery chargers chargers and and replaceable batteries), the replaceable batteries), the following following measures measures will will be used to be used to verify verify that that the the design design and installation and installation is is adequate. Applicable components adequate. Applicable components are arerated ratedby bythethemanufacturer manufacturer (or otherwise (or otherwise tested) tested) for for seismic seismic effects effects atat levels levels commensurate commensurate with with those those of of postulated design postulated design basisbasis event event conditions conditions in in thethe area areaofofinstrument instrumentchannelchannel component use component useusing usingone oneorormoremoreofofthe thefollowing following methods:

methods:

• instrument channel instrument channel components components use known operating use known operating principles principles and and are are supplied by supplied by manufacturers manufacturers with with commercial commercial quality quality programs programs (such (such as as 1809001). The IS09001). Theprocurement procurementspecification specification and/or and/orinstrument instrument channel channel design design shall include shall include the seismic requirements the seismic requirements and and specify specify the the need needfor forcommercial commercial design and design and testing testing underunder seismic seismic loadings loadings consistent consistent with with design design basis basis values at values at the the installed installed locations; locations; 5

5

Clinton Clinton Power Power Station, Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan Plan

• • substantial history of substantial history of operational operational reliability reliability inin environments environmentswith withsignificant significant vibration, vibration, such such as as forforportable portablehand-held hand-held devices devices orortransportation transportation applications.

applications. Such Such aa vibration vibration design design envelope envelope shall shall bebe inclusive inclusive of of the the effects of effects seismic motion of seismic motion imparted impartedtoto the components proposed the components proposed at the at the location of location of the proposed installation; the proposed installation;

• • adequacy adequacy of of seismic seismic design design and and installation installation is demonstrated based is demonstrated based on on the the guidance guidance in in Sections Sections 7, 7, 8, 8, 9,9, and and1010ofofIEEE IEEEStandard Standard344-2004, 344-2004,"IEEE "I EEE Recommended Recommended Practice Practicefor for Seismic SeismicQualification Qualification of of Class Class11EEEquipment Equipmentfor for Nuclear Power Generating Nuclear Power Generating Stations",

Stations", or or aasubstantially substantiallysimilar similar industrial industrial standard; standard;

• demonstration demonstration that proposed devices that proposed devices are are substantially substantially similar similar in in design design to to models models that have been that have been previously previously testedtested forfor seismic seismic effects effects inin excess excess of of the the plant plant design design basisbasis at at the the location location where where thethe instrument instrument isis to to bebeinstalled installed (g-(g-levels levels and frequency ranges);

and frequency ranges); or or

• seismic qualification seismic qualification usingusing seismic seismic motionmotion consistent consistent with with that that of of existing existing design basis loading at the installation location. location.

Independence: The primary instrument instrument channel will be be independent independent of of the thebackup backup instrument channel.

instrument channel. This independence will This independence be achieved will be achieved through through physical physical and and electrical separation electrical separation of each channels' channels' components components commensurate commensurate with with hazard hazard andand electrical isolation needs.

needs.

Power Supplies: Each Power Supplies: channel will Each channel will be be normally normally powered powered from from aadifferent different 120Vac 120Vac bus.

bus. Upon loss of Upon loss of normal normal ac acpower, power,individual individual channel channel installed installed batteries batterieswill will automatically automatically maintain maintain continuous continuous channel channel operation.

operation. The batteries will The batteries will bebe replaceable replaceable and and bebe sized sized to tomaintain maintain channel channel operation operation until until off-site off-site resources resources can can be deployed by be deployed by the themitigating mitigating strategies strategiesresulting resulting from from OrderOrderEA-12-049.

EA-12-049.

Additionally, each Additionally, each channel channel will will have provisions for have provisions connection to for connection to another another suitable suitable power power source.

source.

Accuracy:

Accuracy: The The instrument instrument channels channels will will be designed to be designed to maintain maintain their their design design accuracy accuracy following followingaa power interruption or power interruption or change change in in power power source source without without recalibration. Instrument channel recalibration. Instrument channel accuracy, accuracy, to to be be determined determined duringduring detailed detailed design, design, will willconsider consider Spent Spent Fuel Fuel Pool Pool conditions conditions (e.g.,(e.g., saturated water, steam saturated water, steam environment, environment, etc), as etc), well as, as well as, other otherapplicable applicableradiological radiological and and environmental environmental conditions conditions and and include include display accuracy. Instrument display accuracy. Instrument channelchannel accuracy accuracy will will bebesufficient sufficient to toallow allow trained personnel to trained personnel to determine determine when when the the actual actual level level exceeds exceedsthe thespecified specifiedlowerlower 66

Clinton Clinton Power Power Station, Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan level level of each indicating of each indicating rangerange (levels (levels 1, 1, 22oror3)3)without withoutconflicting conflicting or or ambiguous ambiguous indications.

indications.

Testing: Instrument Testing: Instrument channel design will channel design will provide provide for routine testing for routine testing and and calibration calibration consistent with the guidelines of NRC JLD-ISG-2012-03 and NEI 12-02. Detailswill consistent with the guidelines of NRC JLD-ISG-2012-03 and NEI 12-02. Details will be determined during be determined during detailed detailed design engineering.

design engineering.

Display: The Display: primary and The primary backup instrument and backup instrument displays displays will will be be located located at at the the control control room, room, alternate alternate shutdown shutdown panel,panel, or other appropriate or other appropriate and and accessible accessible location.

location. The The specific location will be determined during detailed design. An appropriate and specific location will be determined during detailed design. An appropriate and accessible locationwill accessible location will include include thethe following following characteristics:

characteristics:

• occupied occupied or promptly accessible or promptly accessible to to the the appropriate appropriate plant plant staff staff giving giving appropriate appropriate consideration consideration to to various drain down various drain down scenarios, scenarios,

• • outside outside the area surrounding the area surrounding the the SFPSFP floor floor (e.g.,

(e.g., an an appropriate appropriate distance distance from from the radiological sources the radiological resulting from sources resulting from an event impacting an event impacting the Spent the Spent Fuel Pool),

Fuel Pool),

• inside inside aa structure structure providing providing protection protection against against adverse weather, and adverse weather, and

• outside outside of of any very high any very high radiation radiation areas areas or or locked locked high high rad rad area areaduring duringnormal normal operation.

operation.

Program Features Training: Personnel Training: Personnel perlorming performing functions associated with functions associated with thesethese SFP SFP levellevel instrumentation channels instrumentation channelswill willbe be trained trained to to perform perform the the jobjobspecific specificfunctions functions necessary necessary for for their their assigned tasks (maintenance, assigned tasks (maintenance,calibration, calibration, surveillance, surveillance, etc.). etc.). This This training will training will be be consistent consistent with with equipment equipment vendor vendor guidelines, guidelines, instructions instructions and and recommendations.

recommendations. The The Systematic Approach to Systematic Approach Training (SAT) to Training (SAT) will will be used to be used to identify identifythe population to the population to be trained and be trained and totodetermine determinethe theinitial initial andandcontinuing continuing elements of elements of the the required required training.

training. Training Training will will be completed prior be completed prior toto placing placing the the instrumentation in instrumentation in service.

service.

Procedures: Procedures Procedures: Procedures will will be be developed developed using using guidelines guidelines and and vendor vendor instructions instructions to address to address the the maintenance, maintenance, operation operation and and abnormal abnormal response response issues issues associated associated with the with the primary primary and and backup channels of backup channels of SFP SFPinstrumentation.

instrumentation.

Procedures will also address address the the following following situations:

situations:

• If, at If, at the the time time of of an an event eventor orthereafter thereafteruntil until the the unit unit isis returned returned to to normal normal service, an service, an instrument instrument channel channel ceases ceases to tofunction, function, its its function function will will be be 7

Clinton Clinton Power Power Station, Station, Unit Unit 11 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan Plan recovered within recovered within a period period of of time time consistent consistent withwith thetheemergency emergencyconditions conditions that may exist exist at at the the time.

time.

• • If, If, at the time at the time of of an an event eventor orthereafter thereafter until until the the unit unit isis returned returned to tonormal normal service, an instrument channel component must be replaced, it may be service, an instrument channel component must be replaced, it may be replaced replaced withwith aa commercially commercially available available component component that that mayor may or may may not meet not meet all all of the qualifications of the qualifications notednoted aboveabove to to maintain maintain instrument instrument channel channel functionality.

functionality.

Testing and Calibration:

Calibration: The testing and and calibration calibration of of the the instrumentation instrumentation will will be be recommendations or other documented basis.

consistent with vendor recommendations basis. Calibration Calibration will will be specific to the the mounted mounted instruments instruments and and thethe displays displays as asdetermined determinedduring duringthe the modification review process.

process.

Need for Relief Need Relief andand Basis:

Basis: Clinton Clinton Power Station is not Power Station not requesting requesting relief relief from from thethe requirements of Order EA-12-051 EA-12~051 or the guidance in in NRC NRC JLD-ISG-2012-03 JLO-ISG-2012-03 at at this this time.

time.

Consistent Consistent withwith the requirements of the requirements of Order Order EA-12-051 EA-12-051 and and the the guidance guidanceininNEI NEI12-02, 12-02, Exelon's Exelon's six-month six-month reports reports will willdelineate delineateprogress progressmade, made, any proposed changes any proposed changes in in compliance compliance methods, methods, updates updates to to the schedule, and the schedule, and ifif needed, needed, requests requests forfor relief relief and and their their basis.

basis.

References:

1.

1. NRC NRC Order Number EA-12-051, Order Number EA-12-0S1, OrderOrder Modifying Modifying Licenses Licenses withwith Regard Regard to to Reliable Reliable Spent Fuel Pool Spent Fuel Pool Instrumentation, Instrumentation, dateddated March March 12,12, 2012 2012 2.

2. NRC Interim Staff NRC Interim Staff Guidance JLO-ISG-2012-03, Compliance Guidance JLD-ISG-2012-03, Compliance with with Order Order EA-12-051, EA-12-0S1, Order Modifying Licenses Order Modifying Licenses with with Regard Regard to to Reliable Reliable Spent Fuel Pool Spent Fuel Pool Instrumentation, Instrumentation, Revision Revision 0, 0, dated August 29, dated August 29,2012 2012 3.

3. NEI 12-02, Industry NEI 12-02, Industry Guidance Guidance for for Compliance Compliance with with NRCNRC OrderOrder EA-12-051, EA-12-0S1, "To "To Modify Modify Licenses Licenses withwith Regard Regard to to Reliable Reliable SpentSpentFuel FuelPool PoolInstrumentation",

Instrumentation",

Revision Revision 1, 1, dated August 24, dated August 24, 2012 2012 4.

4. NRC NRC Order Order Number Number EA-12-049, EA-12-049, Order Order Modifying Modifying Licenses Licenses with Regard to with Regard to Requirements Requirements for for Mitigating Mitigating Strategies Strategies for for Beyond-Design-Basis Beyond-Oesign~Basis External External Events, Events, dated March 12, dated March 12,2012 2012 88