RS-13-035, 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)

ML13060A124
Person / Time
Site:	Quad Cities
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-13-035
Download: ML13060A124 (12)

Text

Exelon Generati on Order No. EA-12-051 RS-13-035 February 28, 2013 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

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 August 24, 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 (EGC). 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.

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

Reference Reference 3, Appendix A-2 3, Appendix A-2 contains contains thethe specific specific reporting reporting requirements requirements for for the the Overall Overall Integrated Integrated Plan. The information Plan. The information in in the enclosure provides the enclosure provides thethe Quad QuadCities CitiesNuclear NuclearPower PowerStation, Station,Units Units11 and and 22 Overall Overall Integrated Integrated Plan Plan pursuant pursuant to to Appendix Appendix A~2 A-2ofofReference Reference 3. The enclosed

3. The enclosed Integrated Integrated Plan Plan isis based based on on conceptual conceptual design information. Final design information. Final design design details details and and associated procedure associated procedure

guidance, guidance, as as well well as any revisions as any revisions toto the theinformation information contained contained in in the the Enclosure, Enclosure,willwill be be provided provided in the 6~month Integrated Plan updates required in the 6-month Integrated Plan updates required by Reference 1.

Reference 1.

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

commitments. If If you you have any questions have any questions regarding 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 declare under penalty of perjury that the foregoing is true and correct. Executed Executedon onthe the28"'

28 dayday th of February of February 2013.

2013.

Respectfully submitted, Respectfully submitted, Glen T.

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

Enclosure:

1. Quad

1. Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22 Reliable Reliable Spent SpentFuelFuelPool PoolInstrumentation Instrumentation (SFPI) Overall (SFPI) Overall Integrated Plan Integrated Plan cc:

cc: Director, Office Office ofof Nuclear Nuclear Reactor ReactorRegulation Regulation NRC Regional Regional Administrator Administrator--Region RegionIIIIII NRC Senior NRC Senior Resident Resident Inspector Inspector-- Quad QuadCities CitiesNuclear NuclearPower PowerStation, Station,Units Units11and and22 NRC Project NRC Project Manager, Manager, NRR NRR -- Quad Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22 Mr. Robert Mr. Robert J. Fretz,Jr, J. Fretz, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr.

Mr. Robert Robert L.L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB,NRC NRC Illinois Emergency Illinois ManagementAgency Emergency Management Agency- -Division Division ofof Nuclear Nuclear Safety Safety

Enclosure Enclosure 1 Quad Cities Quad Cities Nuclear Nuclear Power Power Station, Units 11 and and 22 Reliable Spent Fuel Pool Reliable Pool Instrument ation (SFPI)

Instrumentation (SFPI)

Overall Integrated Overall Integrated Plan (9 pages)

(9 pages)

Quad Cities Quad Cities Nuclear Power Station, Units 11 and and 22 Reliable Spent Reliable Spent Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Plan Applicability:

Applicabil ity:

This integrated This integrated plan plan applies applies to to Quad Quad Cities Nuclear Power Station, Units Units 11 and and 22and andisis based on based on current current conceptual design design information information and and will will bebe revised as as detailed detailed design design engineering proceeds. Consistent engineering Consistent with with the requirements requirements of of Order EA-12-051 (Ref.

Order EA-12-051 (Ref. 1) and the guidance and the guidance in NEI 12-02,in NEI 12 - 02, (Ref.

(Ref. 3) 3)Exelon's Exelon'ssix-month six-month reports reports will will delineate delineate progress made, progress made, any proposed proposed changes changes in in compliance compliance methods, methods, updates updates to to the the schedule schedule and, ifif needed, and, needed, requests requestsfor for relief relief and the basis. basis.

General

Description:

Quad Cities Station Quad Cities Station is is aa two two unit unit BWR BWRStation.Station. The The twotwo units units share share a common Reactor a common Reactor Building Building(RB) (RB)refueling refuelingfloor floorandandtwo twointerconnected interconnectedSpent SpentFuel Fuel Pools Pools (SFP). Normal (SFP). Normal SFP water level SFP water level isis approximately approximately at at elevation elevation689' 689' 6". Top of 6". Top of the the spent spent fuel fuel racks racks isis elevation elevation 666'666' 2"2" and and top top ofof active active fuel fuel isis elevation elevation 665' 665' 5"5" (Ref.

(Ref. 5).

5).

Note:

Note: In In all all subsequent subsequent discussions discussionsininthis thisplan planunless unlessotherwise otherwisenoted, noted,dimensions dimensionswill will be referenced to be referenced to elevation elevation666' 666'2" 2"which which isisthe thetoptopofofthe thefuel fuelracks racksinineither eitherunit.

unit.

Schedule:

The installation The installation of of reliable reliable level level instrumentation instrumentation for for the the SFPs associatedwith SFPs associated withUnit Unit11and and Unit 22 is Unit is scheduled scheduled for for completion completion by by the the endend ofof Q1Q1 R23 R23 (Spring (Spring 2015) 2015) based based onon the the end end of the of second refueling the second refueling outage outage for for Unit Unit 11 following submittal of following submittal ofthis thisintegrated integrated plan. This plan. This is the is the earlier earlier outage outage sequence sequence of of the the units units discharging discharging to to the the pools.

pools. UnitUnit11and andUnit Unit22 discharge irradiated discharge irradiated fuelfuel toto a set of a set of two two interconnected interconnected spent spent fuelfuel storage storage pools.

pools. With With the exception the exception of of limited limited timetime periods periods for for maintenance maintenance orornon-refueling non-refueling operations, operations, administrative controls administrative controls maintain maintain the the gates between the gates between the following following poolspools open: Unit 11 SFP open: Unit SFP and the and the Transfer Transfer Canal, Canal, and and Unit Unit 2 SFP and 2 SFP and the the Transfer Transfer Canal.

Canal. Thus, Thus,the theUnit Unit11andand Unit 22 pools Unit pools are are normally normally interconnected interconnected and and at the same at the same waterwater level level when when thethewater water level in level in either either SFP SFP is is 11 foot foot above above the the top top of of the spent fuel the spent fuel storage storage racks.

racks.

The The current current milestone milestoneschedule scheduleisisas asfollows:

follows:

• Complete Complete Conceptual Conceptual Design Design(CD) (CD)for forPilot PilotPlant Plant(Limerick)

(Limerick) Complete Complete

+* Complete Complete CD CD Follow-up Follow-up Walkdowns Walkdowns at atRemaining Remaining 99Exelon Exelon SitesSites Complete Complete 11

Quad Cities Quad Cities NuclearNuclear Power Station, Units 11 and and 22 Reliable Spent Reliable Spent Fuel Pool Instrum Instrumentation entation Overall Integrated Overall Integrated Plan

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

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

• . Submit Integrated Plan Submit Complete Complete with with this submittal

• • Begin Detailed Begin Detailed Engineering Design 2Q2013 202013

• Order SFP Instrumenta Order Instrumentation tion 2Q2013 202013

• Complete Complete and Issue SFPI and Issue SFPI Modificatio Modificationn Package Package 1Q2014 102014

• • Begin SFPI Installation Begin Installation 4Q2014 402014

• • Complete Complete SFPI SFPllnstallation Installation and Put Into Into Service Service 1 Q2015 102015 Identification of Identification of Spent Spent FuelFuel Pool PoolWater WaterLevels:

Levels:

Key spent fuel pool water water levels levels (Ref.

(Ref. 3)3) will will be beidentified identifiedas asfollows:

follows:

Level adequate to Level adequate to support support operation operation of the the normal normal fuel fuel pool pool cooling coolingsystem system (L1):

(L 1): For For both both units, indicated indicated level either primary level on either primary or or backup backup instrument instrumentchannelchannel must be greater than 23 must be greater than 23feet feet1 1inch inch(elevation (elevation689' 689'3") 3")plus plusinstrument instrumentaccuracy accuracy above the top of above the top of the storage racks based on storage racks based onthe thedesign designaccuracy accuracyof ofthe theinstrument instrument channel (which channel determined) and (which is to be determined) and aaresolution resolution of of 11foot foot or orbetter betterfor forboth boththe the primary and primary and backup backup instrument instrumentchannels.

channels. This This is is based based on on the the1111 inch inchopening opening of of the SFP weir gate design demonstrating the SFP weir gate design demonstrati ng aawater waterlevellevelabove above23 23feet feet1 1inch inch(elevation (elevation 689' 3") is adequate for normal fuel pool cooling system 689' 3") is adequate for normal fuel pool cooling system operation.

operation.

Level Level adequate adequate to to provide provide substantial substantialradiation radiation shielding shieldingfor for aaperson personstanding standing on the spent fuel pool on the spent fuel pooloperating operatingdeck deck(L2): (L2): For For both both units, units, indicated indicated levellevel on on either the either the primary primary or or backup backup instrument instrument channel channel of of greater greater than than10 10feet feet(elevation (elevation 676' 2")

676' 2") plus plus instrument instrument channel channel accuracy accuracy above above the the top top of of the the storage storage racks racks based based on specification of on specification of this this level level as asadequate adequateininNRC NRCJLD-ISG-20 JLD-ISG-2012-03 12-03 (Ref.(Ref.2)2)andandNEI NEI 12-02 (Ref. 3), the specified design 12-02 (Ref. 3), the specified design accuracy accuracy of of the theinstrument instrument channel, channel, and andthethe relatively low relatively low sensitivity sensitivityofofdosedose rates rates toto changes changes in in water water depth depth at atthis thislevel.

level. This This monitoring level monitoring level ensures ensures there isis an anadequate adequatewater waterlevelleveltotoprovide providesubstantial substantial radiation shielding radiation shielding for a personperson standing standingon onthe thespent spentfuelfuelpoolpooloperating operatingdeck deck from from direct gamma radiation from stored direct gamma radiation from stored spent spentfuel.

fuel.

22

Quad Cities Quad Cities Nuclear Power Station, Units Units 11 and and 22 Reliable Spent Fuel Pool Reliable Pool Instrumentation Instrumentation Overall Overall Integrated Plan Level where Level where fuel remains remains covered covered(L3): (L3): For For both units, indicated both units, indicated levellevel onon either either the primary or the primary or backup backup instrument instrument channel channel of of greater greater than than 0 0 feet feet (elevation (elevation666' 666'2") 2")

plus plus instrument instrument channel channel accuracy accuracy above above the the top top of of the the storage storage racks based upon racks based upon thethe design (which is accuracy (which design accuracy to be is to be determined) determined) of of the the instrument instrument channelchannel for for both both the the primary primaryand and backup backup instrument instrument channels.

channels. ThisThis monitoring monitoring level level assures assures thatthat water water is is covering covering thethe stored stored fuel fuel seated seated in in the racks.

the racks.

Instruments:

The design of The design of the the instruments instrumentswill will be be consistent consistentwith with the theguidelines guidelinesofofNRC NRCJLD-ISG-JLD-ISG-2012-03 (Ref. 2) 2012-03 (Ref. 2) and and NEINEI 12-02 12-02 (Ref.

(Ref. 3). Specifically, the 3). Specifically, channels will the channels will bebe designed designed as as discussed below:

discussed below:

Primary (fixed)

Primary (fixed) instrument channel: channel: The primary instrument The primary instrument channelchannel level level sensing sensing components components will willbe be located located and and permanently permanentlymountedmountedininthe the Unit Unit11 SFP.SFP. The The primary primary instrument instrument channel channel willwill provide provide continuous continuous level level indication indication overover aaminimum minimum range range ofof approximately approximately 23 23 feet feet 77 inches inchesfrom from thethehigh highpoolpoollevel levelelevation elevationof of689' 689'9" 9" (Normal ++ 3")

(Normal 3")totothe thetoptop of ofthe the spent spent fuel fuel racks racks atat elevation elevation 666' 666' 2".2". This This continuous continuous level indication will be level indication will provided by be provided by aa guided guided wavewave radar radarsystem, system,submersible submersible pressure transducer, or pressure transducer, or other other appropriate appropriate levellevel sensing sensing technology technology that that will will be be determined determined during during the detailed engineering the detailed engineering design phaseofofthe design phase theproject.

project.

Backup Backup instrument instrument channel:channel: The The backup backup instrument instrument channel channel level level sensing sensing components will components willbe be located located and and permanently permanentlymountedmountedininthe the Unit Unit22 SFP.SFP. The The backup instrument backup instrument channel channel willwill provide provide continuous continuous levellevel indication indication overover aa range rangefromfrom the high the high pool pool level level elevation elevation thethe same same as as primary primary to to the the top top ofof the the spent spent fuel fuel racks racks at at elevation the elevation same as the same asprimary.

primary.This Thiscontinuous continuouslevellevelindication indicationwill beprovided will be providedby by the same level sensing technology as the primary instrument channel.

the same level sensing technology as the primary instrument channel.

Reliability:

Reliability:

Reliability of Reliability ofprimary primaryand and backup backup instrument instrument channels channels will will be assured by be assured byconformance conformance with the with the guidelines guidelines of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 (Ref. (Ref.2)2) and and NEI NEI 12-02 12-02 (Ref.(Ref. 3)3) asas discussed below under Design Features and Program Features sections. Both primary discussed below under Design Features and Program Features sections. Both primary and backup and backup level level instrumentation instrumentation channels channelswill will be be functional functional at at all all times times when when there there isis fuel in fuel in the SFP with the SFP with allowance allowance for for maintenance, maintenance, testingtesting or or repair repair as asdescribed describedininNEI NEI 12-12-02 (Ref.

02 (Ref. 3).

3). Reliability Reliability will will be be established established through through the the use use of of an anaugmented augmentedquality quality assurance process (e.g., a process similar to that applied to the site fire protection assurance process (e.g., a process similar to that applied to the site fire protection program).

program).

33

Quad Cities Quad Cities Nuclear Nuclear Power Station, Units 1 and 22 Reliable Spent Reliable Spent Fuel Pool Instrume Instrumentation ntation Overall Integrated Overall Integrated Plan Design Features Design Features Instrument Channel Instrument Channel Design:

Design: Instrument Instrument channelchannel design design willwill bebe consistent with the consistent with the guidance guidance of of NRC JLD-ISG-201 JLD-ISG-2012-03 (Ref. 2) 2-03 (Ref. 2) and and NEI NEI 12-02 12-02 (Ref.

(Ref. 3).3).

Arrangement: The Arrangement: The current current planplan is is to install SFP to install level sensors SFP level sensors in in the the southwest southwest corner of the Unit 1 SFP corner of the Unit 1 SFP and in the in northwest corner the northwest corner of of the Unit 22 SFP the Unit separated by SFP separated by aa distance distance in in excess of of 50 feet.

feet. TheThesensors sensorsthemselves themselveswill will be be mounted, mounted, to to the the extent extent practical, practical, near near the pool walls the pool walls and and below below the the pool pool curb curb to tominimize minimize their their exposure to exposure damaging debris to damaging debris and and not not interfere interfere withwith SFP activities. Instrument SFP activities. Instrument channel electronics and power supplies will channel electronics and power supplies wi" be located in be located in seismic seismic and and missile missile protected protected areas either below areas either below the SFP SFP operating operating floorfloor oror in in buildings buildings other than other than the the RB.

RB. The The areasareas to to be beselected selectedwill willprovide provide suitable suitable radiation radiation shielding shielding and and environmental conditions for environmenta l for the the equipment equipment consistent consistent with with instrument instrument manufacturer's recommendations. Equipment and manufacturer 's recommenda tions. Equipment and cabling cabling for for power power supplies supplies andand indication indicationfor for each channel will each channel will be separated equivalent be separated equivalent to to that that provided provided for for redundant redundant safety safety related services as as required required by by the the Quad Quad Cities Cities design design basis.

basis.

Mounting:

Mounting: Design Design of of the the mounting mounting of ofthethe sensors sensors in in the SFP shall the SFP shall bebe consistent consistent with the with the seismic seismic Class Class II criteria.

criteria. Installed Installedequipment equipmentwill will be beverified verified to to be beseismically seismically adequate for adequate for the the seismic seismic motions motions associated associatedwith with the themaximum maximum seismic seismicground ground motion considered motion considered in in the the design designof ofthe theplant plantarea areaininwhich whichititisisinstalled.

installed.

Qualification Qualification:  : Reliability Reliability ofofbothboth instrument instrument channels channels will will be be demonstrated demonstrated via via an an appropriate combination appropriate combination of of design, analyses, operating design, analyses, operating experience, experience, and/orand/ortesting testingofof channel components channel componentsfor forthe thefollowing following setssets of of parameters:

parameters:

• conditions inin the conditions area of the area ofinstrument instrument channelchannel component component use use forfor allall components, instrument components,

• effects effects of of shock shock and and vibration vibration on oninstrument instrumentchannelchannelcomponents components used used during during and and following following anyanyapplicable applicableevent, event,and and

• • seismic seismic effects effects onon instrument instrument channel channel components components used used during duringand andfollowing following aa potential seismic potential seismic event.event.

Temperature,, humidity Temperature humidity and radiation levels and radiation levels consistent consistent with with the conditions inin the the conditions the vicinity of vicinity of the the SFP SFP and the area area of of use useconsidering considering normalnormal operation, operation, eventeventandandpost-post-event conditions for no fewer than event conditions for no fewer than seven sevendays dayspost-event post-eventororuntil untiloff-site off-siteresources resources 44

Quad Cities Quad Cities NuclearNuclear Power Station, Units Units 11 and and 22 Reliable Spent Fuel Pool Reliable Pool Instrumentation Instrumentation Overall Integrated Plan Overall can can be be deployed deployed by by the the mitigating mitigating strategies strategiesresulting resultingfrom from Order OrderEA-12-049 (Ref. 4)

EA~12~049 (Ref. 4) will willbe beaddressed addressed in in the the detailed detailed design design engineering engineering phasephase ofof the the project.

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

• • radiological radiologicalconditions conditionsfor for aa normal normal refueling refueling quantity quantity ofof 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 with8FPSFP water level 33 as water level describedinin Order as described OrderEA-12-051, EA-12-051,

• • temperature temperature of of 212 degrees FFand 212 degrees and100%

1000/0relative relative humidity humidity environment, environment,

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

• • a concentrated borated water environment, and

• the impact of FLEX mitigating strategies.

Components Components of of the the instrument instrument channels channels willwill be bequalified qualified for for shock shockand andvibration vibration using one or or more more of of the the following following methods:

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

Requirements") with with shock shock andand vibration vibration requirements requirements included included inin the the purchase specification at levels commensurate with portable hand-held purchase specification at levels commensurate with portable hand-held device or or transportation transportation applications; applications;

• • components have components havesubstantial historyofofoperational substantialhistory operationalreliability reliabilityininenvironments environments with significant with significant shockshock and vibration loadings, and vibration loadings, such such asasportable portablehand-held hand-held applications; or device or transportation applications; or

• components are are inherently inherently resistant resistant toto shock shockandandvibration vibrationloadings, loadings,such suchasas cables.

cables.

seism ic effects For seismic For effects on on instrument instrument channel channel components components used usedafter afteraapotential potentialseismic seismic event for event for onlyonly installed installed components components (with (with the exception of the exception of battery battery chargers chargers and and replaceable batteries),

replaceable batteries), thethefollowing following measures measureswill be used will be usedtotoverify verify that that the thedesign designand and installation is adequate. Applicable installation is adequate. Applicable components components are rated by are rated by the themanufacturer manufacturer (or (or otherwise tested) for seismic effects at levels commensurate with those of postulated otherwise tested) for seismic effects at levels commensurate with those of postulated design basis design basis event eventconditions conditions in in the the area areaofofinstrument instrument channel channel component component use useusing using oneor one ormore moreof of the thefollowing following methods:

methods:

55

Quad Quad Cities Cities NuclearNuclear Power Power Station, Units 1 and 2 Reliable Spent Reliable Spent Fuel Pool Instrumentation Instrumentation Overall Integrated Overall Integrated Plan

• instrument instrumentchannel channel components components use known operating use known operating principles principles and and areare supplied supplied by manufacturers with by manufacturers with commercial commercial quality quality programs programs (such (such as as IS09001).

IS09001). The Theprocurement procurementspecification specification and/or and/or instrument instrument channel channel design design shall shall include include the the seismic requirements and seismic requirements and specify specify the the need need for for commercial commercial design design and testing under and testing under seismic seismic loadings loadings consistent consistent withwith design design basisbasis values at the installed installed locations; locations;

• • substantial history of substantial history of operational operational reliability reliability in in environments environments with with significant significant vibration, suchsuch as as forforportable portablehand-held hand-held devices devices orortransportation transportation applications. Such Such aa vibration vibration design design envelope envelope shall be inclusive shall be inclusive of of the the effects of effects seismic motion of seismic motion imparted imparted to to the components proposed the components proposed at at the the location location ofof the proposed proposedinstallation; installation;

• • adequacy adequacy of of seismic seismic design design andand installation installation is demonstrated based is demonstrated based on on the the guidance in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, "IEEE guidance in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, "IEEE Recommended Recommended Practice Practice forfor Seismic SeismicQualification Qualification of of Class Class11EE Equipment Equipment for for Nuclear Power Generating Nuclear Power Generating Stations",

Stations", or or aasubstantially substantiallysimilar similarindustrial industrial standard;

• • demonstration that demonstration that proposed devices are proposed devices are substantially substantially similar similar in in design design to to models that models that have have been been previously previously tested tested for for seismic seismic effects effects inin excess excess of of the the plant design plant basis at design basis at the the location location where where the the instrument instrument is is to to bebe installed installed (g- (g-levels and frequency ranges); or levels and frequency ranges); or

• seismic seismic qualification using seismic qualification using seismic motion motion consistent consistent with with that that of of existing existing design basis basis loading loading atat the the installation installationlocation.

location.

Independence:

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

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

needs.

Power Power Supplies:

Supplies: Each Each channel channel willwill be be normally normally poweredpowered from from aadifferent different 120Vac 120Vac bus. Upon bus. Upon loss loss ofof normal normal acacpower, power,individual individualchannelchannelinstalled installedbatteries batterieswill will automatically maintain automatically maintain continuous continuous channel operation. The channel operation. batteries will The batteries will be be and be replaceable and replaceable besized sizedtotomaintain maintainchannel channeloperation operationuntil untiloff-site off-site resources resourcescan can be deployed be deployedby bythe themitigating mitigating strategies strategiesresulting resultingfrom fromOrder OrderEA-12-049 EA-12-049(Ref. (Ref.4). 4).

66

Quad Cities Nuclear Power Station, Quad Station, Units Units 11and and 22 Reliable Spent Spent Fuel Fuel PoolPool Instrumentation Instrumentation Overall Integrated Plan Plan Additionally, Additionally,each each channel channel will will have provisions for have provisions connection to for connection to another another suitable suitable power power source.

source.

Accuracy: The instrument channels The instrument 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 sourcewithout without recalibration. Instrument channel recalibration. Instrument accuracy, to channel accuracy, be determined to be determined during during detailed detailed design, design, will willconsider Spent Fuel consider Spent Fuel Pool Pool conditions conditions (e.g.,

(e.g., saturated water, steam saturated water, steam environment, environment, concentrated concentrated borated water), as borated water), as well well as other applicable as other applicable radiological radiological and and environmental environmental conditions, conditions,and include display and include display accuracy.

accuracy. Instrument channel Instrument channel accuracy accuracy will will be sufficient to be sufficient to allow allow trained trained personnel personnel to determine when to determine when thethe actual actual level level exceeds exceeds the the specified specified lower lower level level of each indicating of each indicating range (levels 1, range (levels 1, 22 or or 3) 3)

without conflicting without conflicting or or ambiguous indications.

ambiguous indications.

Testing: Instrument Instrument channel design will channel design will provide provide for for routine routine testing testing andand calibration calibration consistent consistent withwith the the guidelines guidelines of NRC JLD-ISG-2012-03 of NRC JLD-ISG-2012-03 (Ref. (Ref. 2)2) and andNEINE112-02 (Ref.

12-02 (Ref.

3).

3). Details Details will willbebe determined determined during during detailed design engineering.

detailed design engineering.

Display: The primary and The primary and backup backup instrument instrument displays displays willwill be be located located atatthe thecontrol control room, room, alternate alternate shutdown shutdown panel, panel, or or other other appropriate appropriate and and accessible location. The accessible location. The specific location will specific location will be determined during be determined during detailed detailed design.

design. An appropriate and An appropriate and accessible locationwill accessible location will include include the the following following characteristics:

characteristics:

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

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

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

Fuel Pool),

• i inside inside a structure providing a structure providing protection protection against against adverse weather, and adverse weather, and

• outside outside of of any any Very Very High High radiation radiation areas areasororLOCKED LOCKEDHIGH HIGHRAD RADAREAAREA during normal operation.

during normal operation.

Program Features:

Training: Personnel performing functions Personnel performing functions associated associated with with these these SFP SFP level level instrumentation instrumentationchannels channelswill willbe be trained trained toto perform perform the the jobjobspecific specificfunctions functions 7

QuadCities Quad Cities Nuclear Nuclear Power Power Station, Units 1 and 2 Reliable Spent Reliable Spent Fuel Pool Instrum Instrumentation entation Overall Integrated Overall Integrated Plan necessary necessary for for their their assigned assigned tasks (maintenance, tasks (maintenanc calibration, surveillance, e, calibration, surveillance, etc.). This etc.). This training trainingwill willbebeconsistent consistent withwithequipment equipment vendor vendor guidelines, guidelines, instructions instructions and and recommendations.

recommendations.The The Systematic Systematic Approach Approach to Training (SAT) to Training (SAT) will willbe be used used to to identify the population toto be identify the population be trained trained and and toto determine determine the theinitial initial and andcontinuing continuing elements of the required training. Training elements of the required training. Training willwill be completed prior be completed prior to placing the to placing the instrumentation instrumentation in in service.

service.

Procedures: Procedures Procedures: Procedures will will be be developed developed usingusing guidelines guidelines and and vendor vendor instructions instructions to address the maintenance, to address the maintenanc operation and e, operation abnormal response and abnormal response issues associated issues associated with the primary and backup channels of SFP instrumenta with the primary and backup channels of SFP instrumentation.

tion.

Procedures will also address the following Procedures following situations:

situations:

• • If, If, at the time at the time ofof an an event event or orthereafter thereafter until until the the unit unit isis returned returned to to normal normal service, an instrument channel service, an instrument channel ceases ceases to to function, function, its its function function will will bebe recovered recovered within within aa period period of of time time consistent consistent withwith the the emergency emergencyconditions conditions that that maymay existexist at at the the time.

time.

• If, at the If, at the timetime ofof an an event eventor orthereafter thereafteruntiluntil the the unit unit isis returned returned to tonormal normal service, an instrument channel service, an instrument channel component component must must be replaced, itit may be replaced, may be be replaced with replaced with a commercially a commercial ly available available component component that mayor may that may or may not meet not meet all of all of thethe qualificati qualifications noted above ons noted above totomaintain maintaininstrument instrument channel channel functionality..

functionality Testing Testing and andCalibration Calibration:  : The The testing testing andandcalibration calibrationof ofthe theinstrumenta instrumentationtion willwill bebe consistent with consistent with vendor vendor recommend recommendations ations or or other other documented documentedbasis. basis.Calibration Calibrationwill wi" be specific to the be specific to the mounted mounted instruments instruments and and thethe displays.

displays. Instrument Instrumentperformanc performance e will be trended as described in Exelon procedural will be trended as described in Exelon procedural requirement requirements. s.

Need Need forfor Relief Relief and and Basis: Quad Cities Basis: Quad Cities isisnot notrequesting requestingrelief relieffrom from the therequirement requirements s of Order EA-12-051 (Ref.

of Order EA-12-051 (Ref. 1)1) or or the the guidance guidanceininNRC NRCJLD-ISG-20 JLO-ISG-2012-03 (Ref. 2) 12-03 (Ref. 2) at atthis this time.

time.

Consistent with Consistent with the therequirement requirements s ofofOrder OrderEA-12-051 EA-12-051(Ref. (Ref. 1)1) and andthetheguidance guidanceininNRC NRC JLO-ISG-2012-03 (Ref. 2),

JLD-ISG-20 12-03 (Ref. 2), Exelon's Exelon's six-month six-month reports reports will will delineate progress made, delineate progress made,any any proposed changes in compliance methods, updates proposed changes in compliance methods, updates to to the theschedule, schedule,and andif ifneeded, needed, requestsfor requests forrelief relief and andtheirtheirbasis.

basis.

88

Quad Cities Quad Cities Nuclear Nuclear Power Station, Units 11 and 22 Reliable Spent Reliable Spent Fuel Pool Instrumentation Instrumentation Overall Overall Integrated Plan

References:

1. NRC

1. NRC Order Order Number Number EA-12-051, EA-12-051, Order Modifying Modifying Licenses with Regard Regard toto Reliable Reliable Spent Fuel Spent Fuel Pool Pool Instrumentation, Instrumentation, dated March 12, 2012 2.

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

3. NEI NEI 12-02, Industry Guidance 12-02, Industry Guidance forfor Compliance Compliance withwith NRC NRC Order Order EA-12-051, EA-12-051, "To"To Modify ModifyLicenses Licenses with with Regard Regard toto Reliable Reliable Spent Spent Fuel FuelPool PoolInstrumentation",

Instrumentation",

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

4. NRC Order Number NRC Order 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 for Beyond-Design-Basis Strategies for Beyond-Design-Basis External External Events, Events, dated March 12, dated March 12, 2012 2012 5.

5. Quad Cities UFSAR Quad Cities UFSAR Chapter Chapter 9.1 9.1 99