RS-13-030, 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)

ML13060A125
Person / Time
Site:	Dresden
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-13-030
Download: ML13060A125 (11)

Text

Exelon Generati on Order No. EA-12-051 RS-13-030 February 28, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

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. NE112-02, 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. Nuclear Regulatory Commission U.S.

Integrated Plan ReportReport to to EA-12-051 EA-12-051 February 28,2013 28, 2013 Page 2 Reference 44 provided provided the the EGC EGC initial status report initial status report regarding regarding reliable reliable spent spentfuel fuelpool pool instrumentation, as required by Reference instrumentation, Reference 1. 1.

Reference 3, Reference 3, Appendix Appendix A-2A-2 contains contains the the specific specificreporting reporting requirements requirementsfor forthe theOverall OverallIntegrated Integrated Plan. The Plan. The information information in the enclosure enclosure provides provides thethe Dresden DresdenNuclear NuclearPower PowerStation, Station,Units Units22 and 3 Overall Overall Integrated Plan pursuant pursuant to to Appendix Appendix A-2 of Reference A-2 of Reference 3. TheTheenclosed enclosedIntegrated Integrated Plan is Plan is based on on conceptual design information.

information. Final Final design details and associated associated procedure procedure guidance, as aswell well as asany anyrevisions revisionstotothetheinformation informationcontained containedininthe theEnclosure, Enclosure,will will be beprovided provided in the in the 6-month 6-month Integrated Integrated Plan updates updates required required byby Reference Reference1.1.

This letter contains no new regulatory commitments.

This commitments. IfIf you have have any any questions questionsregarding regardingthisthis report, please report, please contact contactDavid David P. P. Helker Helkerat at610-765-5525.

610-765-5525.

I declare under penalty of perjury that the foregoing is true and and correct.

correct. Executed Executedon onthe 28th day the28th day of February 2013.

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

Enclosure:

1. Dresden Nuclear Nuclear Power Power Station, Station, Units Units 22 and and33Reliable ReliableSpent SpentFuel FuelPool PoolInstrumentation Instrumentation (SFPI) Overall Integrated Plan Plan cc: Director, Office of of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region Region III III NRC Senior NRC Senior Resident Inspector -- Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 22 and and 33 NRC NRC Project Manager, NRR NRR Dresden Nuclear Power Station, Units 2 and33

- Dresden Nuclear Power Station, Units 2 and Mr.

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

Enclosure 11 Enclosure Dresden Nuclear Dresden Nuclear Power Power Station, Station, Units Units 22 and and 33 Reliable Spent Reliable Spent Fuel Fuel Pool PoolInstrumentation Instrumentation(SFPI)

(SFPI)

Overall Integrated Overall Integrated Plan Plan (8 pages) pages)

Dresden Nuclear Dresden Nuclear Power Power Station, Station, Units Units 22 and and 33 Reliable Spent Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Overall Integrated Plan Plan Applicabi lity:

Applicability:

This integrated plan This integrated plan applies applies to to Dresden Dresden Station, Units 22 and Station, Units and 3 and is is based basedon oncurrent current conceptual design information and will be revised as detailed conceptual design information and will be revised as detailed design engineering design engineering proceeds. Consistent with proceeds. the requirements of Order EA-12-051' with the EA~12-0511 and the the guidance guidanceinin 3

NEI 12-023, NEI 12-02 Exelon's six-month

, Exelon's six-month reports reports will willdelineate delineate progress progress made,made, anyany proposed proposed changes in in compliance methods, updates to compliance methods, to the the schedule schedule and, and,ifif needed, needed,requests requestsfor for relief and relief and the basis.

basis.

General

Description:

Dresden Station Dresden Station isis aa two two unit unit BWR BWR Station.

Station. The The twotwo units units each each have have aadedicated, dedicated, unconnected unconnected Spent Spent Fuel Fuel Pool Pool (SFP) locatedininthe (SFP) located theReactor ReactorBuilding Building (RB).

(RB). Normal NormalSFP SFP level isis approximately water level water approximately elevation elevation 612 612'5.'5 . Top Top of of thethe spent spent fuel fuel racks racks is is 7

approximately elevation approximately elevation 589,6 589'6 and top of and top of active active fuel fuel isis approximately approximately elevation elevation 5877 587, . .

Schedule:

The installation installation ofof reliable reliable level level instrumentation instrumentation for for the the SFP SFP associated associatedwith withUnit Unit22isis scheduled for scheduled for completion completionby by the the end end ofof D2R24 D2R24 (Fall 2015) based (Fall 2015) based on on the the end endofofthethe second refueling refueling outage outage forfor Unit Unit 22following following submittal submittal of this this integrated integrated plan.

plan. The installation of of reliable reliable level level instrumentation instrumentation for forthethe SFP SFP associated associated with with Unit Unit 33 isis scheduled for scheduled for completion completion by by the the end end ofof D3R24 D3R24 (Fall 2016) based (Fall 2016) based on on the the end endofofthe the second refueling second refueling outage outageforforUnit Unit33following following submittal submittal of of this this integrated integratedplan.plan.

The current milestone milestone schedule schedule isis asas follows:

follows:

• Complete Conceptual Complete ConceptualDesign Design(CD)(CD)forforPilot PilotPlant Plant(Limerick)

(Limerick) Complete

• Complete CD Follow-up Walkdowns at Remaining 9 Exelon Follow-up Walkdowns Exelon Sites Sites Complete

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

• Submit Initial 60-day Status Report Report Complete

• Submit Integrated Plan Complete with Complete with this submittal submittal

• Procure SFP Instrumentation Instrumentation I Q2015 102015

• Begin Detailed Engineering Design Begin Design for for Unit Unit 2 1Q2014 102014

• Complete and Issue IssueSFPI SFPIModification Modification Package Packagefor for Unit Unit 2 3Q2014 302014 11

Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 2 2 andand 33 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan

• Begin Detailed Engineering Engineering Design Design for for Unit Unit33 402014

• Complete and Issue SFPI Modification Package Package for Unit Unit 33 202015

• Begin SFPI Installation for for Unit Unit 22 302015

• Complete SFPI Installation for Unit Unit 2 and Put Put Into Into Service Service 4Q2015 402015

• Begin SFPI Installation Installation for for Unit Unit 33 2Q2016 202016

• Complete SFPI Installation for Unit 3 and Put Put Into Into Service 402016 Identification of Spent Spent Fuel Fuel Pool Pool WaterWater Levels:

Levels:

Key spent fuel pool waterwater levels levels will will bebe identified identifiedas asfollows:

follows:

Level Level adequate adequate to support operation to support operation of the normal of the normal fuel pool cooling fuel pool cooling system system (Level (Level 1): For both 1): For both units, units, indicated indicated level level onon either either primary primary or or backup backupinstrument instrument channel of channel of greater than than 2323 feet feet(elevation (elevation 612')

612') plus plusinstrument instrumentchannel channelaccuracy accuracy above the top of the storage racks racks basedbasedon onthe thedesign designaccuracy accuracyofofthe theinstrument instrument channel (which (which is is to be determined) determined) and and aaresolution resolution of of11foot footor orbetter betterforforboth boththethe primary and primary and backup backup instrument instrumentchannels.channels. This is based based on on the theheight heightof of the theSFP SFP weirs, demonstrating weirs, demonstrating a water level level of 23 feet feet (elevation (elevation 612') 612') above above thethetoptopofofthethe storage racks storage racks isis adequate adequatefor fornormal normalfuel fuel pool pool cooling cooling system system operation.

operation.

Level Level adequate adequate to provide substantial to provide substantial radiationradiation shielding shielding for for a a person person standing standing on the spent on the spent fuelfuel pool pool operating operatingdeck deck(Level (Level2): 2): For both units, indicated level level on on either the primary either primary or backup instrument instrument channel of of greater greater than than 10 10feet feet(elevation (elevation 599') plus instrument 599') instrument channel channel accuracy above the top top ofof the storage storage racks racksbasedbasedon on specification of this level as as adequate adequateininNRC NRCJLD-ISG-2012-032 JLD-ISG-2012-03 and 2 andNEI NEI 12-023, 12-02 , the 3

the specified design accuracy accuracyof of the theinstrument instrumentchannel, channel,and andthe therelatively relativelylowlowsensitivity sensitivity of dose rates of rates to to changes changesininwater waterdepth depthatatthisthislevel.

level.ThisThismonitoring monitoringlevellevelensures ensures there there isis anan adequate adequatewater waterlevelleveltotoprovide providesubstantial substantialradiation radiation shielding shielding for for aa person standing standing on on the thespent spentfuel fuelpool pooloperating operatingdeck deckfromfromdirect directgamma gammaradiation radiation from stored spent from spentfuel.

fuel.

Level Level where where fuel fuel remains remains covered covered (Level (Level 3):3): ForFor both units, units, indicated indicated levellevel onon either the primary either primary or backupbackup instrument instrument channel channel of of greater greaterthan than0 0feet feet(elevation (elevation 589')6 plus 589')6 plus instrument instrumentchannel channelaccuracy accuracyabove above thethe top top of of the storage racksracks based based upon the design design accuracy accuracy (which (which is is to to be bedetermined) determined)of ofthe theinstrument instrumentchannel channelfor for both the primary and backup instrument channels. channels. This Thismonitoring monitoring level level assures assuresthat that water is covering the stored stored fuel fuel seated seated in in the racks.

2

Dresden Nuclear Dresden Nuclear Power Power Station, Station, Units Units 22 and and 33 Reliable Spent Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Overall Integrated Plan Plan Instruments:

Instruments:

The design design of of the theinstruments instrumentswill will bebeconsistent consistentwith withthe theguidelines guidelinesofofNRC NRCJLD-ISG JLD-ISG--

2012-032 2012-03 and2 and NEI NEI 12-02 12-023.3. Specifically, Specifically, the the channels channels will will be be designed designed as as discussed discussed below:

Primary (fixed)

Primary channel: For instrument channel:

(fixed) instrument For both both units, units, the theprimary primary instrument instrument channel levellevel sensing components components will will be located located and and permanently permanently mountedmounted in in the the unit's dedicated SFP. SFP. The Theprimary primaryinstrument instrumentchannelchannelwill willprovide providecontinuous continuouslevel level indication indication over over a minimum minimum range of of 24 24 feet feet from from the thehighhighpoolpoollevel levelelevation elevationofof613' 613' to the toptop ofof the the spent spentfuel fuel racks racksatatelevation elevation589'6.589's. ThisThiscontinuous continuouslevel levelindication indication will will bebe provided providedby byaaguided guidedwavewave radar radar system, system, submersible pressure pressure transducer, transducer,or or other appropriate appropriate levellevel sensing sensingtechnology technologythat thatwill will bebe determined determinedduring duringthe thedetailed detailed engineering designdesign phase phaseof ofthe theproject.

project.

Backup channel: For both units, the backup instrument channel:

Backup instrument backup instrument instrument channel channellevel level sensing sensing components components will also be located will also located and and permanently permanently mounted mounted inin the theunit's unit's dedicated dedicated SFP. SFP. The The backup backup instrument instrument channelchannel will will provide provide continuous continuous level level indication over indication over a minimum minimum range of of 24 24 feet feet from from the thehighhighpoolpoollevel levelelevation elevationofof613' 613' to the toptop ofof the spent spentfuel fuel racks racks atatelevation elevation589'6. 's 589 . This Thiscontinuous continuouslevel levelindication indication will be provided provided by the same same levellevel sensing sensingtechnology technology as asthe theprimary primaryinstrument instrument channel.

Reliability:

Reliabilityofofprimary Reliability primaryand andbackup backup instrument instrument channels channels will be assured will be assured by byconformance conformance with the with the guidelines of NRC JLD-ISG-2012-032 JLD-ISG-2012-03 and 2 and NEI 12-023as NEI 12-02 3 as discussed discussed belowbelowunder under Design Features and Design and Program Program Features.

Features.Both Bothprimary primaryand andbackup backuplevellevelinstrumentation instrumentation channels will be functional will be functional at at all all times times when when there is is fuel fuel in in the SFP SFP withwith allowances allowances for for testing, maintenance or or repair repair per per NEINEI 12-02.

12-02. Reliability Reliability willwill be established established through through the the use of an augmented quality assurance process quality assurance process(e.g.,(e.g.,aaprocess processsimilar similartotothat thatapplied appliedto to the site site fire fire protection protection program).

program).

Design Features Instrument Channel Design: Instrument Instrument channel channel design will be consistent with the 2

guidance of NRC NRC JLD-ISG-2012-032 JLD-ISG-2012-03 and and NEINEI12-023.12-023.

Arrangement:

Arrangement: The current current plan plan is to install install SFP level level sensors in in the the northeast northeastand and southeast areas areas of of the the Unit Unit 2 SFP separated separated by by aadistance distanceinin excess excessofof20 20feet feetand and in the in the northwest northwest and and southwest southwest areas of of the Unit Unit 3 SFP separated separated by by aadistance distanceinin excess of of 20 feet. The Thesensors sensorsthemselves themselveswill willbe bemounted, mounted,totothe theextent extentpractical, practical, near the poolpool walls walls and below below thethe pool pool curb curb to to minimize minimize their exposure exposure to to damaging damaging 3

Dresden Nuclear Dresden Nuclear Power Power Station, Station, Units Units 22 and and 33 Reliable Spent Reliable Spent Fuel Fuel PoolPool Instrumentation Instrumentation Overall IntegratedIntegrated Plan Plan debris and and not not interfere interfere with with SFP SFP activities.

activities. Instrument Instrumentchannel channelelectronics electronics and and power supplies will will bebe located in in seismic and and missile missile protected protected areas areaseither eitherbelow below the SFP SFP operating operating floorfloor or inin buildings buildingsother otherthanthanthethe RB.

RR. The areasareas to to be be selected selected will provide provide suitable suitable radiation radiation shielding shielding and and environmental environmental conditions conditions for for the the equipment consistent with with instrument manufacturer's recommendations. Equipment Equipment and cabling cabling for for power power supplies supplies and and indication indication for for each each channel channel will will be be separated separated equivalent to that providedprovided for redundant redundant safetysafetyrelated relatedservices.

services.

Mounting: Design Mounting: Design of of the mounting mounting of of the the sensors in in the the SFP SFP shall shall bebeconsistent consistent with with the seismic Class ClassIIcriteria.

criteria. Installed Installedequipment equipmentwill willbe beverified verifiedtotobebeseismically seismically adequate for for thethe seismic seismicmotions motionsassociated associatedwith withthethemaximum maximumseismic seismicground ground motion considered considered in in the the design designof of the theplant plantarea areaininwhich whichititisisinstalled.

installed.

Qualification: Reliability Qualification: Reliability ofofbothboth instrument instrument channels channels willwill bebe demonstrated via via an an appropriate combination combination of design, analyses, analyses, operating operatingexperience, experience,and/orand/ortesting testingofof channel components componentsfor for the thefollowing following setssets of of parameters:

parameters:

• conditions inin the conditions the areaarea of of instrument instrument channelchannel component component use use forfor all all instrument components,

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

• seismic effects on instrument channel components components used used during during and and following following a potential seismic seismic event.

event.

Temperature, humidity Temperature, humidity and and radiation radiation levels levels consistent consistent withwith the the conditions conditions in in the the vicinityofofthe vicinity theSFPSFP andand the the area area of of use use considering considering normalnormal operation, operation, event eventandandpost-post-event conditions conditions for for no fewer than seven seven days dayspost-event post-eventororuntiluntiloff-site off-siteresources resources can be be deployed deployedby bythethemitigating mitigatingstrategies strategiesresulting resultingfrom fromOrder OrderEA-12-0494 EA-12-0494will will be be addressed in in the the detailed detailed design design engineering engineering phase phaseofofthe theproject. Examples of project. Examples of post-event (beyond-design-basis)

(beyond-design-basis) conditions conditions to to be be considered consideredare: are:

• radiological conditions radiological conditions for for aa normal refueling refueling quantity of freshlyfreshly discharged discharged (100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />)

(100 hour) fuel fuel with with SFP SFP water level 3 as as described describedininOrder OrderEA-12-051, EA-12-051,

• • temperature of 212 degrees F and 100% 100% relative humidity environment,

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

• • a concentrated borated borated water water environment, environment, and

• • the impact of FLEX the mitigating strategies.

FLEX mitigating strategies.

44

Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 2 2 and and 33 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall IntegratedIntegrated Plan Plan Components of the Components the instrument instrument channels channelswill will bebequalified qualified for forshock shockand andvibration vibration using one one or or more moreof of the thefollowing following methods:

methods:

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

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

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

• components are inherentlyinherently resistant to to shock shock andand vibration vibration loadings, loadings, suchsuch as as cables.

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

batteries), the the following measures will following measures will be used used to toverify verify that that the thedesign design and installation installation is adequate. Applicable components adequate. Applicable components are rated by by the the manufacturer manufacturer (or otherwise (or tested) for otherwise tested) for seismic seismic effects effects at at levels levels commensurate commensurate with with those those ofof postulated design postulated design basis basis eventevent conditions conditions in in the the area areaofofinstrument instrumentchannelchannel component use component useusing usingone oneorormoremoreofofthe thefollowing following methods:

methods:

• instrument channel instrument channel components components use known known operating operating principles principles and and areare supplied by supplied by manufacturers manufacturers with with commercial commercial quality quality programs programs (such (such as as lSO9001). The 1809001). The procurement procurement specification specification and/or and/or instrument instrument channel channel design design shall include shall include the seismic requirements requirements and and specify specify thetheneed needfor forcommercial commercial design and testing design testing underunder seismic seismic loadings loadings consistent consistent with with design design basis basis values atat the the installed installed locations; locations;

• substantial history history of of operational operational reliability reliability inin environments environmentswith with significant significant vibration, such as for for portable portable hand-held hand-held devicesdevicesorortransportation transportation applications. Such Such aa vibration vibration design design envelope envelope shall shall be be inclusive inclusive of of the the effects of effects of seismic seismic motionmotion imparted imparted to to the components components proposedproposed at at the the location of the proposed proposedinstallation; installation;

• adequacy of seismic seismic design and and installation installation is demonstrated demonstrated based based on onthethe guidance in guidance in Sections Sections 7, 7,8,8, 9,9,and and1010ofofIEEE IEEEStandard Standard344-2004, 344-2004,"IEEE "IEEE Recommended Practice Practicefor forSeismic SeismicQualification Qualification of of Class Class1 1EEEquipment Equipmentfor for 5

Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 22 and and 33 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan Nuclear Power Nuclear Power Generating Generating Stations", or Stations", or a substantially a substantially similar similar industrial industrial standard;

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

ranges); or or

• seismic qualification seismic using seismic qualification using seismic motion motion consistent with with that that of of existing existing design basis basis loading loading at atthetheinstallation installationlocation.

location.

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

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

isolation needs.

Power Supplies: Each channel Power Supplies: channel will will bebe normally normally powered powered fromfrom aadifferent different120Vac 120Vac bus. Upon Upon loss of of normal normal ac acpower, power,individual individual channel channelinstalled installedbatteries batterieswill will maintain continuous automatically maintain continuous channel channel operation.

operation. The batteries The batteries will will bebe replaceable and be be sized sizedtotomaintain maintainchannel channeloperation operationuntil until off-site off-site resources resources can can be deployed be deployed by bythe themitigating mitigatingstrategies strategiesresulting resultingfrom fromOrderOrder EA-12-0494

• EA-12-0494.

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

Accuracy: The Accuracy: The instrument channels will instrument channels be designed will be designed to to maintain maintain theirtheir design design accuracy following accuracy following aa power power interruption interruption or or change change in in power power source sourcewithoutwithout recalibration. Instrument recalibration. Instrument channel accuracy, accuracy, to to be bedetermined determinedduringduringdetailed detaileddesign, design, will consider Spent will consider Spent Fuel Fuel Pool Pool conditions conditions (e.g.,

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

accuracy. Instrument channel Instrument channel accuracy will be sufficient will be to allow sufficient to allow trained trained personnel to determine determine when when the theactual actual level exceeds the specified level specified lower lower level level of each each indicating indicating range range (levels (levels 1, 1, 22oror3)3) without conflicting conflicting oror ambiguous ambiguous indications.

indications.

Instrument channel design Testing: Instrument Testing: design will will provide for routine routine testing testing andandcalibration calibration 2

consistent with with the guidelines guidelines of of NRC NRC JLD-ISG-2012-032 JLD-ISG-2012-03 and NEI NEI 12-023.12-023. Details Details willbe will be determined determined during during detailed detailed design engineering.

engineering.

Display: The primary Display: primary and backup backup instrument instrument displays displayswillwill be be located locatedatatthe thecontrol control room, alternate room, alternate shutdown shutdown panel, panel, or or other other appropriate appropriate and and accessible location.

location. The The specific location specific will be location will be determined determined during during detailed detailed design.

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

characteristics:

6

Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 2 2 and and 3 3 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan

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

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

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

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

• outside of any high radiation areas areasduring during normal normal operation.

operation.

Program Program Features Features Training:

Training: Personnel performing Personnel functionsassociated performing functions associated with with these these SFPSFP level level instrumentationchannels instrumentation channels will willbe be trained trained to to perform perform the the jobjobspecific specificfunctions functions necessary for necessary for their assigned assigned tasks tasks(maintenance, (maintenance,calibration, calibration, surveillance, surveillance, etc.).

etc.). This This training will be be consistent with equipment vendor guidelines, consistent with equipment vendor guidelines, instructions and instructions and recommendations. The The Systematic Systematic Approach Approach to Training Training (SAT)

(SAT) will be used will be used to to identifythe identify the population population to to be trained trained and and totodetermine determinethe theinitial initialand andcontinuing continuing elements of of the the required required training. Training will training. Training will bebe completed completed prior to placing placing thethe instrumentation in in service.

service.

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

instrumentation.

Procedures will also address address the the following following situations:

situations:

• If, at the the time time ofof anan event eventororthereafter thereafteruntil until the theunit unitisisreturned returnedtotonormal normal service, an an instrument instrument channel channel ceases ceases totofunction, function, its itsfunction function willwill be be recovered within recovered within a period period of of time time consistent consistent withwith the the emergency emergencyconditions conditions that may exist exist at at the the time.

time.

• If, at the the time time ofof anan event eventororthereafter thereafteruntil until the theunit unitisisreturned returnedtotonormal normal service, service, an instrument instrument channel channel component component must must be replaced, replaced, itit may may be be replaced with with aa commercially commercially available componentcomponent that that may mayor or may maynotnotmeet meet all of thethe qualifications qualifications noted noted above above totomaintain maintaininstrument instrument channel channel functionality.

Testing and Testing Calibration: The testing and Calibration: testing andandcalibration calibrationof ofthe theinstrumentation instrumentationwill will be be consistent with with vendor recommendations recommendations or or other other documented documentedbasis. basis.Calibration Calibrationwillwill be specific specific to the mounted instruments and the the displays.

displays. AAMaintenance MaintenanceProcedure Procedure will be written written to direct direct calibration calibration and and repair repairof ofthe theinstruments.

instruments. PassportPassport will will be be 7

Dresden Dresden Nuclear Nuclear Power Power Station, Station, Units Units 2 2 and and 3 3 Reliable Reliable Spent Spent Fuel Fuel PoolPool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan used to control control the calibration and setpoint parameters. The calibration and The Passport PassportPMIDPMID system system willbe will be used used to direct the calibration frequency frequency of of the the instruments.

instruments.

Need for Relief Need Relief and and Basis:

Basis: Dresden Dresden Nuclear Nuclear Power Power Station Station is not not requesting requesting relief relief from the requirements from requirements of of Order Order EA-12-051' EA-12-0511 or orthe theguidance guidanceininNRC JLD-ISG-2012-032 NRCJLD-ISG-2012-032 at this time.

Consistent withwith the requirements requirements of ofOrder OrderEA-12-0511 EA-12-0511 and andthe theguidance guidanceininNEI 12-023 ,

NEI12-023, Exelon's six-month Exelon's six-monthreports reports will willdelineate delineateprogress progress made, made, anyany proposed proposed changes changes inin compliance methods, compliance methods, updates updates toto the the schedule, schedule, and ifif needed, needed, requests requestsfor for relief relief and and their basis.

References:

NRC Order Number EA-12-051,

1. NRC EA-12-051, Order Modifying Licenses with Modifying Licenses with Regard to to Reliable Reliable Spent Fuel Fuel Pool Pool Instrumentation, dateddated March March 12, 12, 2012 2012 NRC Interim

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

3. NEI 12-02, Industry NEI 12-02, Industry Guidance Guidance for for Compliance Compliance with NRC Order EA-12-051, NRC Order EA-12-051, "To "To Modify Modify Licenses Licenses withwith Regard Regard to to Reliable ReliableSpent SpentFuel Fuel Pool Pool Instrumentation",

Instrumentation",

Revision Revision 1,1, dated August 24, 2012 dated August NRC Order

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

5. Dresden UFSAR Section 9.1.2.2.3, "Spent Fuel Pool", Revision 8, dated June June 2009.

2009.

6. Dresden UFSARUFSAR Figure 9.1-7, "High Density Spent Fuel "High Density Fuel Rack Rack -- 99xx13",

13",Revision Revision8,8, dated June June 2009.

2009.

7. Dresden UFSARUFSAR Section 9.1.2.3.1, High-Density High-Density FuelFuel Racks, Revision Revision 8, dated dated June June 2009 88