RS-13-194, Response to Request for Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
| ML13212A364 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/31/2013 |
| From: | Kaegi G Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| EA-12-051, RS-13-194 | |
| Download: ML13212A364 (15) | |
Text
1 i Generation ti RS-13-194 Order No. EA-12-051 EA-12-051 July 31, 2013 u.s. Nuclear Regulatory U.S. Nuclear Regulatory Commission ATTN: Document Control Control Desk Washington, Washington, DC DC 20555-0001 Braidwood Station, Units Units 11 and and 22 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Response to
Subject:
Response to Request Requestfor forAdditional Additional Information Overall Integrated Information - Overall Integrated Plan in Response in Response to Commission Order Order Modifying License Requirements Modifying License Requirements for for Reliable Reliable Spent SpentFuel FuelPool Pool Instrumentation (Order (Order No.
No. EA-12-051)
References:
Exelon Generation Company, LLC
- 1. Exelon letter to LLC letter to USNRC, USNRC, Overall Overall Integrated Integrated Plan Plan in in Response
Response
to March 12, 2012 Commission Order Modifying Licenses with Modifying Licenses with Regard Regard to to Requirements for Reliable for Reliable Spent Spent Fuel PoolPool Instrumentation Instrumentation (Order Number EA-12-051), EA-12-051), dated February February 28, 2013 (RS-13-027)
NRC Order Number EA-1
- 2. NRC 2-051, Issuance EA-12-051, Issuance of of Order Order to to Modify Modify Licenses Licenses with with Regard Regardto to Reliable Spent Fuel Fuel Pool Pool Instrumentation, Instrumentation, dateddated March March 12,12, 2012 2012
- 3. USNRC letter to Exelon GenerationGeneration Company, Company,LLC, LLC, Request Requestfor forAdditional Additional Information Information Regarding Overall Overall Integrated Plan for ReliableReliable Spent Fuel Fuel Pool Pool Instrumentation, Instrumentation, dated dated July 11,2013 July In Reference In Reference 1, 1, Exelon Exelon Generation Generation Company, Company, LLC LLC (EGC) provided provided the Braidwood Station, Units Units 1 and 2, Overall 1 Overall Integrated Integrated PlanPlan in in Response Response to to the the March March 12,12, 2012 2012Commission CommissionOrder OrderModifying Modifying Licenses with Licenses with Regard Regard to to Requirements Requirementsfor for Reliable Reliable Spent SpentFuel FuelPoolPoolInstrumentation, Instrumentation,pursuant pursuanttoto NRC Order Order No. EA-12 EA-12-051 (Reference 2).
-051 (Reference 2).
The purpose purpose ofof this this letter letter is is to provide provide the response responseto tothe theNRC NRCrequest requestforforadditional additionalinformation information (Reference 3) 3) regarding regarding the the Braidwood Braidwood Station, Units Units 1 and and 22 Overall Overall Integrated Integrated Plan Plan inin Response to Response to the theCommission CommissionOrder OrderModifying Modifying Licenses with with Regard to to Requirements Requirementsfor for Reliable Spent Fuel Pool Spent Fuel Pool Instrumentation Instrumentation(Order(OrderNo. No. EA-12-051).
The Braidwood Station, Units Braidwood Station, Units 11 and and 22 Spent Fuel Pool Instrumentation design is proceeding on the schedule schedule identified identified in in the Overall Overall Integrated Integrated Plan Plan provided provided in in Reference Reference 1. The enclosed
- 1. The enclosed responses to responses tothe theNRC NRCrequest requestforforadditional additionalinformation information are are intended intendedto tonot notprovide provide preliminary preliminary or or conceptual information.
information. The The requested requestedinformation, information, whenwhenfully fully developed, developed, will will be provided upon detailed design completion detailed completion based based on on the the milestone milestone schedule schedule dates provided provided in in each each response.
u.s.
U.S. Nuclear Regulatory Commission Response to Response toRequest RequestforforAdditional AdditionalInformation Information(Order (OrderEA-1 2-051)
EA-12-051) 31, 2013 July 31,2013 Page 2 This letter This letter contains contains no new regulatory regulatory commitments.
commitments. If you have any questions If you questions regarding regarding this this response, please pleasecontact contactDavid David P.P. Helker Helker atat 610-765-5525.
610-765-5525.
II declare declare under penalty of perjury that the perjury that the foregoing foregoing is true true and correct. Executed Executedon onthe the318t 31 stday day of July of July 2013.
Respectfully submitted, G~iT71tF Glen T. Kaegi Director - Licensing & Regulatory Regulatory Affairs Affairs Exelon Generation Company, LLC
Enclosure:
Braidwood Station,
- 1. Braidwood Station, Units Units11andand 22 -- Response Response to Request Request forfor Additional Additional Information Information -- Overall Overall Integrated Plan in Response to Commission Order Response to Commission Order Modifying Modifying License Requirements Requirements forfor Reliable Spent Fuel Reliable Fuel Pool Pool Instrumentation Instrumentation(Order(OrderNo.
No. EA-12-051)
EA-12-051) cc: Director, Office of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator -- Region Region IIIIII NRC Senior NRC Senior Resident Inspector Inspector -- Braidwood Braidwood Station, Units 1 and 2 NRC Project NRC Project Manager, NRR NRR - Braidwood Station, Units 1 and 22 Mr.
Mr. Robert J. Fretz, Fretz, Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr.
Mr. Robert L. L. Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC NRC Mr. Blake Purnell, Mr. Blake Purnell, NRC NRC Project Manager, Manager, NRR NRR Illinois Emergency Illinois Emergency Management Management Agency Agency -- Division Division of Nuclear Safety Safety
Enclosure 11 Enclosure Braidwood Station, Units 11 and 22 Request for Response to Request for Additional Additional Information Information Plan in Overall Integrated Plan Response to Commission in Response Commission Order Order Modifying Modifying License Requirements forfor Reliable Reliable Spent Fuel Pool Instrumentation Instrumentation (Order (Order No.
No. EA-12-051)
EA-12-0S1)
(12 pages)
Response to Request for Additional Information Information (Order(Order EA-1 2-051)
EA-12-051) 1 Page 1 of 12
1.0 INTRODUCTION
By letter By letterdated dated February February 28, 28, 2013 (Agencywide (Agencywide Documents Documents Access Access and Management System System (ADAMS)Accession (ADAMS) Accession No. No. MLML13059A265),
13059A265), Exelon Exelon Generation Generation Company, LLC, LLC, submitted an an overall overall integrated plan (OIP) in response to the March 12, 2012, U.S.
(OIP) in response to the March 12, 2012, U.S. Nuclear Regulatory Nuclear Regulatory Commission (NRC) (NRC) Order modifying licenses with modifying licenses with regard to reliable spent spent fuel fuel pool pool (SFP)
(SFP) instrumentation (Order (Order EA-12-051; EA-12-051 ;ADAMSADAMS Accession Accession No. No. ML12054A679)
ML12054A679)for for Braidwood Braidwood Station, Units 1 and 2. The TheNRCNRCstaffstaffendorsed endorsedNuclear NuclearEnergyEnergyInstitute, Institute,NEI NEI12-02, 12-02,"Industry "Industry Guidance for Guidance for Compliance Compliance with with NRC NRC Order Order EA-12-051, EA-12-051, to to Modify Modify Licenses Licenses with with Regard Regardto to Reliable SFP Instrumentation,"
Reliable Instrumentation," Revision Revision 1, 1, dated datedAugust August2012 2012(ADAMS (ADAMS Accession Accession No. ML No. ML12240A307),
12240A307), with exceptions as documented in NRC Interim Interim Staff Guidance, JLD-ISG- JLD-ISG-2012-03, "Compliance with Order Order EA-1 2-051, Reliable Spent Fuel EA-12-051, Fuel Pool Pool Instrumentation,"
Instrumentation,"
Revision 0, Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339). ML12221A339).
The NRC staff has NRC staff has reviewed reviewed the the February February 28, 28, 2013, 2013, response response by by the licensee licensee and and determined determined that the following request for additional information following request information (RAI) (RAI)isisneeded needed to to complete its technical review.
2.0 LEVELS OF REQUIRED MONITORING The OIP states, in 01 P states, in part, part, that:
Level adequate Level adequate to to support supportoperation operationofofthe thenormal normalfuelfuelpool poolcooling coolingsystem system(Level (Level1):1):
Indicated level level on on either primary primary or or backup backup instrument channel channel of greater than 18 feet 18 feet (elevation 418'-1 (elevation 418'-1 %")
3/4")above abovethethetoptopofofthethestorage storageracks racksbased based on the design accuracyaccuracy of of the instrument channel (which willbe (which will bedetermined determined ininthe thedetailed detailed design design phase) phase) and aa resolution of resolution of 1 foot foot or or better better of of both both thethe primary primaryand and backup backup instrument instrument channels. This Thisisis based on based on Spent SpentFuelFuelPool PoolCooling COOling PumpPump suction suction strainer strainer elevation.
elevation. AAcalculation calculation demonstrating adequate adequatewater waterlevel level will be performed will be performed as part of the detailed engineering design phase phaseto to ensure ensurethe thelevel levelisisadequate adequatefor fornormal normalfuel fuelpool poolcooling cooling system system operation.
Level adequate to provide substantial radiation Level adequate shielding for radiation shielding for aa person person standing on the spent spent fuel fuel pool operating deck (Level (Level 2): 2): Indicated Indicatedlevellevel onon either either the the primary primary or or backup backup instrument channel channel of of greater greaterthan than10 10feet feet(elevation (elevation410'-1 410'-13/4')
%") plus plus instrument instrument channel channel accuracy (which (which will determined in will determined the detailed in the detailed design phase) phase) above abovethe thetop topofof the the storage storage racks racks based basedon onspecification specificationof of this this level level asas adequate adequateininNRC NRCJLD-ISG-2012-03 JLD-ISG-2012-03 (Ref.
(Ref. 2)2) and NEINEI 12-02 (Ref.(Ref. 3),
3), the the specified specified design accuracy accuracy of of the instrument instrument channel, channel, and the the relatively relatively low sensitivityofofdose low sensitivity dose rates rates to changes changes in in water water depth depthat atthis this level.
level.
This monitoring monitoring levellevelensures ensures there is an adequate adequatewater waterlevellevel toto provide provide substantial substantial radiation shielding for radiation shielding for aa person standing on on thethe spent spentfuel fuel pool pool operating operatingdeckdeckfrom from direct gamma gamma radiation radiation from from stored spentspent fuel.
fuel.
Level where fuel Level where fuel remains remains covered (Level (Level 3):3): Indicated Indicated level level onon either either the the primary primary or or backup instrument instrument channel channel of of greater greaterthan than00feet feet(elevation (elevation400'-1 400'-1 3/4)
%") plus plus instrument instrument channel accuracy above the top of the the storage racks based based uponupon the the design design accuracy accuracy (which (which willwilldetermined determined ininthe the detailed detailed design phase) phase) of of the theinstrument instrumentchannel channelfor forboth both the primary primary and backup instrument channels. channels. This This monitoring monitoring level level assures assures that that water water is is covering covering the stored fuel seated seated inin the the rack.
rack.
Response to Request for Additional Additional Information Information (Order (OrderEA-1 2-051)
EA-12-051) 1 Enclosure Page 2 of 12 12
RAI-1
Please provide the following:
a) For Level 1, specify how the identified location represents the higher of the two points pOints described in the NEI 12-02 guidance for this level. level.
b) A b) clearly labeled A clearly labeled sketch depicting the the elevation elevation view view ofof the the proposed proposedtypical typicalmounting mounting arrangement for arrangement for the portions of the instrument channel consisting of permanent of the measurement channel measurement channel equipment equipment(e.g., (e.g.,fixed fixed level level sensors sensorsand/or and/orstilling stilling wells, wells, and and mounting brackets).
mounting brackets). Indicate Indicate onon this this sketch sketch thethedatum datumvalues valuesrepresenting representingLevel Level1,1 ,
Level 2, Level 2, and and Level Level 33 as well well as the top of of the fuel.
fuel. Indicate Indicateon onthisthissketch sketchthe theportion portionofof the level sensor measurement measurementrange rangethat thatisissensitive sensitiveto tomeasurement measurementofofthe thefuel fuel pool pool level, with level, with respect respect to the Level 1, Level 2, and and Level Level 33 datum datum points.
points.
Response
a) The Braidwood Braidwood Spent Spent Fuel Pool Pool has two Spent Fuel Fuel Pool Pool Cooling Cooling Pumps that take take suction from from the pool with the top of with the of the the suction strainer strainer at at the the417'-9-3/8" 417'-9-3/8" elevation.
elevation.
Normal Spent Normal Spent Fuel Pool Level Level is is at the 424'-6" and low low level 424'-2". The level at 424'-2". The detailed detailed design will include aa calculation will include calculation to to determine determine adequate adequate waterwater level level toto maintain maintain normal normal fuel cooling system fuel pool cooling system operation.
operation.This Thisinformation informationwill willbebeavailable availablefollowing following acceptance of acceptance of the the100%
100%design, design,scheduled scheduledfor forApril, April, 2014.
2014.The Theresult resultwill willbe beprovided providedinin the August 2014, 6-month6-month Integrated Integrated Plan Plan update updatereport reporttotothe theNRC.NRC.
b) A b) A sketch is provided as as Attachment Attachment 1, 1,"Braidwood "Braidwood Spent SpentFuel FuelPool PoolElevation ElevationSketch".
Sketch".
Instrument probe mounting Instrument mounting details in Spent Fuel in the Spent Fuel Pool Pool area areawill will be be provided provided in in accordance with accordance with our response responseto toRAI-3.
RAI-3.
3.0 INSTRUMENTATION DESIGN FEATURES FEATURES 3.2 Arrangement The OIP states, inin part, part, that:
The current plan is to install SFP level install SFP sensors in level sensors in the southwest southwest and andnorthwest northwestcorners corners of the of the SFP separated separated by by aa distance distancein in excess excessof of20 20feet.
feet. The Thesensors sensorsthemselves themselveswill willbe be mounted, to the extentextent practical, practical, near near the the pool pool walls walls and andbelow belowthe thepool poolcurbcurbtotominimize minimize their exposure to damaging debris debris and and notnot interfere interfere with with SFP activities.
activities. Instrument Instrument channel electronics and power power supplies supplies will be located in seismic and missile protected will be areas either areas either at at anan elevation elevation below below the the SFPSFPoperating operatingfloorfloor oror in in buildings other than the FHB [Fuel FHB [Fuel Handling Handling Building].
Building]. TheThe areas areas to be be selected selectedwill will provide provide suitable suitableradiation radiation shielding and environmental conditions for shielding for the the equipment consistent consistent with with instrument recommendations. Equipment manufacturer's recommendations. Equipment and and cabling cabling for for power supplies and indication for indication foreach each channel channel will willbebe separated separated equivalent equivalent to to that that provided provided for redundant redundant safety related services.
Response to Request for Additional Additional Information Information (Order (Order EA-1 2-051)
EA-12-0S1) 1 Page 3 of 12
RAI-2
Please provide provide aa clearly clearly labeled labeled sketch sketchor ormarked-up marked-upplant plantdrawing drawing of of the theplan planview view ofof the the SFPSFP area, depicting depicting the SFP SFP inside inside dimensions, dimensions, the theplanned plannedlocations/placement locations/placementofofthe theprimary primaryand and back-up SFP level sensors, and the proposed routing of the cables level sensors, and the proposed routing of the cables that will extend from thethat will extend from the sensors toward sensors toward thethe location location of of the local electronics cabinets and and read-out/display read-out/display devices devices in in the the main control main control room room or or alternate alternate accessible accessible location.
location.
Response
A sketch A sketch is provided provided as Attachment 2, "Braidwood "Braidwood Spent Fuel Pool Plan View Sketch". Note View Sketch". Note that the locations of the level sensors have level sensors havechangedchangedsincesincethe thesubmittal submittalofofthe theOverall Overall Integrated Plan. The Thedetailed detaileddesign designwill will include include cablecablerouting routing drawings drawingsfrom from thethe Spent SpentFuelFuel Pool to Pool to each each channel indicator.
indicator. The The current current plan plan for the design of the SFPI of the SFPI system based based on on the current Exelon Exelon Nuclear program schedule schedulefor for Braidwood Braidwood will start the will start the design phasephasein in November 2013 November 2013 with withdesign designcompletion completionand and100% 100%acceptance acceptance of ofthe the design design in inApril April2014.
2014. The The requested information requested information will will bebe provided provided in in the the August August 2014, 2014, 6-month 6-month Integrated Integrated Plan update.
3.3 Mounting The OIP states, in in part, part, that:
that:
Design of of the the mounting mounting of ofthe the sensors sensors in the SFP SFP shallshall be be consistent consistentwith with the the seismic seismic Class II criteria.
criteria. Installed Installed equipment equipmentwill will be verified verified to to be seismically adequate adequate for for the the seismic motions associated associated with with the maximummaximum seismic ground motion considered in in the design of of the plant plant area areaininwhich which itit is is installed.
installed.
RAI-3
Please provide the following:
a) The design design criteria criteria that will be used to estimate will be estimate thethetotal total loading loading on on the themounting mounting device(s), including static weight including static weight loads loads and and dynamic dynamic loads.loads. Describe Describe the the methodology methodology that will be used will be used to estimate estimate the the total total loading, loading, inclusive inclusive of design design basis basismaximum maximum seismicseismic loads and and thethe hydrodynamic hydrodynamic loads loadsthat thatcould could result resultfromfrom pool pool sloshing sloshing or or other othereffects effects that could accompany such such seismic seismic forces.forces.
b) A description of the manner mannerin in which which the thelevel levelsensor sensor(and (andstilling stillingwell, well,ififappropriate) appropriate) will be attached attached to to the therefueling refueling floor floor and/or other other support support structures structuresfor for each eachplanned plannedpointpoint of of attachment of the the probe assembly. Indicate Indicateininaaschematic schematicthe theportions portionsofofthethelevel level sensor sensorthatthatwill will serve as aspoints pointsof of attachment attachmentfor formechanical/mounting mechanical/mounting or orelectrical electrical connections.
c) A description of of the manner manner by by which which the the mechanical mechanicalconnections connectionswill will attach attachthethelevel level instrument to to permanent permanent SFP structures so so as asto to support support the the level level sensor sensorassembly.
assembly.
Response to Response to Request for Additional Information (Order (Order EA-1 2-051)
EA-12-0S1) 1 Enclosure Page 44 of Page of 12
Response
Response Device total Device total loading loading andand mounting mounting willwillbebeperformed performedas as part part ofof the the detailed detailed design process.
process.
The current The current planplan for forthe the design design of of the the SFPI SFPI system system based based on on the thecurrent currentExelon Exelon Nuclear Nuclear program schedule for Braidwood program Braidwood will willstart startthe the design design phase phase in in November November 2013 2013 with with design design completion and completion and 100% acceptance acceptance of of the the design designininApril April 2014. The Therequested requestedinformation informationwill will be be provided in provided in the the August August 2014, 2014, 6,month 6-month Integrated Plan update. update.
3.4 Qualification The OIP states, in part, that:
Reliabilityofofboth Reliability bothinstrument instrumentchannels channels willwillbebedemonstrated demonstrated via an an appropriate appropriatecombination combination of design, of design, analyses, operating experience, and/or and/or testing of of channel components components .... ....
Temperature, humidity Temperature, humidity and radiation radiation levels levels consistent consistentwithwithconditions conditionsininthethevicinity vicinity ofof the SFP and the area areaof of use useconsidering considering normal normal operational, operational, event event and and post-event post-event conditions conditions for no for no fewer fewer than than seven seven days post-event post-event or or until until off-site resources can be off-site resources be deployed deployed by by the the mitigating strategies mitigating strategies resulting from Order EA-12-049 (Ref. 4) will willbebe addressed addressed in in the the detailed design phase phase of of the the project.
project.
effects on instrument For seismic effects instrument channel components used usedafterafteraapotential potential seismic seismiceventevent for only installed for only installed components components (with the exception (with the exception of of battery battery chargers chargers and and replaceable replaceable batteries), thethe following measures will following measures be used will be used toto verify verify that the design design and and installation installation is is adequate. Applicable components are rated by the manufacturer adequate. Applicable components are rated by the manufacturer (or otherwise tested) for (or otherwise tested) for seismic effects at levels commensurate with those of with those of postulated design basis event event conditions conditions in in the the area of instrument channel component use use using using one oneorormore moreof ofthe the following methods ....
following methods
RAI-4
Please provide the following:
following:
a) A description of the specific method or or combination combination of of methods methodsyou you intend intendto toapply applyto to demonstrate demonstratethe thereliability of the permanently installed equipment under reliability of under beyond-design-beyond-design-basis basis ambient ambienttemperature, temperature,humidity, humidity, shock, shock,vibration, vibration, and andradiation radiation conditions.
conditions.
b) A description description of of the the testing testing and/or and/or analyses that will be conducted will be conducted to provide provide assurance assurance that the the equipment equipment will perform reliably will perform reliably under under the the worst-case worst-case credible design design basis basis loading at the location where the equipment will be mounted.
will be mounted. Include Include aa discussion discussionof of this seismic seismic reliability demonstration as itit applies to (a) the level reliability demonstration level sensor sensormounted mountedininthe the SFP SFP area, area,and and(b) (b)any anycontrol control boxes, boxes,electronics, electronics,or orread-out read-outand andre-transmitting re-transmittingdevicesdevices that that will be employed to convey will be convey thethe level level information information from the level level sensor sensorto to the theplant plant operators operators or or emergency emergency responders.
responders.
Response to Request for Additional Information (Order EA-12-051)
Response 1 Page 5 of 12 c) A c) A description description of of the the specific specific method or combination of methods methods thatthat will will be used used to to confirm the confirm the reliability reliabilityofofthe thepermanently permanently installedinstalled equipment equipment such suchthat thatfollowing following aa seismic event event thethe instrument instrumentwill will maintain its required accuracy.accuracy.
Response
Device qualification Device qualificationand and reliability reliabilitywillwillbebeperformed performedasaspart partofofthe thedetailed detailed design design process.
process. The plan for current plan for the the design design of of the the SFPI SFPI system based based on on the thecurrent currentExelon Exelon Nuclear Nuclearprogram program schedule for schedule for Braidwood Braidwood will willstart startthe the design design phasephase in in November November 2013 2013 with with design design completion completion and 100% acceptance acceptanceof ofthe thedesign designininAprilApril 2014.
2014. TheTherequested requestedinformation informationwill willbe beprovided providedinin the August 2014, 6-month Integrated Plan update.
3.5 3.S Independence The OIP 01 P states, inin part, part, that:
that:
The primary primary instrument channel will will bebe independent independent of the backup instrument instrument channel.
channel.
This independence This independence will will bebe achieved through physical and electrical electrical separation of each channels' components commensuratecommensurate with with hazard and and electrical electrical isolation isolation needs.
RAI-5
RAI-S Please provide Please providethethefollowing:
following:
a) A description of A description of how howthethetwotwochannels channels of ofthethe proposed proposed level level measurement measurement systemsystem in in each pool pool meet meet this this requirement requirement so so that that the the potential potential for for a common common cause causeevent eventtoto adversely affect both channelschannels isis minimized minimized to the the extent extent practicable.
practicable.
b) Further information b) informationdescribing describing the the design design and installation of of each level measurement measurement system, consisting consisting of of level levelsensor sensor electronics, electronics,cabling, cabling,and andreadout readoutdevices.
devices. Please address address how how independence independenceof of these thesecomponents componentsof ofthe theprimary primary and and back-up back-up channels channelsisis achieved through the application of of independent power sources, sources, physical physical andand spatial spatial separation, independence independence of of signals signals sent sentto to the thelocation(s) location(s) ofof the readout devices, devices, and and the independence independence of of the the displays.
displays.
Response
Device Device channel independence independence evaluation evaluation will be performed will be performed as part of the detailed design process. The Thecurrent currentplanplanforfor the the design designof of the the SFPI SFPI system system based basedon onthe thecurrent currentExelon Exelon Nuclear program schedule schedulefor for Braidwood Braidwood will will start the design design phase phaseininNovember November2013 2013with with design completion completion and 100% acceptance acceptance of of the design in April design in April 2014.2014. The requested requested information willbe information will beprovided providedininthe theAugust August 2014, 2014, 6-month 6-month Integrated Plan update. update.
3.6 Power supplies supplies The OIP states, states, in part, that:
that:
Response to Request for Additional Information (Order EA-12-051) EA-12-0S1)
Enclosure 1 Page 6 of 12 Each channel channel willwill be normally normally powered poweredfrom from aadifferent different120Vac 120Vac[120[120volts-alternating volts-alternating current] bus. Upon current] Uponloss lossof ofnormal normalac acpower, power,individual individual channel channelinstalled installedbatteries batterieswill will automatically maintain automatically maintain continuous continuous channel channel operation.
operation. The The batteries batterieswill will be replaceable replaceable and bebe sized sized toto maintain maintain channel channel operation operation until until off-site resources can off-site resources can bebedeployed deployedby by the mitigating strategies resulting mitigating strategies resulting from from Order Order EA-12-049 EA-12-049 (Ref. (Ref. 4).
4). Additionally, Additionally, each each channel will have provisions for will have for connection connection to to another suitable power power source.
source.
RAl-6 Please provide the following:
a) A description of A description of the the electrical electrical acac power sources sources and and capacities capacitiesfor forthe theprimary primaryand and backup channels.
b) IfIfthe b) the level levelmeasurement measurement channelschannels are to be poweredpowered through a battery battery system system directly or (either directly orthrough through an an uninterruptible uninterruptiblepower powersupply),
supply),please please provide the design criteria that criteria that will willbebeapplied appliedto to size size the the battery in in aa manner that ensures, ensures,with with margin, margin, that the channel channel will will be available available to to run run reliably reliably and and continuously continuouslyfollowing following the onsetonset of the of the beyond-design-basis beyond-design-basis event event for for the minimum duration needed, consistent minimum duration consistent withwith the plant mitigation strategies for mitigation strategies for beyond-design-basis beyond-design-basis external events events (Order (Order EA-12-049).
Response
Device total Device total power power supply supply configuration configurationwill willbebeperformed performedas as part part of ofthe the detailed detailed design design process.
process.
The current plan for for the the design of of the SFPI system based basedon onthethecurrent currentExelon ExelonNuclear Nuclear program schedule schedule for for Braidwood Braidwood will willstart startthe the design design phase phase in in November November 2013 2013 withwith design design completion and 100% acceptance completion acceptanceof ofthe thedesign designininApril April 2014.
2014. The Therequested requestedinformation informationwill willbe be provided in provided in the the August August 2014, 6-month Integrated Plan update. update.
3.7 Accuracy The OIP states, in in part, part, that:
that:
The instrument channelschannels will will be designed designed to to maintain maintain their their design designaccuracy accuracyfollowing following aa power interruption interruption or or change change in power sourcesource without without recalibration.
recalibration. Instrument Instrument channel channel accuracy, to be determined determined during during detailed design, design, will consider Spent Fuel will consider Fuel Pool Pool conditions (e.g.,
conditions (e.g., saturated saturated water, steam environment, environment, concentrated borated water), water), as as well as, other applicable radiological well as, radiological and environmental conditions and and include include display display accuracy. Instrument Instrumentchannelchannelaccuracy accuracywill willbe besufficient sufficientto to allow allow trained personnel personnelto to determine when the the actual actual level level exceeds exceedsthe thespecified specifiedlower lowerlevel levelofofeach eachindicating indicating range (levels (levels 1, 1, 22oror3)3)without without conflicting conflicting or ambiguous ambiguousindications.
indications.
Response
ResponsetotoRequest Requestfor forAdditional AdditionalInformation Information (Order (Order EA-12-051)
Enclosure 1 Page Page? 7 of of 12 12
RAI-7
RAI-?
Please provide the the following:
following:
a) AnAn estimate of the expected instrument instrument channel channel accuracy accuracy performance performance(e.g.,
(e.g.,in in percent percent of span) under underboth botha) a)normal normalSFP SFPlevel levelconditions conditions(approximately (approximatelyLevel Level11ororhigher) higher) and b)b) at the the beyond beyond design-basis design-basisconditions conditions(i.e.,
(i.e., radiation, radiation, temperature, temperature, humidity, humidity, post-post-seismic and and post-shock post-shockconditions) conditions) thatthat would would be present present ifif the SFPSFP level level were were atat the the Level Level 2 and LevelLevel 3 datum points.
points.
b) A description of of the the methodology that will be used for will be for determining the the maximum maximum allowed allowed deviation from from thethe instrument channel design design accuracy accuracy that thatwill will be employed employed under under normal operating conditions as an an acceptance acceptancecriterion criterionfor foraacalibration calibration procedure proceduretotoflag flag to operators and and to to technicians technicians thatthat the thechannel channelrequires requiresadjustment adjustmenttotowithin within the the normal normal condition condition design accuracy.
Response
Device channel accuracy analysis will Device channel be performed will be performed as as part of the detailed design process. process.
The current plan for for the design of the SFPI system based basedon onthethecurrent currentExelon ExelonNuclear Nuclear program schedule schedule forfor Braidwood Braidwood will start the will start the design design phase phase in in November November 2013 2013 with with design design completion and 100% acceptance acceptance of the design in April 2014. The requested informationwill of the design in April 2014. The requested information willbe be provided in provided in the the August August 2014, 6-month Integrated Plan update. update.
3.S 3.8 Testing The OIP states, in in part, part, that:
that:
Instrument channel design design will will provide for for routine routine testing and calibration calibration consistent consistent withwith the guidelines guidelines of of NRC NRC JLD-ISG-2012-03 (Ref. 2) and NEI NEI 12-02 (Ref. 3). Details Detailswill will be be determined during detailed design engineering phase. phase.
RAI-8
RAI-S Please provide the following:
a) A A description description ofof the the capability capability and and provisions the proposed proposedlevel level sensing sensingequipment equipmentwill will have to enable enable periodic periodic testing testing and and calibration, calibration, including including how this capability enables the capability enables equipment to be tested tested in-situ.
in-situ.
b) A b) A description description of of how how such such testing and and calibration calibration will enable the conduct will enable conduct of of regular regular channel checks of channel of each independent channel against the other, and against any other permanently-installed SFP SFP level level instrumentation.
instrumentation.
c) A c) A description description of of how how calibration calibration tests tests and functional checkschecks willwill be performed, and and the the frequency at whichwhich theythey will willbe beconducted.
conducted. Discuss Discuss how howthese thesesurveillances surveillanceswill will be be incorporated into the plant surveillance program. program.
Response to Request for Additional Information (Order EA-12-051) EA-12-051) 1 Enclosure Page 8 of 12 12 d) A description of A description ofwhat whatpreventative preventativemaintenance maintenance tasks tasks are required required to to be be performed performed during normal during normal operation, and the the planned plannedmaximum maximum surveillance surveillance interval interval that that isis necessary to necessary to ensure ensurethat thatthe thechannels channelsare arefully fullyconditioned conditionedto toaccurately accuratelyand andreliably reliably perform their perform their functions functions when when needed.
needed.
Response
Device testing Device testing requirement requirement analysis will be performed will be performed as as part part of of the the detailed detailed design process process justjust prior to prior to turnover turnoverto toOperations.
Operations. The The current current plan plan for forthe thedesign design of ofthe the SFPI SFPI system system based based on on the the current Exelon Nuclear program schedule schedule forfor Braidwood Braidwood will start the will start the design design phase phasein in November 2013 with design completion and 100% 100% acceptance acceptance of of the the design design in in April April 2014.
2014.
Following the issue of the design, procedures will start being developed with Following with aa projected projected completion date.
July 2014, completion date. The The requested requested information information willwill be be provided provided in in the the August August 2014,2014, 6-month Integrated Plan update 3.9 Display The OIP states, in in part, that:
The primary and backup instrument instrument displays displays will will be located at at the the control control room, room, alternate alternate shutdown panel, or other appropriate and and accessible accessiblelocation.
location. The Thespecific specificlocation locationwill will be be determined duringduring detailed design.
design.
RAI-9
Please provide the following:
a) The specific location for each location for each ofof the the primary and backup instrument primary and instrument channel channel displays.
displays.
b) IfIfthe b) the primary primary and and backup display location is other than than the the main maincontrol control room, room, provide provide justification justification for forprompt prompt accessibility accessibilitytotodisplays displays including including primary primaryand and alternate alternate route evaluation, habitability habitability atat display location(s),
location(s), continual continual resource resource availability for personnel availability for personnel responsible to promptly promptly read displays, and and provisions provisions forfor communications communications with with decision makers for the various for the various SFP drain down scenarios drain down scenarios and external external events.
c) The reasons c) reasonsjustifying justifying why the locations selected selected enable enablethe theinformation information fromfrom these these instruments to be considered considered "promptly accessible." Include "promptly accessible." Include consideration consideration of of various various drain-down scenarios.
drain-down
Response
Device channel display location will Device willbebefinalized finalizedduring duringthe thedetailed detaileddesign design process.
process. TheThecurrent current for the plan for the design of the SFPI of the SFPI system based based on onthe thecurrent currentExelon ExelonNuclear Nuclearprogram program schedule schedule for Braidwood for Braidwood will willstart startthe thedesign designphase phase inin November 2013 with design completion with design completion and 100%
acceptance of acceptance of the thedesign designininApril April 2014. The Therequested requestedinformation informationwill will be beprovided provided in in the the August 2014, 6-month Integrated Plan Plan update.
Response to Request Request for for Additional Additional Information Information(Order (OrderEA-12-051)
Enclosure 1 Page 9 of of 12 12 4.0 PROGRAM FEATURES PROGRAM FEATURES 4.2 Procedures The OIP 01 P states, states, in in part, part, that:
that:
Procedures Procedures will be developed using will be using guidelines guidelines andand vendor vendor instructions instructions to address addressthe the maintenance, operation operation and abnormal abnormal response responseissues issuesassociated associatedwith withthe theprimary primaryand and backup channels channels of of Spent Spent Fuel Fuel Pool Pool instrumentation.
instrumentation.
RAI-10
Please provide the following:
a) A list of A list ofthe the operating operating (both (bothnormal normaland andabnormal abnormal response) response) procedures, calibration/test procedures, maintenance procedures, and calibration/test procedures, and inspection inspection procedures procedures that that will be developed will be developed for foruse use ofofthe the SFP SFP instrumentation instrumentationininaamanner mannerthat that addresses addresses the order requirements.
b) A brief description of the specific technical objectives objectives to be be achieved achieved withinwithin each each procedure. IfIfyour yourplan planincorporates incorporatesthe theuse useofofportable portablespentspentfuel fuellevel levelmonitoring monitoring components, please include a description of the objectives objectives to to be be achieved achieved with with regard to the storage location and provisions for installation of the portable regard portable components when needed. needed.
Response
Device program Device program features features analysis will be performed will be performed as as part ofof the the detailed detailed design process process just just prior to turnover to Operations. The current plan for the design prior to turnover to Operations. The current plan for the design of the SFPI systemof the SFPI system based on on the the current Exelon Nuclear program schedule schedule for for Braidwood Braidwood will start the will start the design design phase phase in in November 2013 with design completion with design completion and 100% acceptance acceptanceof ofthe thedesign designininAprilApril 2014.
2014.
Followingthe Following the issue issue ofof the the design, procedures procedures willwill start being developed developed with with aa projected projected completion date.
July 2014 completion date. TheThe requested requested information information will will be be provided provided in in the August August 2014, 6-month Integrated Plan Plan update.
update.
4.3 Testing and Calibration The OIP states, in part, that:
The testing and and calibration calibration of of the the instrumentation instrumentation willwill be consistent consistent withwith vendor vendor recommendations or other documenteddocumented basis. basis. Calibration Calibrationwillwill be be specific specific to the mounted instruments and and the the displays.
displays.Calibration Calibrationwillwill be be performed performed to to an anInstrument Instrument Maintenance Procedure Procedure (BIP/BISR (BIP/BISR series). AAPassportPassportPMIDPMIDwill will be used usedto todirect direct frequency for for performance of of the instrument calibration.
calibration. Both Both primary primary and backup backup channels will instrumentation channels will be functional functional at all times when there there isis fuel fuel inin the the SFP SFPwithwith allowance for testing, maintenance maintenanceor orrepair repairper perNEI NEI 12-02 12-02(Ref.(Ref.3).
3).
Response to Response to Request Request for for Additional Additional Information (Order EA-12-051)
EA-12-0S1) 1 Enclosure Page 10 of Page of 12 RAI-1 1
RAI-11
Please provide the following:
Please a) Further a) Further information informationdescribing describingthe the maintenance maintenance and testing testing program program the the licensee licenseewillwill establish and implement to ensure ensure that that regular regular testing testing andand calibration calibration is is performed performed and and verifiedby verified byinspection inspectionand andaudit audittotodemonstrate demonstrate conformance conformance with with design design and and system readiness requirements. Include Includeaadescription description ofof your your plans for for ensuring that necessary necessary channel checks, functional functional tests, periodic periodic calibration, maintenance will calibration, and maintenance will bebe conducted for the for the level level measurement measurement system and and its its supporting supporting equipment.
equipment.
b) A b) A description description of of how howthe the guidance guidance in in NEI NEI 12-02, 12-02, Section Section 4.3, 4.3, regarding regarding compensatory compensatory actions forfor one or both non-functioning channels will non-functioning channels be addressed.
will be addressed.
c) A c) A description description of ofwhat whatcompensatory compensatory actions actions are are planned in the event that one one ofof the instrument channels instrument channels cannot be be restored restoredto tofunctional functional status status within within 90 days.
Response
Device testing Device testing and calibration requirements analysis analysis will will be performed as as part part ofof the the detailed detailed design process processjust justprior prior to to turnover turnover to to Operations.
Operations. TheThecurrent currentplanplanforforthe thedesign designofofthe theSFPI SFPI system based basedon onthethecurrent currentExelon ExelonNuclear Nuclearprogram programschedule schedulefor forBraidwood Braidwoodwill will start startthe the design phase phasein in November November 2013 2013 with with design design completion completion and and 100%
100% acceptance acceptanceofofthe thedesign designinin April 2014. Following April 2014. Following the the issue of the design, design, procedures will start being developed with aa procedures will start being developed with projected July 2014 completion date. The Therequested requestedinformation informationwill will be beprovided providedininthe the August 2014, 6-month Integrated Plan Plan update.
update.
Response to Request for Additional Information Information (Order (Order EA-12-051)
EA-12-051) 1 Enclosure Page 11 Page 11 of 12 A ITACHMENT 11 ATTACHMENT Braidwood Spent Fuel Fuel PoolPool Elevation Sketch 426' ~EL Top of Pit 426'-0'EL SFP Pis High Level Alarm 1424 SFP Pit '.9 K"EL 42C9)? EL Normal SFPSFPwater I water level 1424'-6" Q
424'-6 EL SFP SFP Pit Low Level Alarm 1424" Low Level 424- 2'r EL EL leve1l1418'.1 Level 1 1418'-1 %"EL WEL I Top of pit strainer 1417-9 %'EL 1 Level 2 410'-1 %'EL Level Level 33 1400'.1 400 '-1 W' EL
%'EL II I I.-----.,;~==
Bottom ofof Pit Im' -oBEL I 385'-0°EL
~------------~
Note: t 1/2 ' %=jfv th e Over, eleYatior.
Response toto Request for Additional Information Information (Order EA-12-051)
Page 12 of 12 ATTACHMENT 2 Braidwood Spent Fuel Pool Plan View Sketch Secondary Channel
- - - - - - - - - - - - - - 62'-0* 62'-0" ---~~----+
Shipping cask ShippingCask Area 33'-1" 33'-2" Spent Find Pit E
I PtimaryChannel Primary Channel
+----+ S S