RS-13-114, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML13241A239
Person / Time
Site:	Byron
Issue date:	08/28/2013
From:	Kaegi G Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, RS-13-114
Download: ML13241A239 (12)

Text

1 ti Order No. EA-12-051 RS-13-114 August28,2013 u.s. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to 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 ,

Order Modifying Licenses with Regard to 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 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25,2012

5. Exelon Generation Company, LLC, 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), dated February 28,2013

( RS-13-028)

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 install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2013 Page 2 the EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Byron Station, Units 1 and 2 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2013.

Respectfully submitted,

~r~

Glen T. Kaegi  ;

Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-051 , Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Byron Station, Units 1 and 2 NRC Project Manager, NRR - Byron Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Robert J. Fretz, Jr, NRR/JLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (9 pages)

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Byron Station, Units 1 and 2, developed an Overall Integrated Plan (Reference 1 in Section 8),

documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI),

in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Overall Integrated Plan including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of August 19, 2013.

• Detailed Engineering Design began on February 14, 2013

• Issued Exelon Fleet contract to procure Spent Fuel Pool Instrumentation (SFPI) on June 18, 2013

• Submitted responses to USNRC RAls (Ref. 3 and 4) on July 3,2013 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Revised Target Activity Target Milestone Completion Date Status Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls July 5, 2013 Complete Submit 6 Month Updates:

Complete with Update 1 August 28, 2013 this submittal Page 1 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28, 2013 Revised Target Activity Target Milestone Completion Date Status Completion Date Update 2 February 28, 2014 Not Started Update 3 August 28,2014 Not Started Update 4 February 28, 2015 Not Started Modifications:

Conceptual Design 302012 Complete Begin Detailed Design 102013 Complete Engineering Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Complete and Issue SFPI 402013 Started 102014 Modification Package Begin Installation 202014 Not Started Complete SFPI Installation and 402014 Not Started Put Into Service 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Byron Station, Units 1 and 2, expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Items 01# Description Status 1 Identification of Spent Fuel Pool Started.

Water Levels (RAI-1a, Note that the completion date for design Page 2 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28,2013 Ref.4) The detailed design will include a has changed from December 2013 to calculation to determine adequate water January 2014; however, submittal of level to maintain normal fuel pool results in February 2014 has not cooling system operation. This changed.

information will be available following acceptance of the 100% design, scheduled for January 2014. The result will be provided in the February 2014, 6-month Integrated Plan update report to the NRC.

2 Instruments Complete.

(Ref.1) Continuous level indication will be The Westinghouse Spent Fuel Pool provided by a guided wave radar Level Indication instrumentation was system, submersible pressure selected consistent with the guidelines of transducer, or other appropriate level NRC JLD-ISG-2012-03 and NEI 12-02.

sensing technology that will be The instrument is a guided wave radar determined during the detailed system. It provides the capability to engineering phase of the project. reliably monitor the spent fuel pool water level under normal and anticipated adverse environmental conditions.

The sensor input to the system is a guided wave radar probe. Using the principle of time domain reflectometry (TOR) to detect the SFP water level, microwave signals are pulsed down the cable probe and reflected back from the water surface. This is used to determine the level of the water in the pool.

Each water level measurement channel includes a flexible stainless-steel sensor cable probe suspended in the spent fuel pool from a seismic Category 1 bracket attached to the operating deck or to a raised curb at the side of the pool. The cable probe extends to just above the top of the spent fuel racks. The sensor electronics are mounted in seismic and missile protected areas outside of the building housing the SFP to minimize exposure to elevated radiation and environmental conditions which could result from a postulated loss of water inventory in the pool. There is an interconnecting cable between the Page 3 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28 , 2013 sensor cable probe and sensor electronics.

The sensor electronics provide an instrument standard analog signal to a remote enclosure that will be installed in an accessible location. This enclosure contains the Uninterruptable Power Supply (UPS), backup battery, and water level display. The enclosure also includes the capability to connect an emergency or temporary external power source as part of the FLEX mitigating strategies.

Attachment 1 shows the components and arrangement of the guided wave radar system spent fuel pool level sensor and electronics enclosure for one channel.

3 The detailed design will include cable Started.

routing drawings from the Spent Fuel (RAI-2, Note that the completion date for design Pool to each channel indicator. The Ref.4) has changed from December 2013 to current plan for the SFPI design of the January 2014; however, submittal of system based on the current Exelon results in February 2014 has not Nuclear program schedule for Byron changed.

started the design phase in June 2013 with design completion and 100%

acceptance of the design in January 2014. The requested information will be provided in the February 2014, 6-month Integrated Plan update.

4 Device total loading and mounting will Started.

be performed as part of the detailed (RAI-3, Note that the completion date for design design process. The current plan for Ref.4) has changed from December 2013 to the SFPI design of the system based on January 2014; however, submittal of the current Exelon Nuclear program results in February 2014 has not schedule for Byron started the design changed.

phase in June 2013 with design completion and 100% acceptance of the design in January 2014. The requested information will be provided in the February 2014, 6-month Integrated Plan update.

Page 4 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28 , 2013 5 Device qualification and reliability will be Started.

performed as part of the detailed design (RAI-4, Note that the completion date for design process. The current plan for the SFPI Ref.4) has changed from December 2013 to design of the system based on the January 2014; however, submittal of current Exelon Nuclear program results in February 2014 has not schedule for Byron started the design changed.

phase in June 2013 with design completion and 100% acceptance of the design in January 2014. The requested information will be provided in the February 2014, 6-month Integrated Plan update.

6 Device channel independence Started.

evaluation will be performed as part of (RAI-5, Note that the completion date for design the detailed design process. The Ref.4) has changed from December 2013 to current plan for the SFPI design of the January 2014; however, submittal of system based on the current Exelon results in February 2014 has not Nuclear program schedule for Byron changed.

started the design phase in June 2013 with design completion and 100%

acceptance of the design in January 2014. The requested information will be provided in the February 2014, 6~month Integrated Plan update.

7 Device total power supply configuration Started.

will be performed as part of the detailed (RAI-6, Note that the completion date for design design process. The current plan for Ref.4) has changed from December 2013 to the SFPI design of the system based on January 2014; however, submittal of the current Exelon Nuclear program results in February 2014 has not schedule for Byron started the design changed.

phase in June 2013 with design completion and 100% acceptance of the design in January 2014. The requested information will be provided in the February 2014, 6-month Integrated Plan update.

8 Device channel accuracy analysis will Started.

be performed as part of the detailed (RAI-7, Note that the completion date for design design process. The current plan for Ref.4) has changed from December 2013 to the SFPI design of the system based on January 2014; however, submittal of the current Exelon Nuclear program results in February 2014 has not schedule for Byron started the design changed.

phase in June 2013 with design completion and 100% acceptance of the Page 5 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28 , 2013 design in January 2014. The requested information will be provided in the February 2014, 6-month Integrated Plan update.

9 Device testing requirement analysis will Not started.

be performed as part of the detailed (RAI-8, Note that the completion date for design design process just prior to turnover to Ref A) has changed from December 2013 to Operations. The current plan for the January 2014; however, submittal of SFPI design of the system based on the results in August 2014 has not changed.

current Exelon Nuclear program schedule for Byron started the design phase in June 2013 with design completion and 100% acceptance of the design in January 2014. Following the issue of the design, procedures will start being developed with a projected July 2014 completion date. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

10 Device channel display location will be Complete.

finalized during the detailed design (RAI-9, Both the primary and backup channel process. The current plan for the SFPI Ref A) Spent Fuel Pool Instrumentation displays design of the system based on the will be located in the main control room.

current Exelon Nuclear program The primary channel display will be schedule for Byron started the design located on a Unit 1 main control room phase in June 2013 with design panel with the backup channel display completion and 100% acceptance of the located on a Unit 2 main control room design in December 2013. The panel.

requested information will be provided in the February 2014, 6-month Integrated Plan update.

11 Device program features analysis will Not Started.

be performed as part of the detailed (RAI-10, Note that the completion date for design design process just prior to turnover to Ref A) has changed from December 2013 to Operations. The current plan for the January 2014; however, submittal of SFPI design of the system based on the results in August 2014 has not changed.

current Exelon Nuclear program schedule for Byron started the design phase in June 2013 with design completion and 100% acceptance of the design in January 2014. Following the issue of the design, procedures will start beinq developed with a projected July Page 6 of9

Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 2014 completion date. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

12 Device testing and calibration Not Started.

requirements analysis will be performed (RAI-11, Note that the completion date for design as part of the detailed design process Ref.4) has changed from December 2013 to just prior to turnover to Operations. The January 2014; however, submittal of current plan for the SFPI design of the results in August 2014 has not changed.

system based on the current Exelon Nuclear program schedule for Byron started the design phase in June 2013 with design completion and 100%

acceptance of the design in January 2014. Following the issue of the design, procedures will start being developed with a projected July 2014 completion date. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

Draft Safety Evaluation Open Items 01# Description Status None at this time.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Exelon Generation Company, LLC, letter to USNRC, "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)," dated February 28, 2013 (RS 028)

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

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Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013

3. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7,2013.

4. Exelon Generation Company, LLC, letter to USNRC, "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 051)", dated July 3,2013 (RS-13-156).

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Byron Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 Attachment 1 Spent Fuel Pool Instrumentation System Sensor Electronics

~~~~1I Remote Enclosure containing n sensor UPS Output to Interconnecting Cable optional 1201240 alternate VAC Power display 20-30' (typical) measurement span to just above top of fuel racks

..* 11 40.0 II 6 mm SST Cable Probe with Anchor Weight Spent Fuel Pool Page 9 of9