RS-14-017, Second 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)
| ML14062A056 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/28/2014 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-14-017 | |
| Download: ML14062A056 (16) | |
Text
Order No. EA-12-051 RS-14-017 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457
Subject:
Second 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 Requirements for 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 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (RS-13-027)
- 6. Exelon Generation Company, LLC 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), dated August 28,2013 (RS-13-112)
- 7. NRC letter to Exelon Generation Company, LLC, Braidwood Station, Units 1 and 2-Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0821 and MF0822), dated November 4, 2013
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page 2 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 the EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Braidwood 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. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Braidwood Station. The purpose of this letter is to provide the second 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. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference 7.
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 February 2014.
Respectfully submitted, G~i/.¥ Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Enclosure:
- 1. Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation
Enclosure Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (13 pages)
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Braidwood 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 First six month status report 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 First six month status report (Reference 6), and are current as of February 8, 2014.
- Begin detailed design engineering of the SFPLI for Braidwood Station 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 RAis July 31, 2013 Complete Submit 6 Month Updates:
Update 1 August 28, 2013 Complete Complete with Update 2 February 28, 2014 this submittal Update 3 August28,2014 Not Started Page 1 of 13
Braidwood Station, Units i and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 20i4 Revised Target Activity Target Milestone Completion Date Status Completion Date Provide Final Safety Evaluation September 30, Not Started (SE) Info 2014 Modifications:
Conceptual Design 3Q2012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Design 402013 Complete Engineering Complete and Issue SFPI 202014 Started Modification Package Begin Installation 102015 Not Started Complete SFPI Installation and 2Q2015 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 Braidwood 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 or the Interim Safety Evaluation (ISE) and the status of each item.
Overall Integrated Plan Open Items 01# Description Status 1 RAI Question: Started.
(RAI-1a, For Level 1, specify how the Note that the completion date for design Ref.4} identified location represents the has changed from April2014 to June higher of the two points described in 2014; however, submittal of results in Page 2 of 13
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 the NEI 12-02 guidance for this level. August 2014 has not changed.
RESPONSE
The detailed design will include a calculation to determine adequate water level to maintain normal fuel pool cooling system operation. This information will be available following acceptance of the 100% design, scheduled for June, 2014. The result will be provided in the August 2014, 6-month Integrated Plan update report to the NRC.
2 Open Item: Complete.
(Ref.1) Continuous level indication will be (Addressed in Reference 6) provided by a guided wave radar system, submersible pressure transducer, or other appropriate level sensing technology that will be determined during the detailed engineering phase of the project.
3 RAI Question: Complete.
(RAI-1 b, A clearly labeled sketch depicting (Addressed in Reference 4)
Ref. 4) the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3 as well as the top of the fuel. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.
4 RAI Question: Started.
(RAI-2, Provide a clearly labeled sketch or Note that the completion date for design Ref.4) marked-up plant drawing of the plan has changed from April 2014 to June view of the SFP area, depicting the 2014; however, submittal of results in SFP inside dimensions, the planned locations/placement of the primary and August 2014 has not changed.
backup SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
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Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014
RESPONSE
The detailed design will include cable routing drawings from the Spent Fuel Pool to each channel indicator. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with design completion and 100% acceptance of the design in June 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.
5 RAI Question: Started.
(RAI-3, Provide the following: Note that the completion date for design Ref.4) a) The design criteria that will be used has changed from April 2014 to June to estimate the total loading on the 2014; however, submittal of results in mounting device(s)J including static weight loads and dynamic loads. August 2014 has not changed.
Describe the methodology that will be used to estimate the total loadingJ inclusive of design basis maximum seismic loads and the hydrodynamic roads that could result from pool sloshing or other effects that could accompany such seismic forces.
b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.
Indicate in a schematic the portions of the levelsensor that will serve as points of attachment for mechanicaVmounting or electrical connections.
c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.
RESPONSE
Device total loading and mounting will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program Page 4 of 13
Braidwood Station, Units i and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 201 4 schedule for Braidwood will start the design phase in November 2013 with design completion and 100%
acceptance of the design in June 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
6 RAI Question: Started.
(RAI-4, Provide the following: Note that the completion date for design Ref.4) a) A description of the specific method has changed from April 2014 to June or combination of methods that will be 2014; however, submittal of results in applied to demonstrate the reliability of the permanently installed equipment August 2014 has not changed.
under beyond-design basis ambient temperature, humidity, shock, vibration, and radiation conditions.
b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worstcase credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out andre-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RESPONSE
Device qualification and reliabil~y will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with design completion and 100%
Page 5 of l3
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 acceptance of the design in June 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
7 RAI Question: Started.
(RAI-5, Provide the following: Note that the completion date for design Ref.4) a) A description of how the two has changed from April2014 to June channels of the proposed level 2014; however, submittal of results in measurement system meet this requirement so that the potential for a August 2014 has not changed.
common cause event to adversely affect both channels is minimized to the extent practicable.
b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RESPONSE
Device channel independence evaluation will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for I Braidwood will start the design phase in November 2013 with design completion and 100% acceptance of the design in June 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.
8 RAI Question: Started.
(RAI-6, Provide the following: Note that the completion date for design Ref.4) a} A description of the electrical ac has changed from April2014 to June power sources and capabilities for the 2014; however, submittal of results in primary and backup channels.
b) The results of the calculation August 2014 has not changed.
depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite Page6 of 13
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 resource availability Is reasonably assured.
RESPONSE
Device total power supply configuration will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with design completion and 100%
acceptance of the design in June 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
9 RAI Question: Started.
(RAI-7, Provide the following: Note that the completion date for design Ref.4) a) An estimate of the expected has changed from April2014 to June instrument channel accuracy 2014; however, submittal of results in performance under both (a) normal SFP level conditions August 2014 has not changed.
(approximately Level 1 or higher) and (b) at the beyond design-basis conditions (i.e., radiation, temperature, humidity, post-seismic and postshock conditions) that would be present if the SFP level were at the Level2 and Level 3 datum points.
b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RESPONSE
Device channel accuracy analysis will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with Page 7 of 13
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 design completion and 100%
acceptance of the design in June 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
10 RAI Question: Started.
(RAI-8, Provide the following: Note that the completion date for design Ref.4) a) A description of the capability and has changed from April 2014 to June provisions the proposed level sensing 2014; however, submittal of results in equipment will have to enable periodic testing and calibration, including how August 2014 has not changed.
this capability enables the equipment to be tested in-situ.
b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
c) A description of how functional checks will be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted.
d) A discussion as to how these surveillances will be incorporated into the plant surveillance program.
e) A description of the preventive maintenance tasks required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RESPONSE
Device testing requirement analysis will be performed as part of the detailed design process just prior to turnover to Operations. The current plan tor the design of the SFPI system based on the current Exelon Nuclear program schedule tor Braidwood will start the design phase in November 2013 with design completion and 100%
acceptance of the design in June 2014.
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Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Following the issue of the design, procedures will start being developed.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
11 RAJ Question: Complete.
(RAI-9, Please provide the following: (Addressed in Reference 6)
Ref.4) a) The specific location for each of the primary and backup instrument channel displays.
b) If the primary and backup display location is other than the main control room, provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.
c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible." Include consideration of various drain-down scenarios.
12 RAJ Question: Replaced by Interim SE RAI #13.
(RAI-10, Please provide the following: Note that the completion date for design Ref.4) a) A list of the operating (both normal has changed from April 2014 to June and abnormal response) procedures, 2014; however, submittal of results in calibration/test procedures, August 2014 has not changed.
maintenance procedures, and inspection procedures that will be developed for use of the SFP instrumentation in a manner that addresses the order requirements.
b) A brief description of the specific technical objectives to be achieved within each procedure. If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for Page 9 of 13
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLJ February 28, 2014 installation of the portable components when needed.
RESPONSE
Device program features analysis will be performed as part of the detailed design process just prior to turnover to Operations. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with design completion and 100%
acceptance of the design in June 2014.
Following the issue of the design, procedures will start being developed.
The requested information will be provided in the August 2014, 6-month Integrated Plan update.
13 RAI Question: Started.
(RAI-11, Provide the following: Note that the completion date for design Ref.4) a) Further information describing the has changed from April 2014 to June maintenance and testing program the 2014; however, submittal of results in licensee will establish and implement August 2014 has not changed.
to ensure that regular testing and calibration is performed and I
verified by inspection and audit to demonstrate conformance with design and system readiness requirements.
Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
b) A description of how the guidance in NEI12-02 section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days.
RESPONSE
Device testing and calibration requirements analysis will be performed Page 10 of 13
Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 as part of the detailed design process just prior to turnover to Operations. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Braidwood will start the design phase in November 2013 with design completion and 100% acceptance of the design in June 2014. Following the issue of the design, procedures will start being I developed. The requested information will be provided in the August 2014, 6-month Integrated Plan update.
Interim Safety Evaluation Open Items I
01# Description Status 1 RAI Question: Started.
(RAI-1, Provide the results of the calculation Ref. 5) used to determine the water elevation necessary for the SFP cooling pump required NPSH to confirm that Level1 has been adequately identified.
2 RAI Question: Not Started.
(RAI-3, Provide additional information Ref. 5) describing how the final arrangement of the SFP instrumentation and routing of the cabling between the level instruments, the electronics and the displays, meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.
3 RAI Question: Not Started.
(RAI-5, For RAJ 4{a) above, provide the Ref. 5) analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design basis maximum seismic loads and the hydrodynamic toads that could result from pool sloshing or other effects that could accompany such seismic forces.
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Braidwood Station, Units 1 and 2 Second Six*Month Status Report for the Implementation of SFPLI February 28, 2014 4 RAI Question: Not Started.
(RAI*6, For each of the mounting attachments Ref. 5) required to attach SFP level equipment to plant structures, please describe the design Inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.
5 RAI Question: Not Started.
(RAI-8, For RAI #7 above, provide the results Ref. 5) from the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
6 RAI Question: Not Started.
(RAI-13, Provide a list of the procedures Ref. 5) addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP Instrumentation.
Provide a brief description of the specific technical objectives to be achieved within each procedure.
Note: RAis not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAisin Reference 3 and are listed in the Overall Integrated Plan Open Item Table.
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-13* 027)
- 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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Braidwood Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014
- 3. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated July 11, 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 31,2013 (RS-13-194).
- 5. USNRC letter to Exelon Generation Company, LLC, "Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", dated November 4, 2013.
- 6. First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 28, 2013 (RS-13-112).
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