RS-14-195, Third 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)

Third 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)

ML14248A208
Person / Time
Site:	Braidwood
Issue date:	09/05/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-195
Download: ML14248A208 (37)

Text

AMINI/

4M1Mr, Exelon Generation, Order No. EA-12-051 RS-14-195 August 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:

Third 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. Exelon Generation Company, LLC 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), dated February 28, 2014 (RS-14-017)

8. 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, dated November 4, 2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 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 EGO 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 EGO 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. References 6 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition 0.2, of Reference 1 for Braidwood Station. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition 0.2, 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 8.

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 2014.

Respectfully submitted, 77 Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Stephen R. Monarque, NRR/JLD/JPMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Joel S. Wiebe, NRR/DORULPL3-2, NRC Mr. John Hughey, NRR/JLD/MSD, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (33 pages)

Braidwood Station, Units 1 and 2 Third 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 second 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 Second Six-Month status report (Reference 7), and are current as of August 28, 2014.

• Provided responses to all RAls via ePortal on 7/1/2014

• Completed and Issued SFPI Modification Package 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 31, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Complete with Update 3 August 28, 2014 this submittal Page 1 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Revised Target Activity Target Milestone Completion Date Status Completion Date Provide Final Safety Evaluation September 30, Complete (SE) Info 2014 Update 4 February 28, 2015 Not Started Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Design 402013 Complete Engineering Complete and Issue SFPI 202014 Complete 302014 Modification Package Begin Installation 1Q2015 Not Started Complete SFPI Installation and 202015 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 (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Items 01# Description Status 1 For Level 1, specify how the Complete.

identified location represents (RAI-1a, Page 2 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status Ref.4) the higher of the two points Level 1 is the level adequate to support described in the NEI 12-02 operation of the normal fuel pool cooling guidance for this level. system. It is the higher of the following two points:

1) The level at which reliable suction loss occurs due to uncovering the coolant inlet pipe or any weirs or vacuum breakers associated with suction loss.

For Braidwood, this is the level at which suction loss occurs due to uncovering the inlet pipe strainer. This level, (1), is elevation 417'-9314", not considering any required margin as a result of vortex formation.

2) The level at which the water height, assuming saturated conditions (boiling);

above the centerline of the cooling pump shaft provides the required net positive suction head. This level is 422'-

0" at 2,000 qpm per pump and corresponds to the high point elevation of the inside of the suction piping.

Water level below this elevation will result in vapor void formation inside the piping for pool temperatures of 212 °F.

The typical margin required to prevent vortex formation at Point 1 is estimated to be less than the difference between Point 1 and Point

2. Thus, the higher of the above points is (2).

Therefore, LEVEL 1 is 422'-0" and is applicable to both units.

2 Open Item:

Complete.

(Ref.1) Continuous level indication will (Addressed in Reference 6) be provided by a guided wave radar system, submersible Page 3 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status 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 (Addressed in Reference 4)

Ref. 4) depicting 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: Complete.

(RAI-2, Provide a clearly labeled sketch The marked-up sketch is provided in Ref.4) or marked-up plant drawing of Attachment 1, attached with this submittal.

the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and 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.

5 RAI Question: Complete.

Page 4 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status (RAI-3, Provide the following: a) All Spent Fuel Pool Instrumentation Ref.4) a) The design criteria that will be System (SFPIS) equipment will be used to estimate the total designed in accordance with the loading on the mounting Braidwood Station Safe Shutdown device(s), including static Earthquake (SSE) design weight loads and dynamic requirements.

loads. Describe the methodology that will be used The vendor, Westinghouse, has to estimate the total loading, evaluated the structural integrity of the inclusive of design basis mounting brackets in calculation ON-maximum seismic loads and PEUS-13-24. The GTSTRUDL model, the hydrodynamic loads that used by Westinghouse to calculate the could result from pool stresses in the bracket assembly, sloshing or other effects that considers load combinations for the could accompany such dead load, live load and seismic load seismic forces. on the bracket. The reactionary forces b) A description of the manner calculated from these loads become in which the level sensor (and the design inputs to design the stilling well, if appropriate) mounting bracket anchorage to the will be attached to the refuel floor to withstand a Safe refueling floor and/or other Shutdown Earthquake (SSE).

support structures for each planned point of attachment Seismic of the probe assembly.

Indicate in a schematic the The seismic loads are obtained from portions of the level sensor Braidwood Station's response spectra that will serve as points of curves (Reference Updated FSAR attachment for Chapter 3 Figures for Braidwood mechanical/mounting or Nuclear Generating Station). The electrical connections, following methodology was used in c) A description of the manner determining the stresses on the bracket by which the mechanical assembly:

connections will attach the

• Frequency analysis, taking into level instrument to permanent account the dead weight and the SFP structures so as to hydrodynamic mass of the support the level sensor structure, is performed to obtain the assembly .

natural frequencies of the structure in all three directions.

• SSE (Safe Shutdown Earthquake) response spectra analysis is performed to obtain member stresses and support reactions.

• Modal responses are combined using the Ten Percent Method per U.S. NRC Regulatory Guide 1.92, Page 5 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status Revision 1, "Combining Modal Responses and Spatial Components in Seismic Response Analysis". This method is endorsed per Appendix A of the Updated FSAR Revision 14 for Braidwood Nuclear Generating Station.

• The seismic loads for each of the three directions are combined by the Square Root of the Sum of Squares (SRSS) Method.

• Sloshing analysis is performed to obtain liquid pressure and its impact on bracket design.

• The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum. These combined results are compared with the allowable stress values.

Sloshing Sloshing forces were obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach has been used to estimate the wave height and natural frequency.

Horizontal and vertical impact force on the bracket components was calculated using the wave height and natural frequency obtained using TI D-7024 approach. Using this methodology, sloshing forces have been calculated and added to the total reactionary forces that would be applicable for bracket anchorage design. The analysis also determined that the level probe can withstand a credible design basis seismic event. During the design basis event, the SFP water level is expected to rise and parts of the level Page 6 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status sensor probe are assumed to become submerged in borated water. The load impact due to the rising water and submergence of the bracket components has also been considered for the overall sloshing impact. Reliable operation of the level measurement sensor with a submerged interconnecting cable has been demonstrated by analysis of previous Westinghouse testing of the cable, and the vendor's cable qualification. Boron build up on the probe has been analyzed to determine the potential effects on the sensor in WNA-TR-03149-GEN.

The following Westinghouse documents provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a. CN-PEUS-13-24 Pool-side Bracket Seismic Analysis

b. LTR-SEE-II-13-47, WNA-TR-03149-GEN Sloshing Analysis

c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification of other components of SFPI Braidwood Station specific calculations 12.3.4-BRW-10-0021 Seismic Qualification of Instrument Mounting Details Associated with Plant Process Computer Replacement, and BRW 0109-M- Seismic Qualification of Weschler Indicator VX-252, are being developed to address the seismic qualification of the readout display (Weschler Instruments) in the main control room (MCR). The design Page 7 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status criteria used in this calculation meets the requirements to withstand a SSE and will meet the Braidwood Station safety related installation requirements.

The methods used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, will be suspended from the launch plate via coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors. Attachment 2 shows a schematic of the level sensor with mechanical attachment points.

c) The bracket assembly that supports the sensor probe and launch plate will be mechanically connected to the SFP structure. The mechanical connection consists of four concrete expansion anchors that will bolt the bracket assembly to the SFP structure via the base plate. The concrete expansion anchors will be designed to withstand SSE and will meet the Braidwood Station safety related installation requirements. The qualification details of the bracket are provided in Westinghouse's Pool-side bracket Seismic Analysis CN-PEUS-13-24 and the qualification of the anchorage to the floor is provided in Braidwood Station specific calculation BRW-14-0009-S and 12.3.4-BRW-14-0116-S, Evaluation of SFPI Sensor Mounting Detail Anchorage and Mounting for OPLO4J and OPLO6J.

6 RAI Question: Complete.

(RAI-4, Provide the following: a) Beyond Design Basis Environment Page 8 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status Ref.4) a) A description of the specific Westinghouse qualified the components method or combination of (probe, connector, cable) of the SFPIS methods that will be applied located in the SFP area to the beyond to demonstrate the reliability design basis environment. Components of the permanently installed of the system were subjected to beyond equipment under beyond- design basis conditions of heat and design basis ambient humidity, thermal and radiation aging temperature, humidity, shock, mechanisms. This testing confirmed vibration, and radiation functionality of these system components conditions. under these beyond design basis b) A description of the testing environmental conditions. Westinghouse and/or analyses that will be performed testing to ensure aging of the conducted to provide components in the SFP area will not have assurance that the equipment a significant effect on the ability of the will perform reliably under the equipment to perform following a plant worst-case credible design design basis earthquake. Exelon has basis loading at the location reviewed the documents and found where the equipment will be acceptable. Reference Westinghouse mounted. Include a documents EQ-TP-351, WNA-TR-03149-discussion of this seismic GEN, and EQ-TP-354 for description of reliability demonstration as it specific qualification methods.

applies to a) the level sensor mounted in the SFP area, and Mild Environment Westinghouse b) any control boxes, qualified the system components (display electronics, or read-out and panel, sensor) that reside in the mild re-transmitting devices that environment conditions to determine that will be employed to convey the components can satisfactorily perform the level information from the to those conditions. Westinghouse has level sensor to the plant determined that aging does not have a operators or emergency significant effect on the ability of the responders.

equipment to perform following a plant c) A description of the specific design basis earthquake. Exelon has method or combination of methods that will be used to reviewed the documents and found confirm the reliability of the acceptable. Reference Westinghouse permanently installed documents EQ-QR-269, WNA-TR-03149-equipment such that GEN for description of specific methods.

following a seismic event the instrument will maintain its required accuracy. MCR Display Braidwood Station specific calculation (12.3.4-BRW-10-0021-S &

BRW-14-0109-M- Seismic Qualification of Weschler Indicator VX-252) includes a Report of Qualification Testing performed by the vendor (Weschler Instruments).

The methods used by the vendor to qualify Page 9 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status the readout display follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

For temperature and humidity qualification of the displays IEEE 344-2004, IEEE 323-2003, NRC Regulatory Guides 1.100, Revision 2; 1.209, March 2007; and EPRI TR-107330 guidance was followed. The habitability of the MCR will be maintained as part of the FLEX strategies, and therefore, the readout display in the MCR will not be subject to harsh environmental or radiological conditions.

Shock and Vibration SFPIS pool side brackets were analyzed for Safe Shutdown Earthquake design requirements per NRC order EA-12-051 and NEI 12-02 guidance. As provided by the NRC Order EA-12-051, the NEI 12-02 guidance and as clarified by the NRC interim staff guidance, the probe, coaxial cable, and the mounting brackets are "inherently resistant to shock and vibration loadings." As a result, no additional shock and vibration testing is required for these components. SFPIS pool side brackets for both the primary and backup Westinghouse SFP measurement channels will be permanently installed and fixed to rigid refuel floors, which are Seismic Category 1 structures. The SFPI system components, such as level sensor and its bracket, display enclosure and its bracket, were subjected to seismic testing, including shock and vibration test requirements. The results for shock and vibration tests were consistent with the anticipated shock and vibration expected to be seen by mounted equipment. The level sensor electronics are enclosed in a Page 10 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status NEMA-4X housing. The display electronics panel utilizes a NEMA-4X rated stainless steel housing as well.

These housings will be mounted to a seismically qualified wall and will contain the active electronics, and aid in protecting the internal components from vibration induced damage.

Reference Westinghouse reports WNA-DS-02957 and WNA-TR-03149-GEN for shock and vibration.

b) The seismic adequacy of the SFPIS (all components) is demonstrated by vendor testing and analysis in accordance with below listed standards:

• IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class lE Electrical Equipment for Nuclear Power Generating Stations

• IEEE-323-2003, Standard for Qualifying Class lE Equipment for Nuclear Power Generating Stations

• USNRC Regulatory Guide 1.100, Rev. 2

• USNRC Regulatory Guide 1.92, Rev. 1

• Calculation 12.3.4-BRW 0021-S, Seismic Qualification of Instrument Mounting Details Associated with Plant Process Computer Replacement

• BRW-14-0109-M - Seismic Qualification of Weschler Indicator VX-252 c) Westinghouse has seismically qualified Page 11 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status the SFPI instrument and its components. CN-PEUS-13-24 describes Pool-side Bracket Seismic Analysis, EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 describe remaining seismic qualifications of the instrument components. With the instrument being seismically qualified and installed as described in RAI 6b response, including the readout display in the main control room, the instrument is assured to maintain reliable and accurate indication when required.

Westinghouse report WNA-CN-00301-GEN and Braidwood Engineering Change 394935 provide the channel accuracy from measurement to display.

7 RAI Question:

Complete.

(RAI-5, Provide the following:

The two channels of the proposed level Ref.4) a) A description of how the two channels of the proposed measurement system will be installed such level measurement system that:

meet this requirement so that a) The level probes will be mounted on the the potential for a common west wall of the SFP and will be separated cause event to adversely by a distance greater than the span of the affect both channels is shortest side of the pool. This meets the minimized to the extent NEI 12-02 revision 1 guidance for channel practicable.

b) Further information on how separation.

each level measurement b) The level sensor enclosure and the system, consisting of level electronics/ Uninterruptible Power Supply sensor electronics, cabling, (UPS) enclosure for the primary instrument and readout devices will be channel will be installed in the Auxiliary designed and installed to Building in Unit 1 Electrical Penetration address independence Area. The level sensor enclosure and the through the application and selection of independent electronics/ UPS enclosure for the backup power sources, the use of instrument channel will be installed in Unit physical and spatial 2 Electrical Penetration Area.

separation, independence of Independence, physical and spatial signals sent to the location(s) separation of the level sensors and of the readout devices, and electronics/UPS enclosures for primary and the independence of the backup instrument channels is maintained displays.

Page 12 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status by routing the associated instrument channel cables through Unit 1 and Unit 2 respectively.

The 120 VAC power to the primary instrument will be provided from a Unit 1 ESF-Division 2 MCC (132X2), and 120 VAC power to the backup level instrument will be provided from a Unit 2 ESF Division 2 MCC (232X2). The 120VAC distribution panels for the primary and backup instruments are powered by different 480V safety buses. Therefore the loss of any one bus will not result in the loss of ac power to both instrument channels.

Attachment ldemonstrates the physical separation between the primary and backup power sources.

An analog level indicator for each channel will be provided in the Main Control Room (MCR). The primary channel indicator will be located on the Unit 1 side of the MCR at panel 1PM06J. The backup channel indicator will be located on the Unit 2 side of the MCR at panel 2PM06J. These analog level indicators will be credited as the level indications used by operators to satisfy the NRC Order EA-12-051 requirements. Providing the 120VAC power to primary and backup instrument channels from separate MCCs will address the concerns regarding power supply independence. Also, installing the SFP level indicator displays for primary and backup channels in separate units (Unit 1 for primary and Unit 2 for backup channels) addresses the concerns regarding physical and spatial separation.

All power and instrument cables associated with the primary channel will be routed on the Unit 1 side of Auxiliary Building and Fuel Handling Building; and all power and Page 13 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status instrument cables associated with the backup channel will be routed on the Unit 2 side of the Auxiliary Building and Fuel Handling Building to meet the physical and spatial separation requirements.

8 RAI Question: Complete.

(RAI-6, Provide the following: a) The primary and backup SFPLI Ref.4) a) A description of the electrical instrument channels will be normally ac power sources and powered from 120 VAC Unit 1 and Unit capabilities for the primary and 2 ESF Division 2 MCC respectively.

backup channels.

These are on different safety buses, b) Please provide the results of the calculation depicting the which maintains power source battery backup duty cycle independence. Upon loss of normal AC requirements demonstrating power, individual batteries installed in that its capacity is sufficient to each channel's electronics/ UPS maintain the level indication enclosure will automatically maintain function until offsite resource continuous channel operation for at availability assured. least three (3) days. The power cables will be routed on the Unit 1 side for the primary channel and on the Unit 2 side for the backup channel so that spatial and physical separation is maintained between the primary and backup channels. These ESF MCCs have also been identified as part of the FLEX strategy to ensure that the SFPLI will have ac power restored if a Beyond Design Basis External Event would occur. Additionally, a receptacle and a selector switch are installed in each channel electronics/ UPS enclosure to directly connect emergency power to the SFPLI.

b) The Westinghouse Report, WNA-CN-00300-GEN, provides the results of the calculation depicting the battery backup duty cycle. This calculation demonstrates that battery capacity is 4.22 days to maintain the level indicating function to the display Page 14 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status location, located in the Electrical Penetration Area at Braidwood Station.

The calculation also determines that the battery will last for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assuming the remote display in the MCR consumes a maximum of 0.064 Amps. Braidwood Station is crediting the MCR display as the primary display.

The remote display vendor (Weschler's) data sheet indicates the readout display is self-contained. It will be calibrated to consume no more than 0.022 Amps, which is bounded by the 0.064 Amps assumed in the Westinghouse calculation above.

Therefore, the Braidwood Station readout display of level indication in the MCR will be available for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation. The results of the calculation meet the NEI 12-02 requirements.

9 RAI Question: Started.

(RAI-7, Provide the following: a) The Westinghouse documents WNA-Ref.4) a) An estimate of the expected CN-00301 and WNA-DS-02957-GEN instrument channel accuracy describe the channel accuracy under performance under both (a) both (a) normal SFP level conditions normal SFP level conditions and (b) at the Beyond Design Basis (approximately Levell or higher) (BDB) conditions that would be present and (b) at the beyond design- if SFP level were at Level 2 and Level 3 basis conditions (i.e., radiation, datum points. Each instrument channel temperature, humidity, post- will be accurate to within +/-3"during seismic and post-shock normal spent fuel pool level conditions.

conditions) that would be The instrument channels will retain this present if the SFP level were at accuracy after BDB conditions, in the Level2 and Level3 datum accordance with the above points. Westinghouse documents. The same b) A description of the channel accuracy requirements are methodology that will be used applicable to the readout display in the for determining the maximum main control room as the display allowed deviation from the enclosures are installed locally in the instrument channel design Electrical Penetration Area. Braidwood accuracy that will be employed Station has analyzed the channel under normal operating accuracy to the main control room Page 15 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status conditions as an acceptance indicators in the Engineering Change criterion for a calibration package 394935, Revision 0 for the procedure to flag to operators normal operating conditions and and to technicians that the determined that the displayed level is channel requires adjustment to accurate to within +/-5.06". Braidwood is within the normal condition in the process of analyzing the channel design accuracy. accuracy to the main control room indicators for the BDB conditions.

Braidwood will complete the analysis by September 30, 2014. At this time Braidwood station believes the accuracy will be within the channel accuracy requirements of the Order (+/-1 foot) for BDB conditions.

b) The Westinghouse document WNA-TP-04709-GEN describes the methodology for routine testing/calibration verification and calibration methodology. This document also specifies the required accuracy criteria under normal operating conditions. Braidwood Station calibration and channel verification procedures will follow the guidance and criteria provided in this document.

Instrument channel calibration will be performed if the level indication reflects a value that is outside the acceptance band established in the Braidwood Station calibration and channel verification procedures.

Instrument channel loop accuracy and set point deviation/error are determined using the Braidwood Station Engineering Standard NES-EIC-20.04 for safety related instruments. The methodology used to determine the set point deviation in this standard is consistent with ANSI/ISA-67.04.01-2000. Per this methodology, since drift value was not specified by the vendor, a default random drift value of +/-1% of span (or +/-1% of full scale, for conservatism) for mechanical Page 16 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status components were assigned. A setting tolerance of twice the reference accuracy, which is a typical value, was applied to the indicator to yield an overall setting tolerance of +/-- 2% of full scale. This value will be used for the calibration procedure being developed for this instrument loop. The resultant non-negligible terms (Reference Accuracy, Drift, Readability, Measurement and Test Equipment Effect, and Setting Tolerance) are all random terms, and will be combined using the Square Root Sum of Squares (SRSS) methodology given in Engineering Standard NES-EIC-20.04.

Thus, the maximum deviation introduced by the indicator, in percent of full span, is computed.

Calibration will be performed once per refueling cycle for Braidwood Station.

Per Westinghouse document WNA-TP-04709-GEN calibration on a SFP level channel is to be completed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g. 25%). This is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation.

10 RAI Question: Started.

(RAI-8, Provide the following: a) Westinghouse calibration procedure Ref.4) a) A description of the capability WNA-TP-04709-GEN and functional and provisions the proposed test procedure WNA-TP-04613-GEN level sensing equipment will describe the capabilities and provisions have to enable periodic testing of SFPI periodic testing and calibration, and calibration, including how including in-situ testing. Westinghouse this capability enables the calibration and functional test equipment to be tested in-situ, procedures are acceptable for Braidwood. However, Braidwood must b) A description of how such use a different in-situ test methodology testing and calibration will to accommodate Braidwood's low enable the conduct of regular profile bracket installation.

channel checks of each Westinghouse provided letter LTR-independent channel against the SFPIS-14-55, Revision 0 (SFPIS 2 Page 17 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status other, and against any other Point Verification Methodology) permanently-installed SFP level describing the new in-situ test instrumentation, methodology to accommodate low c) A description of how profile bracket. Exelon has reviewed functional checks will be the letter and found it acceptable.

performed, and the frequency at b) The level displayed by the channels will which they will be conducted. be verified per the Braidwood Station Describe how calibration tests administrative and operating will be performed, and the procedures, as recommended by frequency at which they will be Westinghouse vendor technical manual conducted. WNA-G0-00127-GEN. If the level is d) A discussion as to how these not within the required accuracy per surveillances will be Westinghouse recommended tolerance incorporated into the plant in WNA-TP-04709-GEN, channel surveillance program. calibration will be performed.

e) A description of the c) Functional checks will be performed per preventive maintenance tasks Westinghouse functionality test required to be performed during procedure WNA-TP-04613-GEN at the normal operation, and the Westinghouse recommended planned maximum surveillance frequency. Calibration tests will be interval that is necessary to performed per Westinghouse assure that the channels are calibration procedure WNA-TP-04709-fully conditioned to accurately GEN at the Westinghouse and reliably perform their recommended frequency.

functions when needed. d) In accordance with Braidwood Station maintenance and operating programs, Braidwood Station will develop calibration, functional test, channel verification procedures per Westinghouse recommendations to ensure reliable, accurate and continuous SFPI functionality by June 1,2015.

e) Braidwood Station will develop preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-G0-00127-GEN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed by June 1,2015.

11 RAI Question: Complete.

(RAI-9, Please provide the following: (Addressed in Reference 6)

Page 18 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status 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" to various drain-down scenarios and external events.

12 RAI Question:

Replaced by Interim SE RAI #13.

(RAI-10, Please provide the following:

Ref.4) a) A list of the operating (both normal and abnormal response) procedures, calibration/test procedures, 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 Page 19 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable components when needed 13 RA! Question:

Complete.

(RAI-11, Provide the following:

a) Performance tests (functional checks)

Ref.4) a) Further information describing the maintenance and Operator performance checks will and testing program the be described in detail in the vendor licensee will establish and operator's manual, and the applicable implement to ensure that information is planned to be contained regular testing and calibration in plant operating procedures. Operator is performed and verified by performance tests are planned to be inspection and audit to performed periodically as demonstrate conformance recommended by the equipment with design and system vendor. Channel functional tests per readiness requirements.

Include a description of your operations procedures with limits plans for ensuring that established in consideration of vendor necessary channel checks, equipment specifications are planned to functional tests, periodic be performed at appropriate calibration, and maintenance frequencies established equivalent to or will be conducted for the level more frequently than existing SFPI.

measurement system and its Manual calibration and operator supporting equipment. performance checks are planned to be b) A description of how the performed in a periodic scheduled guidance in NEI 12-02 section 4.3 regarding compensatory fashion with additional maintenance on actions for one or both non- an as-needed basis when flagged by functioning channels will be the system's automated diagnostic addressed. testing features. Channel calibration c) A description of what tests per maintenance procedures with compensatory actions are limits established in consideration of planned in the event that one vendor equipment specifications are of the instrument channels planned to be performed at frequencies cannot be restored to established in consideration of vendor functional status within 90 recommendations. SFPI days.

channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness are planned to be established in Page 20 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status accordance with Exelon's processes and procedures and in consideration of vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit). Subject maintenance and testing program requirements are planned to be developed during the SFPI modification design process.

Response for b, c:

Both primary and backup SFPI channels incorporate permanent installation (with no reliance on portable, post-event installation) of relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) is (are) out-of-service for an extended period of time.

Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:

1. Required Compensatory Channel(s) Restoration Action if Out-of- Action Required Service Restoration Action not completed within Specified Time 1 Restore Immediately channel to initiate action functional in accordance status within with Note 90 days (or if below channel Page 21 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status restoration not expected within 90 days, then proceed to Compensatory Action) 2 Initiate action Immediately within 24 initiate action hours to in accordance restore one with Note channel to below functional status and restore one channel to functional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Note: Present a report to the on-site Plant Operations Review Committee (PORC) within the following 14 days. The report shall outline the planned alternate method of monitoring, the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.

Page 22 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete.

(RAI- Provide the results of Level 1 is the level adequate to support operation of the normal 1, the calculation used fuel pool cooling system. It is the higher of the following two Ref. to determine the points:

5) water elevation necessary for the SFP cooling pump 1) The level at which reliable suction loss occurs due to required NPSH to confirm that Level 1 uncovering the coolant inlet pipe or any weirs or vacuum has been adequately breakers associated with suction loss. For Braidwood, this is identified. the level at which suction loss occurs due to uncovering the inlet pipe strainer. This level, (1), is elevation 417-9 3/4", not considering any required margin as a result of vortex formation.

2) The level at which the water height, assuming saturated conditions (boiling); above the centerline of the cooling pump shaft provides the required net positive suction head. This level is 421'-6" at 2,000 gpm per pump and corresponds to the high point elevation of the inside of the suction piping. Water level below this elevation will result in vapor void formation inside the piping for pool temperatures of 212 °F.

The typical margin required to prevent vortex formation at Point 1 is estimated to be less than the difference between Point 1 and Point 2. Thus, the higher of the above points is (2).

Therefore, LEVEL 1 is 422'-0" and is applicable to both units.

2 RAI Question: Complete.

(RAI- Provide additional Two independent primary and backup instrument channels will 3, information be installed as part of this modification with indication for both Ref. describing how the channels at an operator accessible location. The location of the

5) final arrangement of level sensors on the top of the west wall of the SFP, separated the SFP by a distance greater than the span of the shortest wall, instrumentation and routing of the cabling Drovi

- des adequate separation between the two channels. The Page 23 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 between the level level transmitter and level indication display for the primary and instruments, the backup channels will be installed in the Auxiliary Building in electronics and the Unit 1 Penetration Area 5 and Unit 2 Penetration Area 7, displays, meets the Order requirement to respectively. The 120 VAC power to the primary and backup arrange the SFP level level indication display will be provided from Unit 1 and Unit 2 instrument channels ESF MCCs, respectively. An additional analog level indicator in a manner that for each channel will also be provided in the MCR at panels provides 1PM06J and 2PM06J, which will be credited as the level reasonable protection indication used to satisfy NRC Order EA-12-051. The power of the level indication function against and instrument cables will be routed on the Unit 1 side for missiles that may primary channel and on the Unit 2 side for the backup channel.

result from damage Therefore, adequate separation is maintained between the to the structure over primary and backup channels.

the SFP.

3 RAI Question: Complete.

(RAI- For RAI 4(a) above, The following Westinghouse documents provide the analyses 5, provide the analyses used to verify the design criteria and describe the methodology Ref. used to verify the for seismic testing of the SFP instrumentation and electronics

5) design criteria and units, inclusive of design basis maximum seismic loads and methodology for hydrodynamic loads that could result from pool sloshing and seismic testing of the SFP instrumentation other effects that could accompany such seismic forces:

and the electronics a. CN-PEUS-13-24 Pool-side Bracket Seismic Analysis units, including design basis b. LTR-SEE-I1-13-47, WNA-TR-03149-GEN Sloshing maximum seismic Analysis loads and the hydrodynamic loads c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 that could result from Seismic Qualification of other components of SFPI pool sloshing or No equipment failures lures were noted as a result of seismic test other effects that could accompany runs. Seismic test data has been documented in the seismic such seismic forces. test reports, referenced above.

Braidwood Station specific calculations 12.3.4-BRW-10-0021-S

- Seismic Qualification of Instrument Mounting Details Associated with Plant Process Computer Replacement, BRW-14-0009-S SFPI Sensor Mounting Detail Anchorage and BRW-14-0109-M - Seismic Qualification of Weschler Indicator VX-252, address the seismic qualification of the main control room indicators. The design criteria used in this calculation satisfies the requirements to withstand a SSE and will meet the Braidwood Station safety related installation requirements for mounting the readout displays in the main control room.

4 RAI Question: Complete.

(RAI- For each of the The structural integrity and mounting of SFP level equipment is 6, mounting based on formal calculations, plant drawings, and approved Page 24 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Ref. attachments required work plans per Exelon procedures and processes.

5) to attach SFP level equipment to plant Design Inputs include, but not limited to, the following:

structures, please

1. Component weights and dimensions, core hole locations and describe the design inputs, and the support details.

methodology that 2. The capability of concrete expansion anchors.

was used to qualify the 3. The loads (dynamic and static) for the probe mounting structural integrity of bracket.

the affected structures/equipment 4. Concrete properties

5. Seismic accelerations requirements for electrical equipment

6. Allowable stresses for structural bolts.

Methodology to qualify the safety related structural integrity includes, but not limited to, following:

1. Structural Weldments Qualifying the weld design entails the selection of a weld's physical attributes, such as type, configuration and size, which will make it suitable for transferring the prescribed loads within appropriate limits. This process involves determining the maximum unit forces on the weld and comparing them with the weld capacity. The methodology determines weld design forces by assuming nominal linear stress/strain distribution. For each design, the engineer must confirm that the distribution of stiffness within the joint is consistent with this assumption. In some cases more refined techniques may be required to predict appropriate distribution of weld forces.

2. Concrete Expansions - The design methodology of concrete expansion anchor assemblies involves 1) application of component attachment loads to the plate, 2) analysis of the assembly to determine the resultant tension and shear forces on individual anchors, 3) evaluation of the anchor forces relative to anchor allowables and 4) computation and evaluation of bending stresses in the CEA plate. Reactions for the attached component (applied to the plate at the centroid of the attachment weld) shall be resolved into moments, shears and axial loads (about the major axes of the expansion anchor plate).

3. Local Stress Effects The member local stresses for open sections are computed according to specific procedures for flange attachments, web attachments, attachments to flanges of beams supporting concrete, and attachments to webs of beams supporting concrete.

Page 25 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014

4. Existing Embedment Plate Evaluation - Embedment plates for mechanical/electrical component support attachments (i.e., pipe supports, conduit supports, HVAC supports, etc.) are evaluated as follows:

Determine embedment plate detail based on the component support design drawing and appropriate structural drawings.

Determine an allowable load for the embedment plate detail per plant design tables.

Ensure that the attachment location satisfies the location tolerances used in determining the embedment plate allowables.

Calculate reactions at face of embedment plate.

Determine if the embedment plate can be qualified per criteria.

5. Conduit and Conduit Supports - Structural adequacy of rigid conduit is evaluated by determining the critical span condition, loads, checking conduit stresses and verifying structural adequacy of conduit clamps. Structural adequacy of Conduit, Junction Boxes and Junction Box supports is evaluated by determining loads, calculating member forces and joint reactions, checking member stresses, checking connections, checking expansion anchor assemblies, checking attachments to structure and resolving overstresses.

6.Cable Tray Loading Violations (CTLVs) - The structural evaluation of cable tray supports for potential increase in design basis loading will be performed by identifying the hangers affected by the routing point. For each affected hanger controlling routing point will be determined. Then actual load associated with the routing point will be computed. Then the actual load will be compared to the load used in the hanger design. An evaluation of cable tray hanger for any increased load will be performed.

7. Category I Partition Walls - When qualifying a wall for a new/revised attachment, the following method is utilized:

• If the loads on the existing critical design strip are larger in magnitude than the loads on the design strip containing the new attachment, then the wall can be qualified by this comparison.

• If the wall cannot be qualified by comparison of loading, moment and shear due to the attachment shall be calculated Page 26 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 and their effects added to the critical design strip. New stresses or moment and shear will be compared to the allowable stresses/capacities.

If this results in an unacceptable overstress condition, detailed evaluation of the design strip containing the attachment is required. All existing attachments and core holes in the strip will be accounted for in this evaluation.

5 RAI Question: Started.

(RAI- For RAI #7 above, Below is a summary of the test conditions used by 8, provide the results Westinghouse to qualify the SFPIS. Environmental Ref. from the selected Conditions for SFPIS Components installed in the Spent Fuel

5) methods, tests and Pool Area at Braidwood Station are bounded by below test analyses used to conditions, except for radiation TID 12" above top of fuel rack demonstrate the qualification and for beyond design basis s conditions (BOB). The BDB radiation reliability of the TID, 12" above top of fuel rack for Braidwood is 4.E07 R y, per installed equipment calculation BYR13-051, "NEI 12-02 Spent Fuel Pool Doses."

in accordance with The BDB radiation value to which the Westinghouse equipment the Order is qualified to is 1.E07 R y, per Section 5.1.1 of WNA-TR-requirements. 03149-GEN. The radiation value of 4.E07 R y is higher than 1.E07 R y to which Westinghouse qualified the instrument to.

However, this value of 4.E07 R y is applicable only when the water is at Level 3. At Level 2 the TID reduces to 2.E07 R y and it further reduces to 8.E06 at Level 1 and above. With SFP water level at Level 3 the only components of SFPI that are exposed to high radiation are the stainless steel probe and the stainless steel anchor. The materials with which the probe and the anchor are manufactured are resistant to radiation effects.

The stainless steel anchor and stainless steel probe can withstand 40 year dose. Westinghouse updated the design specification (WNA-DS-02957-GEN) and LTR-SFPIS-13-35, Revision 1 documentation to include the above technical justification.

Environmental Conditions for SFPIS Components in the Spent Fuel Pool Area Level sensor probe, coax coupler and connector assembly, launch plate and pool side bracket assembly, coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Parameter Normal BOB Temperature 50-140°F 212°F Page 27 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Pressure Atmospheric Atmospheric Humidity 100% (saturated 0-95% RH steam)

Radiation TID y 1E03 Rads 1E07 Rads (above pool)

Radiation TID y 1E09 Rads 1E07 Rads (12" above (probe and top of fuel weight only) rack)

Environmental Conditions Outside of the Spent Fuel Pool Area The level sensor transmitter and bracket, electronics display enclosure and bracket are designed and qualified to operate reliably in the below specified environmental conditions.

BDB (Level Parameter Normal BDB Sensor Electronics Only)

Temperature 50-120°F 140°F 140°F Pressure Atmospheric Atmospheric Atmospheric Humidity 0-95% 0-95%

0-95% RH (non- (non-condensing) condensing)

Duration 3 days 3 days 3 days Radiation TID 5 1E03 R y 5 1E03 R 5 1 E03 R Y

Page 28 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Braidwood Station specific calculation (BRW-14-0109-M-Seismic Qualification of Weschler Indicator VX-252) describes the results of the qualification testing of the MCR readout display to the design basis temperature, humidity, and vibration to demonstrate its reliability. The display was also tested to demonstrate that it performed accurately under extreme heat and humidity conditions.

Thermal and Radiation Aging organic components in SFP area Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-03149-GEN provide thermal and radiation aging program details for the SFPI components. Westinghouse completed their thermal and radiation aging testing programs to qualify the SFPI components to 1.25 years. Exelon has reviewed the documents and found acceptable.

Additionally, Westinghouse is continuing their aging tests to age the system components to 10 years. These tests are projected to be completed towards end of Summer 2014. Final test reports are scheduled to be provided to Exelon by September 4, 2014. Exelon will complete the test report reviews by September 30, 2014.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirm that the SFPIS meets the seismic requirements of the vendor's design specification. Westinghouse's design specification satisfies the Braidwood Station installation requirements to withstand a SSE.

Vibration Justification As specified in RAI-6, components of the system (i.e., bracket, transmitter enclosure, display enclosure, and readout display in the MCR) will be permanently installed to meet the Page 29 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 requirements to withstand a SSE and will meet the Braidwood Station safety related installation requirements. Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification The sloshing calculation performed by Westinghouse was reviewed for a design basis seismic event and found acceptable. Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

6 RAI Question: Complete.

(RAI- Provide a list of the Appropriate quality measures will be selected for the SFPIS 13, procedures required by Order EA-12-051, consistent with Appendix A of Ref. addressing operation NEI 12-02. Site procedures will be developed for system

5) (both normal and inspection, calibration and test, maintenance, repair, operation abnormal response),

and normal and abnormal responses, in accordance with calibration, test, maintenance, and Exelon's procedure control process. Technical objectives to be inspection achieved in each of the respective procedures are described procedures that will below:

be developed for use of the spent SFP Procedure Objectives to be achieved instrumentation. 1. System Inspection: To verify that system components are in Provide a brief place, complete, and in the correct configuration, and that the description of the specific technical sensor probe is free of significant cant deposits of crystallized boric objectives to be acid.

achieved within each 2. Calibration and Test: To verify that the system is within the procedure.

specified accuracy is functioning as designed, and is appropriately indicating SFP water level.

3. Maintenance: To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.

4. Repair: To specify troubleshooting steps and component repair and replacement activities in the event of system malfunction.

5. Operation: to provide sufficient instructions for operation and use of the system by plant operation staff.

Page 30 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014

6. Responses: To define the actions to be taken upon observation of system level indications, including actions to be taken at the levels defined in NEI 12-02.

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 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.

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).

7. Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 28, 2014 (RS-14-017).

Page 31 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 ATTACHMENT 1 Braidwood Station, Units 1 and 2 SFPI LAYOUT IN PLAN VIEW Fuel Handling Building E le wition 426' 62' 0" AUXII la ry B ui Idi nci Elevation 426' 4--

Unit 1 Electrical Unit 2 Electrical P en etrati on Area P enetration Area U nit 1 Lovke.r Cable Unft 2 Lower Cable Spreading Room Spreading Room E lewition 439' Elevation 439' Main Control Room Elevation 451'

,Braidwood SFP level

-instrument Layout Page 32 of 33

Braidwood Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 ATTACHMENT 2 Braidwood Station Schematic of the Level Sensor with Mechanical Attachment Points Braidwood schematic Mechanical/

Mounting and Electrical Connections Page 33 of 33