RS-15-136, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML15182A009
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 07/01/2015
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-136
Download: ML15182A009 (7)
v • d • e


Text

Exelon Generation Order No. EA-12-051 RS-15-136 July 1, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Report of Full Compliance with 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, "Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012
3. 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 (RS 181)
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-13-032)
6. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 24, 2013
7. Exelon Generation Company, LLC letter to NRC, Response to Request For Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051 ),

dated July 18, 2013 (RS-13-177)

8. 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-13-122)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page2

9. 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 022)
10. Exelon Generation Company, LLC 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), dated August 28, 2014 (RS-14-200)
11. Exelon Generation Company, LLC Fourth 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 27, 2015 (RS 030)
12. NRC letter to Exelon Generation Company, LLC, Limerick Generating 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 October 23, 2013
13. NRC letter to Exelon Generation Company, LLC, Limerick Generating Station, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051, dated March 17, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-051 , "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed 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 (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed 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 Limerick Generating Station, Units 1 and 2 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 8, 9, 10, and 11 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Limerick Generating Station, Units 1 and 2.

The purpose of this letter is to provide the report of full compliance with the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Limerick Generating Station, Units 1 and 2.

Limerick Station has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Limerick Station OIP Open Items have been addressed and closed as documented in References 8, 9, 10, and 11, and are considered complete pending NRC closure. The information provided herein documents full compliance for Limerick Generating Station, Units 1 and 2 with Reference 1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page 3 EGC's response to the NRC OIP Requests for Additional Information (OIP RAls), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAls) identified in References 6 and 12 have been addressed and closed as documented in References 7, 8, 9, 10, and 11, and below, and are considered complete pending NRC closure. EGC's response to the NRC audit questions and additional audit open items have been addressed as documented in the NRC Site Audit Report (Reference 13). Reference 13 contains no remaining audit open items regarding Limerick Station compliance with NRC Order EA-12-051.

The following table provides completion references for each NRC OIP RAI and ISE RAI.

OIP Open Item No. 1 Reference 8 OIP RAI No. 1 Reference 7 OIP RAI No. 2 (Open Item No. 3, Ref. 6) Reference 1O OIP RAI No. 3 (Open Item No. 4, Ref. 6)

OIP RAI No. 4 (Open Item No. 5, Ref. 6)

OIP RAI No. 6 (Open Item No. 7, Ref. 6)

OIP RAI No. 7 (Open Item No. 8, Ref. 6)

OIP RAI No. 9 (Open Item No. 10, Ref. 6)

OIP RAI No. 10 (Open Item No.11, Ref. 6)

OIP RAI No. 5 (Open Item No. 6, Ref. 6) Reference 1O and updated with this submittal as provided below OIP RAI Nos. Ba, 8b (Open Item No. 9, Ref. Reference 11 6)

OIP RAI Nos. 8c, 8d (Open Item No. 9, Ref. Reference 11 and updated with

6) this submittal as provided below OIP RAI No. 11 (Open Item No. 12, Ref. 6) References 10 and 11 ISE RAI No. 1a (Open Item No. 1, Ref. 12) Reference 11 and updated with this submittal as provided below ISE RAI No. 2 (Open Item No. 2, Ref. 12) Reference 9 ISE RAI No. 4 (Open Item No. 3, Ref. 12) Reference 1O ISE RAI No. 6 (Open Item No. 4, Ref. 12)

ISE RAI No. 7 (Open Item No. 5, Ref. 12)

ISE RAI No. 14 (Open Item No. 7, Ref. 12)

ISE RAI No. 15 (Open Item No. 8, Ref. 12)

ISE RAI No. 1b (Open Item No. 1, Ref. 12) Reference 11 ISE RAI No. 9 (Open Item No. 6, Ref. 12) References 1O and 11 Note: ISE RAls are not duplicated in the table above if previously issued as OIP RAls in Reference 6.

The following table documents the completion of the fin al remaining open actions as identified in Reference 11, and the revised response to OIP RAI No. 5 regarding the additional instrument channel separation provided as described in Reference 13. As stated above, EGC provides the response for the following items and considers them to be complete for Limerick Station.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page 4 Item Description Reference OIP Open Item No. 6 Complete (RAI* 5, Ref. 6)

To resolve the NRC concern identified during the b) Further information on Audit for implementation of mitigating strategies how each level and reliable spent fuel pool instrumentation related measurement system, to Order EA-12-051, the junction boxes for the consisting of level sensor Primary and Backup channels coax cables have electronics, cabling, and been relocated to provide a separation of readout devices will be approximately 13 feet (Reference 13).

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.

OIP Open Item No. 9 Complete (RAl-8c, 8d, Ref. 6) c) The Limerick functional test and calibration c) A description of how requirements are combined in the same functional checks will be procedure IC-11-00339 for both the Primary and performed, and the Backup channels. The Limerick procedure is frequency at which they associated with a preventive maintenance task will be conducted. that establishes the required performance of the Describe how calibration procedure within 60 days of a scheduled tests will be performed, refueling outage of either unit. This procedure is and the frequency at which based on the Westinghouse Two Point they will be conducted. Verification Method and WNA-TP-04709-GEN Provide a discussion as to Spent Fuel Pool Instrument System Calibration how these surveillances Procedure. The Limerick procedure notes the will be incorporated into high point reading (Point 1) from the output the plant surveillance reading on the digital display. The low point program. reading (Point 2) on the digital display is noted by lifting the Coax cable out of the pool to a predefined marked point on the cable. The d) A description of what probe is lowered back into the water freely preventive maintenance suspended from the launch plate. The level tasks are required to be indication is recorded. If the values recorded for performed during normal the 2-point check are within the tolerance operation, and the planned specified, the procedure is exited. If the values

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page 5 maximum surveillance are not within tolerance, an Issue Report (IR) interval that is necessary will be generated and calibration will be to ensure that the performed to bring the indication within the channels are fully calibration requirements.

conditioned to accurately and reliably perform their The calibration steps of the Limerick procedures functions when needed. were taken from Westinghouse document WNA-TP-04709-GEN Spent Fuel Pool Instrument System Calibration Procedure.

d) Limerick Station developed preventive maintenance tasks for 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.

ISE Open Item No.1 (RAI Complete 1a, Ref. 12) a) A description of the Procedure M-097-009 has been revised to notify operational circumstances Shift Management when the cask pit gate is to under which the gates are be installed and to establish compensatory expected to be installed, actions if the gate is installed greater than 90 and describe how days.

continuous back-up monitoring (e.g., direct visual observation) is available when the gates are installed.

MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall lnteqrated Plan February 28, 2013 Submit Responses to RAls July 18, 2013 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Uodate 3 Auqust 28, 2014 Provide Final Safety Evaluation (SE) Information September 30, 2014 Update 4 February 27, 2015 Modifications:

Conceptual Design 302012 Issue Exelon Fleet contract to procure SFPI 202013 Equipment

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page6 Milestone Completion Date Beqin Detailed Desiqn Enqineerinq 302013 Complete and Issue SFPI Modification Package 302014 Beqin Installation 102015 Complete SFPI Installation and Put Into Service April 25, 2015 ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Limerick Station, as well as the site overall integrated plan response submittal (Reference 5), the 6-Month Status Reports (References 8, 9, 10, and 11 ),

and any additional docketed correspondence, demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Limerick Station has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051 . The required actions have been integrated into the site procedures for monitoring level during events and responding to loss of SFP inventory.

INSTRUMENT DESIGN FEATURES-COMPLETE The design of the instruments installed at Limerick Station complies with the requirements specified in the Order and described in NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051". The instruments have been installed in accordance with the station design control process.

The instruments have been arranged to provide reasonable protection against missiles.

The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their design accuracy following a power interruption and are designed to allow for routine testing and calibration.

The instrument display is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.

PROGRAM FEATURES - COMPLETE Training for Limerick Generating Station, Units 1 and 2, has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1. The completion of the training is as follows:

Operations training is complete.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 1, 2015 Page 7 Maintenance completed on-the-job training for calibrating the level instruments.

Operating and maintenance procedures for Limerick Station have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

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 1st day of July 2015.

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Limerick Generating Station, Units 1 and 2 NRC Project Manager, NRR - Limerick Generating Station, Units 1 and 2 Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRC Ms. Jessica A. Kratchman, NRR/JLD/JPSB, NRC Mr. John D. Hughey, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

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