RS-15-137, Provides 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)

Provides 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)

ML15198A113
Person / Time
Site:	Clinton
Issue date:	07/15/2015
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-137
Download: ML15198A113 (15)

Text

ExelonGeneratim Order No. EA-12-051 RS-1 5-137 July 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

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-1 2-051, "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, 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-1 2-051), dated February 28, 2013 (RS-1 3-029)

6. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7, 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 3, 2013 (RS-13-157)

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-1 2-051), dated August 28, 2013 (RS-1 3-116)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 2

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-1 2-051), dated February 28, 2014 (RS-1 4-019)

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-14-197) 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 027)

12. NRC letter to Exelon Generation Company, LLC, Clinton Power Station, Unit 1 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 No. MF0791), dated November 15, 2013 13.NRC letter to Exelon Generation Company, LLC, Clinton Power Station, Unit 1 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 (TAC No. MF0791),

dated April 27, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to Exelon Generation Company, LLC (EGG). 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 Clinton Power Station, Unit 1 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 Clinton Power Station, Unit 1.

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-1 2-051) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Clinton Power Station, Unit 1.

Clinton Power Station has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Clinton Power 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 Clinton Power Station, Unit 1 with Reference 1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 3 EGC's response to the NRC OIP Requests for Additional Information (OIP RAts), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAts) 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. EGG response to the NRC audit questions and additional audit open items have been addressed as documented in the NRC Site Audit Report (Reference 13).

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

OIP Open Item No. 1 Reference 5 OIP RAI No. 1 Reference 7 OIP RAI Nos. 3,4,6, 7a, lib, llc Reference 11 OIP RAI Nos. 2, 5, 7b, 8a, 8b, 8c, Reference 11 and updated with this 8d, 11a submittal as provided below ISE RAI Nos. 3, 4, 6, 8 Reference 11 ISE RAI Nos. 11, 12 Reference 11 and updated with this submittal as provided below Note: ISE RAts are not duplicated in the table above if previously issued as OIP RAts in Reference 6.

The table below documents the completion of the final remaining open actions as identified in Reference 11, and the revised response to OIP RAI Nos. 2 and 5 and ISE RAI No. 11 regarding the additional instrument channel separation provided as described in Reference 13.

Additionally, response to the SFPI audit item listed in Attachment 3 of Reference 13 is documented below. Since the NRC SFPI Order audit at Clinton Power Station, the response to ISE RAI No. 11 has been revised due to constructability issues in the field. The revised response for ISE RAI No. 11 is also provided below. As stated above, EGG provides the response for the following items and considers them to be complete for Clinton Power Station, Unit 1.

Item Description Reference OIP Item 5 (RAI- 5, Ref. 3)

OIP Item 2 (RAI- 2, Ref. 3)

Compplete The following is a summary of the additional b) Further information on the actions taken to provide as much physical and use of physical and spatial spatial separation within the Spent Fuel separation Building area utilizing, to the maximum extent practical, inherent shielding from missiles provided by existing recesses and corners in the Spent Fuel Building structure at Clinton Power Station (CPS) (Reference enclosed Sketch #2).

Spent Fuel Probes:

The two spent fuel probes were moved at opposite corners of the Spent Fuel Pool, one on the NE corner and the other on the SE

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 4 corner of the pool, to obtain the maximum extent practical separation. The original design had a separation of approximately 34 feet, and the final installed configuration has a separation of 45 feet, which meets the NEI 12-02 requirement of separating the sensors at least by the shortest distance of the pool edge (i.e.,

32 feet).

Probe Coax Cable Signal Routing:

Where the channels leave the spent fuel area, a change was made so the signal cable is routed in conduit on opposite faces of a two (2) foot wide webbed column, which is part of the support for the Fuel Building, a seismically designed and constructed structure. The channel cables are then routed, after leaving the top of the column, with one conduit (primary) being four (4) feet higher than the other to provide practically achievable separation due to interferences at the top of the column. After approximately eighteen (18) inches, the conduits maintain a separation of six (6) feet for a distance of approximately 10 feet into a separate conduit and a cable tray.

At the cable tray, the primary channel is routed in a robust cable tray, and the secondary channel is routed in its own conduit outside the cable tray. The cable tray provides reasonable protection to the primary channel. Both channels are supported by seismically installed support hangers. The cable tray and conduit remain common to the tray supports until approximately ten (10) feet from the North Fuel Building wall, where they then separate, one in the tray and the other in a conduit by a distance of approximately five (5) feet until penetrating the North Fuel Building wall.

Structural calculations lP-S-0303 and lP-S-0311 were revised, as required, to address the structural adequacy of conduit supports due to additional separation being provided from the column to the cable tray in the Fuel Building.

The above described changes further enhance the design for the SFPI at Clinton Power Station and meet the NEt 12-02 requirements.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 5 Justification for considering the cable tray to be robust:

Structural Design Criteria DC-SD-01 -CP provides guidance for load combination of component supports and various structures, specifically Section 6.1.4 "Abnormal Loads",

which provides the guidance to consider the different environmental conditions (when applicable) during design and qualification of the component supports. The subject cable tray and conduit support are designed to be redundant in the safety related building. Both supports and cable tray are evaluated for impacts caused by internally generated missiles in the Fuel Building.

The supports that hold the cable trays are designed seismically, and thus will not fail during a seismic event. Evaluation of missile impacts is explained below:

If the supports or the cable trays are subjected to a missile strike, the cable tray though a non-safety related component, is considered robust since it is constructed of 14 gauge material, as specified in the Clinton Power Station design specification K-2980, and provides reasonable assurance to resist a missile strike. The seismically installed supports are robust as well in order to meet the design basis seismic standards for Clinton Power Station.

In conclusion, with the supports being designed seismically, as required per DC-SD-01-CP, and the cable tray being sufficiently robust, the supports and cable tray are expected to be capable of surviving an internal missile impact.

OIP Item 7 (RAt- 7b, Ref. 3)

Complete b) A description of the The Westinghouse document WNA-TP-methodology that will be used 04709-GEN describes the methodology for determining the maximum for routine testing/calibration verification allowed deviation from the and calibration methodology. This document instrument channel design also specifies the required accuracy criteria accuracy that will be employed under normal operating conditions. Clinton under normal operating Power Station calibration and channel conditions as an acceptance verification procedures followed the guidance criterion for a calibration and criteria provided in this document and procedure to flag to operators developed site specific procedures.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 6 and to technicians that the channel requires adjustment to Instrument channel calibration will be within the normal condition performed if the level indication reflects design accuracy. a value that is outside the acceptance band established in the Clinton Power Station calibration and channel verification procedures.

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 test scheduling allowances (e.g., 25%). This is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation.

OIP Item 8 (RAI-8a, 8b, Bc, 8d, Ref. 3) Comp plete Please provide the following: a) Westinghouse calibration procedure a) A description of the WNA-TP-04709-GEN and functional capability and provisions the test procedure WNA-TP-0461 3-GEN proposed level sensing describe the capabilities and provisions equipment will have to enable of SFPI periodic testing and calibration, periodic testing and including in-situ testing. Clinton Power Station calibration, including how this used the above described Westinghouse capability enables the procedures and developed site specific equipment to be tested in-situ, calibration, channel verification and in-situ b) A description of how such testing procedures.

testing and calibration will enable the conduct of regular b) The level displayed by the channels will be channel checks of each verified per the Clinton Power Station independent channel against administrative and operating procedures, as the other, and against any recommended by Westinghouse vendor other permanently-installed technical manual WNA-GO-00127-GEN. If the SFP level instrumentation, level is not within the specified accuracy, per c) A description of how Westinghouse recommended tolerance functional checks will be in WNA-TP-04709-GEN, then channel performed, and the frequency calibration will be performed.

at which they will be conducted. Describe how c) Functional checks will be performed by calibration tests will be Clinton Power Station per the performed, and the frequency Westinghouse functionality test procedure at which they will be WNA-TP-0461 3-GEN and at the Westinghouse conducted. Provide a recommended frequency. Calibration checks discussion as to how these will be performed by Clinton Power Station per surveillances will be the Westinghouse calibration procedure WNA-incorporated into the plant TP-04709-GEN and at the Westinghouse surveillance program. recommended frequency in accordance with

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 7 d) A description of what Clinton Power Station maintenance and preventive maintenance tasks operating programs. The performance of these are required to be performed procedures will ensure reliable, accurate and during normal operation, and continuous SFPI functionality.

the planned maximum surveillance interval that is d) Clinton Power Station developed preventive necessary to ensure that the maintenance tasks for the SFPI per channels are fully conditioned Westinghouse recommendations identified in to accurately and reliably the technical manual WNA-GO- 001 27-GEN.

perform their functions when These preventative maintenance tasks will be needed. performed as a minimum, at the Westinghouse recommended frequency, and will ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

OIP Item 11 (RAI- 11 a, Ref. 3)

Complete a) Further information Performance tests (functional checks) and describing the maintenance Operator performance checks were and testing program the described in detail in the vendor operator's licensee will establish and manual, and the applicable information is implement to ensure that captured in plant operating procedures.

regular testing and calibration is performed and verified by Operator performance tests will be performed inspection and audit to by Clinton Power Station periodically as demonstrate conformance with recommended by the equipment vendor via design and system readiness Preventive Maintenance task process.

requirements. Please include a description of your plans for Channel functional tests per operating ensuring that necessary procedures with limits established in channel checks, functional consideration of vendor equipment tests, periodic calibration, and specifications will be performed by Clinton maintenance will be conducted Power Station at appropriate frequencies for the level measurement established per the Preventive Maintenance system and its supporting task process.

equipment.

Manual calibration and operator performance checks will be performed by Clinton Power Station per established preventive maintenance tasks with additional maintenance on an as-needed basis when flagged by the system's automated diagnostic testing features.

Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications will be performed by Clinton Power Station at frequencies established in

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 8 consideration of vendor recommendations.

SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness are established in accordance with Exelons 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. Subject maintenance and testing program requirements are developed during the SFPI modification design process.

All of these activities are subject to the inspection and audit process defined in the Exelon Quality Assurance Manual.

ISE Item 6 (RAI- 11, Ref. 5)

Complete Please provide the following:

a) The specific location for the a) An updated sketch of the specific location of primary and backup the primary and backup instrument channel instrument channel display. display (monitor) is depicted on the enclosed b) If a display will be revised Sketch #1, NRC RAI Question 1.

located somewhere other than the control room or b) Clinton Power Station revised the location of alternate shutdown panel, the Primary display near the Remote (alternate) please describe the Shutdown Panel as shown on the enclosed evaluation used to validate revised Sketch #1 NRC RAI Question 1 due to that the display location can constructability issues. This revised location is be accessed without as close to the Main Control Room as the unreasonable delay original location described in Reference 11 following a BOB event. (Fourth Six Month Update). The time to access Include the time available the display is approximately eight (8) minutes.

for personnel to access the The Primary display is still within the Remote display as credited in the Shutdown Panel area and environmental evaluation, as well as the conditions remain as previously described. No actual time (e.g., based on changes to the location of the Backup channel walk-throughs) that it will display were made.

take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-1 2-051 July 15, 2015 Page 9 ISE Item 6 (RAI- 12, Ref. 5)

Complete Please provide a list of the I Normal/Inspection procedure to monitor the procedures addressing Spent Fuel Pool level is implemented in operation (both normal and accordance with Operations Procedure OP-AA-abnormal response), 102-102 "General Area Checks and Operator calibration, test, maintenance, Field Rounds" and readings are noted by using and inspection procedures that a "Hand Held Electronic Data Device" with will be developed for use of predefined acceptance criteria.

the SFP instrumentation. The licensee is requested to Abnormal procedures are implemented when include a brief description of an out of the predefined values condition is the specific technical observed as a result of performing the OP-AA-objectives to be achieved 102-102, or on the receipt of annunciator 5040-within each procedure. 2F, described in procedure 5040.02 "Low Level Spent Fuel Storage Pool", and initiates, if required, CPS 4011.02 "Spent Fuel Pool Abnormal Water Level Decrease."

Calibration/Testing procedures 9577.01 "Spent Fuel Pool Level Indication Primary 1 LT-FC221 A / Backup 1 LT-FC221 B Channel Functional Test," and 9477.01 A(01 B) "Spent Fuel Pool Level Primary 1 LT-FC221A (Backup 1 LT-FC221 B) Channel Calibration" define the periodicity, functional testing and loop calibrations for the Spent Fuel Pool Level Indication system.

Maintenance procedures consist of a series of Preventative Maintenance activities in accordance with ER-AA-200 "Preventive Maintenance Program" which define the periodicity for calibration, battery replacement, electronic component replacements, probe replacement, transmitter replacement, sensor probe inspection, and coax cable replacement.

MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Submit Responses to RAIs July 5, 2013 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 August 28, 2014 Provide Final Safety Evaluation (SE) Information September 30, 2014

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 July 15, 2015 Page 10 Milestone Completion Date Update 4 February 27, 2015 Modifications:

Conceptual Design 302012 Issue Exelon Fleet contract to procure SFPI 202013 Equipment Begin Detailed Design Engineering 402013 Complete and Issue SFPI Modification Package 2Q2015 Begin Installation 4Q2014 Complete SFPI Installation and Put Into Service May 15, 2015 ORDER EA-1 2-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Clinton Power 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 051.

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

INSTRUMENT DESIGN FEATURES - COMPLETE The design of the instruments installed at Clinton Power 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 Clinton Power Station, Unit 1, has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-1 2-051 July 15, 2015 Page 11 Operating and maintenance procedures for Clinton Power 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 150' day of July 2015.

Respectfully submitted,

,,A Z/&'U,'

Glen T. Kaegi Director Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

Clinton Power Station SFPI Figures:

CPS Revised Sketch #1 (one page) Transmitter and Electronic Enclosure Layout CPS Revised Sketch #2 (two pages) Depiction of Pool Sensor Locations and Cable Routing cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator Region Ill NRC Senior Resident Inspector Clinton Power Station, Unit 1 NRC Project Manager, NRA Clinton Power Station, Unit 1 Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRC Ms. Jessica A. Kratchman, NRR/JLD/JPSB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency Division of Nuclear Safety

Enclosure Clinton Power Station SFPI Figures CPS Revised Sketch #1 (one page) - Transmitter and Electronic Enclosure Layout CPS Revised Sketch #2 (two pages) -Depiction of Pool Sensor Locations and Cable Routing

CPS Revised Sketch #1 (one page)

Transmitter and Electronic Enclosure Layout CPS REVISED SKETCH #1 (one page) 9 0

0 AUXILIARY BUILDING EL 762'-0 AREAS Page 1 of 1

CPS REVISED SKETCH #2 (two pages)

Depiction of Pool Sensor Locations and Cable Routing Primary Sensor 1/2" Spent Fuel Pool I 32'2" N>

Backup Sensor 36'O" Primary conduit is routed inside a robust cable tray for missile protection

-6' Changes made in this section of primary channel conduit run are shown in the sectional view, in next page Page 1 of 2

SECTIONAL VIEW OF CONDUIT RUNS FROM COLUMN TO CABLE TRAYS 4O '

/

Ii

-I' Column providing protection to 0 Page 2 of 2