RS-13-027, 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)
| ML13059A265 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/28/2013 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-13-027 | |
| Download: ML13059A265 (12) | |
Text
Exelon Generation Order No. EA-12-051 RS-13-027 February 28, 2013 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:
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)
References:
- 1. NRC Order Number EA-12-051, "Issuanceof 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. NEI12-02, 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 24, 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 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC) . Reference 1 was immediately effective and directs EGC to have a reliable indication of the water level in associated spent fuel storage pools. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 3 provides direction regarding the content of this Overall Integrated Plan* The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section IV, Condition C.1 , of Reference 1. This letter confirms EGC has received Reference 2 and has an Overall Integrated Plan complying with the guidance for the purpose of ensuring a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of required wide range pool water level conditions by trained personnel.
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Integrated Integrated PlanPlan Report Report to to EA-12-051 EA-12-051 February February 28, 2013 28, 2013 Page Page 22 Reference Reference 44 provided provided the the EGC EGC initial initial status report regarding status report regarding reliable reliable spent spent fuel fuel pool pool instrumentation, instrumentation, as required by as required by Reference Reference 1. 1.
Reference Reference 3, 3, Appendix Appendix A-2 A-2 contains contains the the specific specific reporting reporting requirements requirementsfor forthe theOverall OverallIntegrated Integrated Plan. Theinformation Plan. The information in in the the enclosure enclosureprovides providesthetheBraidwood BraidwoodStation,Station,Units Units11andand22Overall Overall Integrated Integrated Plan Plan pursuant pursuant to to Appendix Appendix A-2 A-2ofofReference Reference3.3. The The enclosed Integrated Plan enclosed Integrated Plan isis based based on on conceptual conceptual design information. Final design information. Final design design details details andand associated procedure guidance, associated procedure guidance, as as well as well any revisions as any revisions toto the the information information contained contained in in the theEnclosure, Enclosure,will will be beprovided provided inin the the 6-month 6-month Integrated Integrated Plan Plan updates required by updates required by Reference Reference 1. 1.
This This letter letter contains contains no new regulatory no new regulatory commitments.
commitments. If If you you have any questions have any questions regarding regarding this this
- report, report, please contact David please contact David P. P. Helker Helker at at 610-765-5525.
610-765-5525.
II declare under penalty declare under penalty of of perjury perjury that that the the foregoing foregoing is is true true and and correct. Executed on correct. Executed onthe the281' 28th day day of of February 2013.
February 2013.
Respectfully submitted,
~<!.7¥ Glen T. Kaegi Director - Licensing & & Regulatory Regulatory Affairs Affairs Exelon Generation Company, Company, LLC LLC
Enclosure:
- 1. Braidwood Braidwood Station, Station, Units Units 11 and and 22 Reliable Reliable Spent Spent Fuel FuelPool PoolInstrumentation Instrumentation(SFPI)
(SFPI)Overall Overall Integrated Plan Integrated Plan cc: Director, Office of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region Region IIIIII NRC NRC Senior Senior Resident Inspector -- Braidwood Resident Inspector Braidwood Station, Station, UnitsUnits 11 and and 22 NRC NRC Project Project Manager, Manager, NRR NRR -- Braidwood Braidwood Station, Units 1 Station, Units 1 and and 22 Mr.
Mr. Robert J. Fretz, Robert J. Fretz, Jr,Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert L. Dennig, NRRIDSS/SCVB, Mr. NRRIDSS/SCVB, NRC NRC Illinois IllinoisEmergency Emergency Management Management Agency Agency -- Division Division of of Nuclear Nuclear Safety Safety
Enclosure 1 Braidwood Station, Units Units 11 and and 22 Reliable Spent Spent Fuel Fuel Pool PoolInstrumentation Instrumentation(SFPI)
(SFPI)
Overall Integrated Plan Overall Integrated Plan (9
(9 pages) pages)
Braidwood Station, Braidwood Station, Unit Unit 1 1 and and 22 Reliable Spent Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Overall Integrated Plan Plan Applicability:
Appl icabi Iity:
This This integrated integrated plan plan applies applies to Braidwood Station, to Braidwood Station, Units Units 11 and and 22 and is based and is based on on current current conceptual conceptual design information and design information and will willbe revised as be revised as detailed detailed design design engineering engineering proceeds.
proceeds. Consistent Consistent with with the requirements of the requirements Order EA-12-051 of Order EA-12-051 (Ref.1)
(Ref.1) and the and the guidance guidance in in NEI NEI 12-02 12-02 (Ref.3),
(Ref.3), Exelon's six-month reports Exelon's six-month will delineate reports will delineate progress progress made,made, any any proposed changes in proposed changes in compliance compliance methods, methods, updates updates to to the the schedule schedule and, and, ifif needed, needed, requests requests for for relief relief and and the basis.
the basis.
General
Description:
Braidwood Braidwood StationStation isis aa two two unit unitPressurized Pressurized Water Water Reactor Reactor Station. The two Station. The two units units share share a single Spent a single Spent FuelFuel Pool Pool (SFP)
(SFP) located locatedininthe theFuel FuelHandling Handling Building Building (FHB).
(FHB). Normal Normal SFP water level SFP water level isis approximately approximately El. EI. 424'-6".
424'-6". Top Topof of the thespent spentfuelfuelrack rackisisEl.
EI.400'-13W 400'-1 3fit and top of and top of active active fuel fuel is is approximately approximately El. EI. 400'-0".
400'-0".
Note: The Note: The elevations' elevations' reference reference mark mark tolerances tolerances are are +/- 1/2".
1/2".
Schedule:
The installation of The installation of reliable reliable level level instrumentation instrumentationfor forthe the SFP SFP associated with Unit associated with Unit 1 1 and and Unit Unit 22 is is scheduled scheduled for for completion completion by bythe the end end ofof A 1R18 Al R18 (Spring (Spring2015) 2015)based based onon the end the end of of the second refueling the second refueling outage outageforfor Unit Unit 11 following following submittal submittal of of this this integrated plan. This integrated plan. This is the is earlier outage the earlier outage sequence sequenceof ofthe theunits unitsdischarging dischargingto tothe thepool.
pool.
The current milestone milestone schedule schedule isis as as follows:
follows:
- Complete Conceptual Design Design (CD)(CD) for for Pilot PilotPlant Plant(Limerick)
(Limerick) Complete
- Complete CD Follow-up Walkdowns at Remaining Remaining 9 Exelon Exelon Sites Sites Complete
- Submit Initial 60-day 60-day Status Status Report Report Complete
- Develop Request for Proposal Proposal for for Detailed Detailed Engineering Engineering Complete Design Services
- Submit Integrated Submit Integrated Plan Plan Complete with Complete with this this submittal submittal
- Begin Detailed Engineering Engineering Design Design 3Q2013 302013 11
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool PoolInstrumentation Instrumentation Overall Integrated Integrated Plan Plan
- Complete and Issue Issue SFPI SFPI Modification Modification PackagePackage 4Q2013 402013
- Begin SFPI SFPI Installation Installation Q2015 1102015
- Complete SFPI Installation and SFPllnstallation and PutPut Into Into Service Service 2Q2015 202015 Identification of Identification of Spent Spent Fuel Fuel Pool Pool Water WaterLevels:
Levels:
Key spent Key fuel pool spent fuel pool water waterlevels levelswill will be beidentified identifiedas asfollows:
follows:
Level adequate Level adequate to to support support operation operation of of the the normal normal fuel fuelpool poolcooling coolingsystemsystem (Level (Level 1): Indicated Indicated level level on on either either primary primary or or backup backup instrument instrument channel channel of ofgreater greater than 18 18 feet feet (elevation (elevation 418'-13/4") above the 418'-1 3M.") above the top top of the storage storage racksracks based based on on the the design accuracy of the the instrument instrument channel channel (which(which will will be be determined determined ininthe thedetailed detailed design design phase) phase) and and a resolution resolution of 11 foot foot ororbetter betterofofboth boththetheprimary primaryand andbackup backup channels. This instrument channels. This is is based based on on Spent Spent FuelFuelPoolPoolCooling CoolingPump Pumpsuction suction strainer elevation. A calculation calculation demonstrating demonstrating adequate adequate water water level level willwill bebe performed performed as as part of the the detailed detailed engineering engineering design design phase phase to to ensure ensure the the level levelisis adequate for normal fuel fuel pool pool cooling cooling system systemoperation.
operation.
Level adequate to provide substantial Level substantial radiation radiation shielding shielding for for aa person person standing standing on the spent on spent fuel fuel pool pooloperating operating deck deck(Level (Level 2): 2): Indicated Indicated level level onon either the primary primary or backup instrument or backup instrument channel channel of ofgreater greaterthan than1010 feet feet (elevation (elevation 410' -1 3A")
410'-1314")
plus instrument channel plus instrument channel accuracy(which accuracy(which will will determined determined in in thethe detailed detailed designdesign phase) above the top phase) above top of of the the storage storage racksracks based basedon onspecification specification of of this this level level as adequate adequate in in NRC NRC JLD-ISG-2012-03 JLO-ISG-2012-03 (Ref. (Ref. 2) and NEI
- 2) and NEI 12-02 12-02 (Ref.
(Ref. 3), 3), the the specified specified design accuracy of design accuracy of the the instrument instrument channel, channel, and andthetherelatively relativelylow low sensitivity sensitivity of of dose dose rates to changes rates to changes in in water water depth depth at at this this level.
level. This Thismonitoring monitoring levellevel ensures ensures there thereisis an adequate water an adequate water levellevel totoprovide provide substantial substantial radiation radiation shielding shielding for for aa person person standing standing on the spent on the spent fuelfuel pool pool operating operating deck deckfrom from direct direct gamma gammaradiation radiation from from stored spent fuel.
stored spent fuel.
Level where Level where fuel fuel remains covered covered (Level(Level 3): 3): Indicated Indicated level level on either the primary primary or backup instrument or backup instrument channel channel of of greater greater than than0 0feet feet (elevation400'-13/4")
(elevation 400' -1 3A") plusplus instrument instrumentchannelchannelaccuracy accuracyabove abovethe thetoptop ofof the the storage storage racks racks basedbased upon upon the the design design accuracy accuracy (which (whichwill determinedininthe willdetermined the detailed detailed design design phase)phase) of the of the instrument channel for both the primary and backup instrument channels. This instrument channel for both the primary and backup instrument channels. This monitoring monitoringlevel levelassures assures thatthat water water is is covering covering the the stored stored fuel fuel seated seated in in the the rack.
rack.
2
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool PoolInstrumentation Instrumentation Overall Integrated Overall Integrated Plan Plan Instruments:
The design The design of of the theinstruments instrumentswill will be beconsistent consistentwith with the theguidelines guidelinesofofNRC NRCJLD-ISG-JLD-ISG*
2012-03 (Ref. 2) and NEI 12-02 (Ref. 3). Specifically, the channels will be designed as 2012-03 (Ref. 2) and NEI 12-02 (Ref. 3). Specifically, the channels will be designed as discussed below:
discussed below:
Primary (fixed) instrument Primary (fixed) instrument channel:
channel: The The primary primary instrument instrument channel level sensing channel level sensing components will components will bebe located located andand permanently permanently mountedmounted in in the the Spent Spent FuelFuel Pool. The Pool. The primary instrument primary instrument channelchannel willwill provide provide continuous continuous level level indication indication over over aaminimum minimum range range of of approximately approximately 24 24 feet feet 88 inches inches from from thethehigh highpool poollevel level elevation elevationofof424'-9 424'-9 Y2" totothe 1/8" thetoptopofofthe the spent spent fuel racks at fuel racks at elevation elevation 400'-1 400'*1 3/4".3A". ThisThis continuous continuous level level indication indication willwillbe beprovided providedby byaa guided guided wavewave radar system, submersible radar system, submersible pressure pressure transducer, or transducer, or other other appropriate appropriate level level sensing sensing technology technology that that willwill be be determined determined during the during the detailed engineering design detailed engineering design phase phaseof of the the project.
project.
Backup Backup instrument instrument channel: channel: The The backup backup instrument instrument channel channel levellevel sensing sensing components components will will also also bebe located located and and permanently permanently mounted mounted in in the Spent Fuel the Spent Fuel Pool.
Pool.
The backup instrument The backup instrument channel channel will will provide provide continuous continuous level level indication indication over over aa minimum minimum range range of of approximately approximately 24 24 feet feet 8 inches from 8 inches from the the high high poolpool level level elevation elevation of 424'- 9 of 424'- 9 '/" tothe 1;2" to thetoptopofofthethespentspentfuelfuelracks racksat at elevation400'-
elevation 400'-1 3/a".
1 3A". This This continuous continuous level level indication indication willwillbebeprovided providedby bythe thesame same levellevel sensing technology as sensing technology as the primary instrument the primary instrument channel.
channel.
Reliability:
Reliability:
Reliability of of the the primary primary and and backup backup instrument instrument channels channels will will bebe assured assured by by conformance with conformance with the guidelines guidelines of (Ref.
of NRC JLD-ISG-2012-03 (Ref. 2) and NEI 12-02 NRC JLD-ISG-2012-03 2) and NEI 12-02 (Ref.3) as discussed (Ref.3) discussedbelow belowunder underDesign DesignFeatures Featuresand andProgram ProgramFeatures. Features. Both primary Both primary and backup level instrumentation and instrumentation channels will will be functional functional at all all times, times, when when there thereisis fuel in fuel in the the SFP with allowances for with allowances for testing, maintenance maintenanceor or repair repair per per NEI NEI 12-02 12-02 (Ref.3).
(Ref.3).
Reliability will be be established established through through the the useuse of ofan anaugmented augmentedquality quality assurance assurance process (e.g.,
process (e.g.,aaprocess processsimilar similartotothat thatapplied appliedtotothe thesite sitefire fireprotection protectionprogram).
program).
Design Features Design Features Instrument Channel Design: Instrument channel Design: Instrument channel designdesign will be consistent with the guidance of NRC JLD-ISG-2012-03 (Ref. 2) and NEI 12-02 (Ref. 3).
3
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool PoolInstrumentation Instrumentation Overall Overall IntegratedIntegrated Plan Plan Arrangement:
Arrangement: The current plan is to install install SFP level sensors SFP level sensors in in the the southwest southwest and and northwest corners northwest cornersofofthe theSFP SFP separated separated by by aa distance distance in in excess excess of of 20 feet. The 20 feet. The sensors themselves sensors themselveswill will bebe mounted, mounted, to to the the extent extentpractical, practical, nearnearthe thepool poolwalls walls and and below the below pool curb the pool curb toto minimize minimize theirtheir exposure exposure to to damaging damaging debris debris and and not notinterfere interfere with SFP with activities. Instrument SFP activities. Instrument channel channel electronics electronics and and power power supplies supplies will will be be located in located in seismic seismic and missile protected and missile protected areas areas either either atat an anelevation elevation below below the the SFP SFP operating floor operating floororor inin buildings buildingsother otherthanthanthethe FHB.
FHB. The The areas areas to to bebeselected selectedwill will provide suitable radiation shielding and environmental conditions for the equipment provide suitable radiation shielding and environmental conditions for the equipment consistent with consistent with instrument instrument manufacturer's recommendations. Equipment manufacturer's recommendations. Equipmentand andcabling cabling for power for power supplies indication for supplies and indication for each channel will each channel will be separated equivalent be separated equivalent to to that provided for that provided for redundant redundant safetysafety related services.
related services.
Mounting: Design Mounting: Design of of the mounting of the mounting of the the sensors sensors in in the the SFPSFP shallshall bebe consistent consistent with the with the seismic Class II criteria.
seismic Class criteria. Installed Installedequipment equipmentwill will be beverified verified to to be beseismically seismically adequate for adequate for the the seismic seismic motions motions associated associatedwith with the themaximum maximumseismic seismicgroundground motion motion considered considered in in the design of the design of the the plant plant area areaininwhich which itit is is installed.
installed.
Qualification: Reliability Qualification: Reliabilityofofboth both instrument instrument channels channels willwill be be demonstrated demonstrated via via an an appropriate combination of appropriate combination of design, analyses, operating design, analyses, operating experience, experience, and/or and/ortesting testingof of channel components for channel components for the the following following sets sets ofof parameters:
parameters:
- conditions inin the conditions the area area of of instrument instrument channel channel component component use use for for all all instrument components,
- effects effects of shock and of shock and vibration vibration on on instrument instrument channel channel components components used used during during and following any and following any applicable applicable event, event, and and
- seismic instrument channel seismic effects on instrument channel components componentsused usedduringduringand andfollowing following a
a potential potential seismic event.
seismic event.
Temperature, Temperature, humidity humidity and radiation levels and radiation consistent with levels consistent with the conditions conditions in in the the vicinity vicinityofofthe theSFP SFPand and the the area area ofof use considering normal use considering normal operation, operation, event event and post--
and post event conditions for event conditions for no no fewer fewer than seven days than seven dayspost-event postMeventororuntil untiloff-site offMsite resources resources can can be be deployed deployed by bythe themitigating mitigating strategies strategiesresulting resultingfrom fromOrder EAM12M049(Ref.4),
OrderEA-12-049 (Ref.4),
will willbe be addressed addressed in in the the detailed detailed design engineering phase design engineering phase of of the the project.
project. Examples Examples of postMevent of post-event (beyondMdesign-basis)
(beyond-design-basis) conditions conditions to to be considered are:
be considered are:
- radiological conditions radiological conditions for for a normal normal refueling refueling quantity quantity of of freshly freshlydischarged discharged (100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />) fuel with SFP water water level level 33 asas described describedininOrder OrderEA-12-051, EA-12-051, 4
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan
- temperature of 212 degrees degrees FF andand 100%
100% relative relative humidity humidity environment, environment,
- boiling water and/or and/or steam steam environment, environment,
- aa concentrated concentrated borated borated water water environment, environment, and and
strategies.
Components of Components of the the instrument instrument channels channels will will bebe qualified qualified forfor shock shockand andvibration vibration using one using one oror more moreof ofthe thefollowing following methods:
methods:
- components are components supplied by are supplied by manufacturers manufacturers using using commercial commercial quality quality programs programs (such (such as as 1509001, 1809001, "Quality "Quality management management systems systems -
Requirements")
Requirements") with with shock shock and and vibration vibration requirements requirements includedincluded in in the the purchase specification at purchase specification levels commensurate at levels commensurate with with portable portable hand-held hand-held devices or devices or transportation transportation applications; applications;
- components components have havesubstantial substantialhistory historyofofoperational operationalreliability reliability inin environments environments with with significant significant shock shock and vibration loadings, and vibration loadings, such such as as portable portable hand-held hand-held devices devices oror transportation transportation applications; applications; or or
- components components are are inherently inherently resistant resistant to to shock shock andand vibration vibration loadings, loadings, suchsuch asas cables.
cables.
For For seismic seismic effects effects on on instrument instrument channel channel components components used used after after aa potential potential seismic seismic event event for for only only installed installed components components (with (with the exception of the exception battery chargers of battery chargers and and replaceable batteries), the replaceable batteries), the following following measures measures will will be used to be used to verify verify that that the the design design and installation is and installation is adequate. Applicable components adequate. Applicable components are are rated rated bybythethemanufacturer manufacturer (or otherwise tested)
(or otherwise tested) for for seismic seismic effects effects at at levels levels commensurate commensurate with those ofof with those postulated postulated design design basis event conditions basis event conditions in the area in the areaofofinstrument instrument channel channel component component use use using using oneoneor ormore moreof ofthe thefollowing following methods:
methods:
- instrument instrument channel channel components components use known operating use known operating principles principles and are and are supplied supplied by manufacturers with by manufacturers with commercial commercial qualityquality programs programs (such (such as as 1809001).
IS09001), The Theprocurement procurementspecification specification and/or and/or instrument instrument channel channel design design shall shall include include the seismic requirements the seismic requirements and and specify specify the the need needfor for commercial commercial design design andand testing testing under under seismic seismic loadings loadings consistent consistent with with design design basis basis values values atat the the installed installed locations; locations; 55
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool PoolInstrumentation Instrumentation Overall Overall Integrated Integrated Plan Plan
- history of substantial history of operational operationalreliability reliability inin environments environmentswith with significant significant vibration, such vibration, such as asfor forportable portablehand-held hand-helddevices devicesoror transportation transportation applications. Such applications. Such aa vibration vibration design design envelope envelope shall shall bebe inclusive inclusive of of the the effects of effects seismic motion of seismic motion imparted imparted to to the components proposed the components proposed at the at the location of location of the proposed installation; the proposed installation;
- adequacy of seismic adequacy seismic design design and installation installation is is demonstrated demonstrated based based on the the guidance in guidance in Sections Sections 7, 7, 8,8, 9,9,and and1010ofofIEEE IEEEStandard Standard344-2004, 344-2004,"IEEE "IEEE Recommended Practice Recommended Practicefor forSeismic SeismicQualification Qualification of of Class Class1 1EEEquipment Equipmentfor for Nuclear Power Generating Nuclear Power Generating Stations",
Stations", or or aasubstantially substantiallysimilar similarindustrial industrial standard; standard;
- demonstration that demonstration proposed devices are that proposed are substantially substantially similar similar in in design design to to models models that been previously that have been previously tested tested forfor seismic seismic effects effects inin excess excessof of the the plant plant design basis at design basis at the the location location where where the the instrument instrument is is to to be be installed installed (g-(g-levels levels and frequency ranges);
and frequency ranges); or or
- seismic qualification seismic qualification using using seismic motion consistent seismic motion consistent with with that that of of existing existing design basis design basisloading loading atatthetheinstallation installationlocation.
location.
Independence: The primary instrument channel will Independence: will be be independent of of the the backup backup instrument channel. This instrument channel. independence will This independence will be achieved through be achieved through physical physical and and electrical electrical separation separation of of each components commensurate each channels' components commensurate with with hazard hazard andand electrical electrical isolation isolation needs.
needs.
Power Supplies:
Power Supplies: Each Each channel will will be normally normally powered powered from from aa different different 120Vac 120Vac bus.
bus. Upon loss of Upon loss of normal normal ac acpower, power,individual individual channel channelinstalled installedbatteries batterieswill will automatically automatically maintainmaintain continuous continuous channel channel operation.
operation. The batteries will The batteries will bebe replaceable replaceable and and bebe sized sizedtotomaintain maintainchannelchanneloperation operationuntiluntil off-site off-site resources resources can can be deployed by be deployed by the themitigating mitigating strategies strategiesresulting resultingfrom fromOrder OrderEA-12-049(Ref.4).
EA-12-049(RefA).
Additionally, Additionally,each each channel channel will willhavehave provisions provisions for for connection connection to suitable to another suitable power power source.
source.
Accuracy: The Accuracy: instrument channels The instrument channels will will be designed to be designed to maintain maintain theirtheir design design accuracy accuracy following followingaa power power interruption interruption or change in or change in power power source sourcewithoutwithout recalibration.
recalibration. Instrument channel channel accuracy, to be be determined determined duringduring detailed design, will willconsider consider Spent Spent Fuel Fuel Pool Pool conditions conditions (e.g.,
(e.g., saturated water,water, steam steamenvironment, environment, concentrated concentrated borated borated water),
water), as well as, other other applicable radiological and applicable radiological and environmental environmental conditions conditions andand include include display display accuracy. Instrument channel accuracy. Instrument 6
Braidwood Braidwood Station, Station, Unit Unit 11 and and 22 Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan Plan accuracy will be accuracy sufficient will to be allow sufficient to allowpersonnel trained trained personnel to determine to determine when when the theactual actual level exceeds level exceeds the the specified specified lower lower level level ofof each each indicating indicating range range (levels (levels 1, 1, 22 or or3) 3)
without conflicting without conflicting or or ambiguous indications.
ambiguous indications.
Instrument channel Testing: Instrument channel design design will provide provide for for routine routine testing testing and andcalibration calibration consistent with the guidelines of of NRC NRC JLD-ISG-2012-03 JLD-ISG-2012-03 (Ref. (Ref. 2)2) and andNEI 12-02 (Ref.
NE112-02 (Ref.
3). Details will be determined during during detailed detailed design design engineering engineeringphase. phase.
Display:
Display: The The primary primary and and backup backup instrument instrument displays displays will will be be located located at atthe thecontrol control room, room, alternate alternate shutdown shutdown panel, panel, oror other other appropriate appropriateand and accessible accessible location.
location. The The specific location specific location will will be determined during be determined during detailed detailed design.
design. An An appropriate appropriate and and accessiblelocation accessible locationwillwill include include the the following following characteristics:
characteristics:
- occupied or occupied promptly accessible or promptly accessible to to the the appropriate appropriate plant plant staff staff giving giving appropriate consideration appropriate consideration to to various various drain drain down down scenarios, scenarios,
- outside outside the area surrounding the area surrounding the the SFP SFP floor floor (e.g., an appropriate (e.g., an appropriate distance distance from the from radiological sources the radiological resulting from sources resulting from an event impacting an event impacting the Spent the Spent Fuel Pool),
Fuel Pool),
- inside inside a structure providing a structure providing protection protection against against adverse weather, and adverse weather, and
- outside outside of of very very high high radiation radiation areas areasororLOCKED LOCKEDHIGH HIGHRAD RADAREA.AREA.
Program Features Program Features Training: Personnel Training: performing functions Personnel performing functionsassociated associated with with these Spent Fuel these Spent Fuel Pool Pool level level instrumentation instrumentation channels will be channels will be trained trained toto perform perform thethe job job specific specific functions functions necessary necessary for for their their assigned assigned tasks tasks (maintenance, calibration, calibration, surveillance, surveillance, etc.). This etc.). This training training will will be consistent with be consistent with equipment equipment vendorvendor guidelines, guidelines, instructions instructions and and recommendations.
recommendations. The Systematic Approach The Systematic Approach to Training (SAT) to Training (SAT) will willbebe used used toto identify identifythe the population populationtoto be trained and be trained and toto determine determine the theinitial initial andandcontinuing continuing elements elements of of the the required required training.
training. Training Training willwillbebe completed completed prior prior to placing the to placing the instrumentation instrumentation in in service.
service.
Procedures: Procedures Procedures: Procedures will will be be developed developed usingusing guidelines guidelines andand vendor vendor instructions instructions to address the to address the maintenance, maintenance, operation operation and and abnormal abnormal response response issuesissues associated associated with with the the primary primaryand and backup backup channels channels of of Spent Spent Fuel Fuel Pool Pool instrumentation.
instrumentation.
Procedures will will also address the following situations:
situations:
7
Braidwood Station, Braidwood Station, Unit Unit 11 and and 22 Reliable Spent Reliable Spent Fuel Fuel Pool Pool Instrumentation Instrumentation Overall Integrated Plan Plan If, at the time of an
- eventIf, at theor time of an event until thereafter or thereafter the unit until is thereturned unit is returned to normal to normal service, an service, instrument channel an instrument channel ceases ceases to tofunction, function, its its function function will will bebe recovered recovered within within aa period period of of time time consistent consistent with with the the emergency emergencyconditions conditions that may that may exist exist at at the the time.
time.
- If, If, at the time at the time of of an an event eventor orthereafter thereafteruntil until the the unit unit isis returned returned totonormal normal service, an service, instrument channel an instrument channel component componentmust must be replaced, itit may be replaced, may be be replaced replaced with with aa commercially commercially available available component component that that mayor may or may may not meet not meet all all of the qualifications of the qualifications noted noted above above totomaintain maintain instrument instrument channel channel functionality.
functionality.
Testing and Testing and Calibration:
Calibration: The testing and The testing and calibration calibration ofof the the instrumentation instrumentation will will be be consistent consistent with with vendor vendor recommendations recommendations or or other other documented documentedbasis. basis.Calibration Calibrationwillwill be specific to be specific to the the mounted mounted instruments instruments and and the thedisplays.
displays. Calibration will be Calibration will be performed performed to to an Instrument Maintenance an Instrument Maintenance Procedure (BIP/BISR series).
Procedure (BIP/BISR series). AA Passport Passport PMIO PMID will willbe beused used to direct frequency to direct frequency for for performance performance of of the the instrument instrumentcalibration.
calibration.
Both Both primary primary and backup instrumentation and backup instrumentation channelschannels willwill bebe functional functional at at all all times times when when there there is is fuel fuel inin the the SFP SFP withwith allowance allowance for for testing, testing, maintenance maintenance or or repair repair per per NEI NEI 12-02(Ref.3),.
12-02(Ref.3),.
Need for Need for Relief Relief and and Basis:
Basis: Exelon Exelon is not requesting is not requesting relief relief from from the the requirements requirements of of Order EA-12-051 or Order EA-12-051 or the guidance in the guidance in NRC NRC IJD-ISG-2012-03 IJO-ISG-2012-03 at at this this time.
time.
Consistent Consistent with with the requirements of the requirements of Order OrderEA-12-051(Ref.1),
EA-12-051 (Ref.1), and and thetheguidance guidanceininNEI NEI 12-02(Ref.3),
12-02(Ref.3), Exelon's Exelon's six-month six-monthreportsreports will willdelineate delineateprogress progress made, made, anyany proposed proposed changes changes in in compliance compliance methods, methods, updates updates to to the the schedule, schedule, and and ifif needed, needed, requests requestsfor for relief relief and and their their basis.
basis.
References:
1.
- 1. NRC NRC Order Order Number Number EA-12-051, EA-12-051, Order Order Modifying Modifying Licenses Licenses with with Regard Regard toto Reliable Reliable Spent Spent Fuel Fuel PoolPool Instrumentation, Instrumentation, dated dated March March 12,12, 2012 2012 2.
- 2. NRC Interim Staff NRC Interim Guidance JLD-ISG-2012-03, Staff Guidance JLO-ISG-2012-03, Compliance Compliance with with Order Order EA-12-051, EA-12-051, Order Modifying Licenses Order Modifying Licenses withwith Regard Regard to to Reliable Reliable Spent Spent FuelFuel PoolPool Instrumentation, Instrumentation, Revision 0, Revision 0, dated August 29, dated August 2012 29, 2012 3.
- 3. NEI 12-02, Industry NEI 12-02, Industry Guidance Guidance for for Compliance Compliance with with NRCNRC OrderOrder EA-12-051, EA-12-051, "To "To Modify Modify LicensesLicenses with with Regard Regard to to Reliable Reliable Spent SpentFuel FuelPool PoolInstrumentation",
Instrumentation",
Revision Revision 1 1,, dated August 24, dated August 24, 2012 2012 8
Braidwood Braidwood Station,Station, UnitUnit 11 and and 22 Reliable Reliable Spent Spent FuelFuel Pool PoolInstrumentation Instrumentation Overall Integrated Integrated Plan Plan
- 4. NRC
- 4. NRC Order Order Number Number EA-12-049, EA-12-049, Order Order Modifying Modifying Licenses Licenses with Regard to with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events, Requirements for Mitigating Strategies for Beyond-Design-Basis External Events, dated March dated March 12, 12, 2012 2012 9