RS-13-122, 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)

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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)
ML13241A037
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/28/2013
From: Jim Barstow
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, RS-13-122
Download: ML13241A037 (13)
v • d • e


Text

1 Exelon Generation Order No. EA-12-051 RS-13-122 August 28, 2013 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

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)

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. 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 2012
4. Exelon Generation Company, LLC's Initial 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 October 25,2012
5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2013 (RS-13-032)

On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to install reliable spent fuel pool level instrumentation. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28,2013 Page 2 the EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Limerick Generating 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. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the reqUirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

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 2013.

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-051 , Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 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 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Robert J. Fretz, Jr, NRR/JLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, 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

u.s. Nuclear Regulatory Commission Integrated Plan Report to EA-12-0S1 August 28, 2013 Page 3 bcc: Site Vice President - Limerick Generating Station, Units 1 and 2 Vice President Operations Support Plant Manager, Limerick Generating Station, Units 1 and 2 Site Engineering Director - Limerick Generating Station, Units 1 and 2 Regulatory Affairs Manager Regulatory Assurance Manager - Limerick Generating Station, Units 1 and 2 Severe Accident Management Director Site Operations Director - Limerick Generating Station, Units 1 and 2 Corporate licensing Manager - East Corporate licensing Director - East Exelon Records Management Vinod Aggarwal Roger Schiavoni Sailaja Mokkapati Abiola Olayiwola PA DEP BRP Inspector - LGS

Enclosure Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (9 pages)

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Limerick Generating 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 Overall Integrated Plan 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 Overall Integrated Plan (Reference 1), and are current as of August 19, 2013.

  • Submitted responses to USNRC RAls (Ref. 3 and 4) on July 18, 2013 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 Completion Activity Target Milestone 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 19, 2013 Complete Submit 6 Month Updates:

Complete with Update 1 August 28, 2013 this submittal Update 2 February 28, 2014 Not Started Page 1 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28,2013 Revised Target Completion Activity Target Milestone Date Status Completion Date Update 3 August 28, 2014 Not Started Update 4 February 28, 2015 Not Started Update 5 August28,2015 Not Started Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 102015 Complete procure SFPI Equipment Begin Detailed Engineering 302013 Not Started Design Complete and Issue SFPI 402013 Not Started 202014 Modification Package Begin Installation 102015 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 Limerick Generating Station, Units 1 and 2 expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Items 01# Description Status 1 Instruments Complete.

(Ref.1 ) Continuous level indication will be The Westinghouse Spent Fuel Pool Page 2 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28, 2013 provided by a guided wave radar Level Indication instrumentation was system, submersible pressure selected consistent with the guidelines of transducer, or other appropriate level NRC JLD-ISG-2012-03 and NEI 12-02.

sensing technology that will be The instrument is a guided wave radar determined during the detailed system. It provides the capability to engineering phase of the project. reliably monitor the spent fuel pool water level under normal and anticipated adverse environmental conditions.

The sensor input to the system is a guided wave radar probe. Using the principle of time domain reflectometry (TDR) to detect the SFP water level, microwave signals are pulsed down the cable probe and reflected back from the water surface. This is used to determine the level of the water in the pool.

Each water level measurement channel includes a flexible stainless-steel sensor cable probe suspended in the spent fuel pool from a seismic Category 1 bracket attached to the operating deck or to a raised curb at the side of the pool. The cable probe extends to just above the top of the spent fuel racks. The sensor electronics are mounted in seismic and missile protected areas outside of the building housing the SFP to minimize exposure to elevated radiation and environmental conditions which could result from a postulated loss of water inventory in the pool. There is an interconnecting cable between the sensor cable probe and sensor electronics.

The sensor electronics provide an instrument standard analog signal to a remote enclosure that will be installed in an accessible location. This enclosure contains the Uninterruptable Power Supply (UPS), backup battery, and water level display. The enclosure also includes the capability to connect an Page 3 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August 28, 2013 emergency or temporary external power source as part of the FLEX mitigating strategies.

Attachment 1 shows the components and arrangement of the guided wave radar system spent fuel pool level sensor and electronics enclosure for one channel.

2 Final sensor locations and cable Not Started.

routings are not available at this time.

(RAI-2, This information will be developed Ref.4) during the detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

3 Mounting device total loading and Not Started.

attachments are not available at this (RAI-3, time. This information will be developed Ref.4) during the detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

4 Equipment reliability qualification Not Started.

information is not available at this time.

(RAI-4, This information will be developed Ref.4) during the detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to beain the Page 4 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

5 Channel independence information is Not Started.

not available at this time. This (RAI-5, information will be developed during the Ref.4) detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

6 Equipment total power supply Not Started.

configuration and characteristics are not (RAI-6, available at this time. This information Ref.4) will be developed during the detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100% acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

? Channel accuracy information is not Not Started.

available at this time. This information (RAI-?,

will be developed during the detailed Ref.4) design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design Page 5 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 completion and 100% acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

a Equipment testing, calibration, Not Started.

functional checks and maintenance (RAI-a, requirements are not available at this Ref.4) time. This information will be established during process and procedure development following the detailed design phase. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. Following the issue of the design and prior to operation acceptance, procedures will start being developed with a projected March 2015 completion date. The requested information will be developed early in the process and will be provided in the August 2014, 6-month Integrated Plan update.

9 Channel display location information is Not Started.

not available at this time. This (RAI-9, information will be developed during the Ref.4) detailed design process. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

10 Procedural details are not available at Not Started.

this time. This information will be (RAI-10, established during process and Page 6 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 Ref.4) procedure development following the detailed design phase. The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. Following the issue of the design and prior to operation acceptance, procedures will start being developed with a projected March 2015 completion date. The requested information will be developed early in the process and will be provided in the August 2014, 6-month Integrated Plan update.

11 Testing and calibration program Not Started.

requirements and compensatory actions (RAI-11, are not available at this time. This Ref.4) information will be established during process and procedure development following the detailed design phase.

The current plan for the SFPI design of the system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%

acceptance of the design in May of 2014. Following the issue of the design and prior to operation acceptance, procedures will start being developed with a projected March 2015 completion date. The requested information will be developed early in the process and will be provided in the August 2014, 6-month Integrated Plan update.

Page 7 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 Draft Safety Evaluation Open Items 01# Description Status None at this time.

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 Generating 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 032).
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 June 24, 2013.
4. Exelon Generating 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 18, 2013, (RS-13-177).

Page 8 of9

Limerick Generating Station, Units 1 and 2 First Six-Month Status Report for the Implementation of SFP LI August28,2013 Attachment 1 Spent Fuel Pool Instrumentation System Sensor Electronics Fr:;;;;~;;=ll Remote Enclosure containing I[4O]J I sensor UPS Output to Interconnecting Cable optional 1201240 alternate VAC Power display 20-30' (typical) measurement span to just above top of ..../1 40.0 1/

fuel racks 6 mm SST Cable Probe with Anchor Weight Spent Fuel Pool Page 9 of9

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