RS-13-159, Response to Request for Additional - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation
| ML13186A003 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/03/2013 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-13-159 | |
| Download: ML13186A003 (14) | |
Text
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Generatti Order Order No.No. EA-12-051 EA-12-051 RS-13-159 RS-13-159 July 3,2013 July 3, 2013 Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission ATTN: Document Control Control Desk Desk Washington, DC DC 20555-0001 20555-0001 Quad Cities Quad Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22 Renewed Facility Operating License Nos. DPR-29 DPR-29 and and DPR-30 DPR-30 NRC Docket Nos. 50-254 and 50-265 50-265 ResponsetotoRequest
Subject:
Response Request forAdditional for AdditionalInformation Information -- Overall Overall Integrated Plan in Response Response to Commission Order Order Modifying Modifying License Requirements Requirements for for Reliable Reliable Spent SpentFuel FuelPool Pool Instrumentation (Order (Order No.No. EA-12-051)
References:
Exelon Generation Company, LLC
- 1. Exelon Letter to LLC Letter to USNRC, USNRC, Overall OverallIntegrated Integrated PlanPlan inin Response
Response
to March 12, 2012 Commission Order Order Modifying Licenses with Modifying Licenses with Regard Regard to to Requirements for Reliable Spent Fuel for Fuel Pool Pool Instrumentation Instrumentation (Order(Order Number NumberEA-1 2-051), dated EA-12-051), dated February February 28,2013 (RS-13-035) 28, 2013 (RS-13-035)
- 2. NRCNRC Order Number EA-1 EA-12-051, 2-051, Issuance Issuance ofof Order Order toto Modify Modify Licenses with Regard Licenses with Regardto to Reliable Reliable Spent Fuel Pool Instrumentation, Instrumentation, dated dated March March 12, 12, 2012 2012
- 3. USNRC letter to Exelon GenerationGeneration Company, Company,LLC, LLC, Request Requestfor forAdditional Additional Information Information Regarding Overall Regarding Overall Integrated Plan for ReliableReliable Spent Fuel Fuel Pool Pool Instrumentation, Instrumentation, dated dated June 7, 2013 In In Reference Exelon Generation Reference 1, Exelon Generation Company, Company, LLC provided the LLC (EGC) provided the Quad Cities Nuclear Power Power Station, Station, Units Units 11 and and 2, 2, Overall Overall Integrated IntegratedPlan PlanininResponse Response to to the the March March 12, 12, 2012 2012 Commission Order Order Modifying Licenses with Modifying Licenses with Regard to Requirements for for Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation, pursuant Instrumentation, pursuant to to NRC Order Order No. 051 EA-12-051 EA (Reference 2).
purpose of The purpose of this letter is to provide the response responseto tothe theNRC NRCrequest requestfor foradditional additionalinformation information (Reference 3) regarding the Quad Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22Overall Overall Integrated Integrated Plan Plan in in Response Response to to the the Commission Commission Order OrderModifying Modifying Licenses with with Regard to Requirements Requirements for for Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation (Order (Order No.No. EA-12-051).
EA-12-051). Subsequent issuanceof Subsequent to issuance of Reference Reference 3, thethe NRC NRC identified identified that Request Requestfor for Additional Additional Information Information ItemItem No.
No. 6.a 6.a was also applicable applicable toto Quad Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 2. This item
- 2. This item is included and addressed addressed in in Enclosure Enclosure 11to to this this letter.
letter.
The Quad Cities Nuclear The Nuclear Power Power Station, Station, Units Units 11 and and 22 Spent Fuel Pool Instrumentation design is proceeding proceeding on the schedule schedule identified identified in in the Overall Integrated Plan Plan provided provided in in Reference Reference 1. 1.
The enclosed responses The responsestotothe theNRCNRCrequest requestfor foradditional additional information information are intended intended not not toto provide provide preliminaryor preliminary orconceptual conceptual information.
information. The requested requestedinformation, information, when when fully fully developed, developed, will will be
U.S. Nuclear U.S. Nuclear Regulatory Commission Response to Response to Request Request for Additional Information (Order (Order EA-1 2-051)
July 3,2013 July 3, 2013 Page 22 Page provided upon provided upon detailed detailed design design completion completion based based on on the the milestone schedule dates provided in in each response.
each response.
This letter This letter contains contains nono new new regulatory regulatory commitments.
commitments. If you have If you have any questions questions regarding regarding this this response, please response, please contact contact David David P.
P. Helker Helker at 610-765-5525.
IIdeclare declare under under penalty of of perjury perjury that that the the foregoing foregoing isis true true and and correct. Executed Executedon onthe 3rd day the3rd day of July 2013.
of July 2013.
Respectfully submitted, Respectfully
~~~
Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Exelon LLC
Enclosure:
- 1. Quad CitiesCities Nuclear Power Station, Station, Units Units 11 and and 22 -- Response ResponsetotoRequest RequestforforAdditional Additional Information --Overall Information OverallIntegrated Integrated Plan Plan inin Response Response to to Commission CommissionOrder OrderModifying Modifying License License Requirements for Requirements for Reliable Reliable Spent SpentFuel FuelPool PoolInstrumentation Instrumentation(Order (OrderNo.
No.EA-12-051)
EA-12-051) cc: Director, Office of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region Region III III NRC NRC Senior Resident Inspector - Quad QuadCitiesCities Nuclear Nuclear Power PowerStation, Station, Units Units 11 and and 22 NRC Project Manager, NRR - Quad QuadCities Cities Nuclear NuclearPower PowerStation, Station,Units Units11and and22 Mr.
Mr. Robert J. J. Fretz, Fretz,Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC NRC Mr. Robert Robert L.L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC NRC Mr. Blake Purnell, Purnell, NRC NRC Project Project Manager, Manager, NRR NRR Illinois Emergency Management Illinois Emergency Management Agency Agency--Division Division of of Nuclear Nuclear Safety Safety
Enclosure Enclosure 11 Quad Quad Cities Nuclear Nuclear Power Station, Station, Units 1 and 2 Response to Request for Additional Information Information Overall Integrated Plan in Response to Commission Order Modifying Overall License Requirements for Reliable Spent Fuel Pool Instrumentation License (Order No. EA-12-051)
EA-12-0S1)
(11 (11 pages)
Response to Response to Request Request for for Additional Information (Order EA-12-051) EA-12-051)
Enclosure Page 1 of 11 Page 11 1.0
1.0 INTRODUCTION
INTRODUCTION Byletter By letterdated dated February February28, 28, 2013 2013 (Agency (Agencywide wideDocuments DocumentsAccess Access and and Management Management System (ADAMS) Accession No. ML13060A124), Exelon Generation Company, LLC, submitted an (ADAMS) Accession No. ML13060A124), Exelon Generation Company, LLC, overall integrated overall integrated plan plan (OIP)
(OIP) ininresponse response to the March 12, 2012, U.S.
12,2012, U.S. Nuclear Nuclear Regulatory Regulatory Commission (NRC)
Commission (NRC) Order Order modifying modifyinglicenses licenses withwith regard regard to to reliable reliable spent fuel pool (SFP) instrumentation (Order EA-12-051; instrumentation EA-12-051; ADAMS ADAMS Accession No. No. ML12054A679)
ML12054A679) for for Quad Quad Cities Cities Nuclear Power Nuclear Power Station, Station, Units Units 11and and 2.2. The NRC NRC staff endorsed endorsed NuclearNuclear Energy Energy Institute, Institute, NEI 12-02, "Industry NEI12-02, "IndustryGuidance Guidance for for Compliance Compliance with with NRC NRC Order EA-12-051, to Modify Licenses Modify Licenses with Regard with Regard to Reliable SFP Instrumentation," Revision 1, dated Instrumentation," Revision 1, dated August 2012 (ADAMSAugust 2012 (ADAMS Accession No. ML12240A307),
ML12240A307), with withexceptions exceptions as documented documentedin in NRC NRC Interim Interim StaffStaff Guidance, Guidance, JLD-ISG-2012-03, "Compliance with JLD-ISG-2012-03, with Order Order EA-12-051, EA-12-051, Reliable Spent Spent FuelFuelPool Pool Instrumentation," Revision Instrumentation," Revision 0, dated dated August August 29, 29, 2012 2012(ADAMS (ADAMS Accession AccessionNo. No.ML12221A339).
NRC staff The NRC staffhas has reviewed reviewedthe the February February 28, 28, 2013, 2013, response response by the licensee and determined determined that the following request for following request additional information for additional information (RAI) (RAI)isisneeded needed to to complete complete its technical review.
2.0 LEVELS OF REQUIRED MONITORING MONITORING The OIP 01 P states, in in part, part, that:
Level adequate Level adequate to to support supportoperation operationof ofthe thenormal normalfuel fuelpool poolcooling coolingsystem system(L1): (L 1):
For both units, indicated level on either primary primary or backup backup instrument instrumentchannelchannel must be greater greater than than 23 23 feet feet 11inch inch (elevation (elevation 689' 689' 3")
3") plus instrument accuracy above the top of the storage racks based on of the on the the design design accuracy accuracy of of the instrument channel (which (which is to be determined) and and aaresolution resolution of of 11foot foot oror better for both the for both the primary primary and and backup backup instrument instrument channels.
channels. This is based based on on the the 11 inch opening 11 inch opening of of the the SFP weirweir gate design demonstrating demonstrating aa water water level level above above 23 feet 11 inchinch (elevation (elevation 689'3")
689' 3") isis adequate adequatefor fornormal normalfuel fuelpool poolcooling cooling system system operation.
Level adequate to Level adequate to provide provide substantial substantial radiation radiation shielding shielding for for aa person personstanding standingon on the spent spent fuelfuel pool pool operating operating deck deck (L2):
(L2): For Forboth bothunits, units,indicated indicatedlevel levelon oneither either the the primary primary or backup instrument instrument channel channel of of greater greaterthanthan10 10feet feet(elevation (elevation676' 676' 2")
2") plus instrument channel instrument channel accuracy accuracy above the top of the of the storage racks based based on specification specification of this level as as adequate adequateininNRC NRCJLD-ISG-2012-03 JLD-ISG-2012-03(Ref. (Ref.2) 2)and and NEI NEI 12-02 (Ref. (Ref. 3),
3), the the specified specified design accuracyaccuracy of of the instrument instrument channel, channel, and and the the relatively relatively low sensitivityof low sensitivity ofdose dose rates rates to changes changes in in water water depth depthatatthis thislevel.
level.
This monitoring monitoring level level ensures ensures there is is an adequate adequatewater waterlevel level to to provide provide substantial substantial radiation radiation shielding shielding for for a person person standing standingon onthethespent spentfuelfuelpool pool operating operating deck deck from from direct direct gamma gamma radiation radiation fromfrom stored spent spentfuel.
fuel.
Level Level where fuel remains covered covered (L3):(L3): For For both both units, units, indicated indicated level level onon either eitherthe the primary primary or backup instrument channel of greater than 0 feet (elevation (elevation 6662")
666' 2")plusplus instrument instrument channel accuracy above the the top top of of the storage storage racks racks based basedupon uponthe thedesign design accuracy accuracy (which (which is to to bebe determined) determined) of of the the instrument instrumentchannelchannelfor forboth both the theprimary primary and and backup backup instrument instrument channels.
channels. This This monitoring monitoring level assures that level assures that water wateris is covering covering thethe stored stored fuel fuel seated seatedinin the theracks.
racks.
Response to Response to Request for Additional Information Information (Order (Order EA-12-051)
Enclosure 1 Page 2 of 11 Page 11
RAI-1
Please provide the following:
Please a) For a) For level level LL1, specify how the 1, specify the identified identified location location represents the higher of the two points described in the NEI 12-02 guidance guidance for for this this level.
level.
b) A b) A clearly clearly labeled labeled sketch sketch depicting the elevation elevation viewview of the proposed proposedtypical typical mounting mounting arrangement for the portions of of instrument instrument channel channel consisting consisting of of permanent permanent measurement channel measurement channel equipment equipment(e.g., (e.g., fixed fixed level level sensors sensorsand/or and/orstilling stilling wells, and mounting brackets).
mounting brackets). Indicate Indicate onon this this sketch sketch thethe datum datum values valuesrepresenting representingL1, L1,L2, L2, and and L3 as L3 as well well asas the top top of of the the fuel.
fuel. Indicate Indicate on this sketch the the portion portion of the level sensor level sensor measurement range measurement range that thatisis sensitive sensitiveto tomeasurement measurementofofthe thefuel fuelpool poollevel, level, with with respect respect to the L1, L 1, L2, L2, and L3 datum points.
Response
a) The Spent Fuel Pool a) Pool at Quad Cities Cities Station has skimmers and scuppers scupperslocated locatedat atthe the 689' 3"' elevation that 3'" elevation that water water must must flow flowinto.
into. From From there there the the water is routed to to surge tanks from whichthe from which the Fuel Fuel Pool Pool Cooling Coolingand and Cleanup Cleanup (FC)(FC)pumps pumps draw draw suction.
suction. The suction trip suction trip isis at at an an approximate approximate 667' 6676" 6" elevation.
elevation. Thus Thusthethe689' 689'3"'
3'"elevation elevation reflects reflects the higher higher of the two points noted in NEI in NEI 12-02, section 2.3.1.
Please reference b) Please reference the the sketch sketch below.
below. Instrument Instrumentprobe probemounting mounting details details in in the the Spent SpentFuel Fuel area will Pool area will be provided in accordance accordancewith with the the response responsetotoRAI-3.
RAI-3.
Response to Request for Additional Information Information (Order (Order EA-12-051)
Enclosure Enclosure 11 Page 3 of of 1111
! 11 EL, 689'-9" EL. 689'-(r r EL. 689'-9 FlOOR EL EL 6il0'-6" r° i
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UNIT #1 LNIT # 1 SPENT SPENT FUEL FLEL gL..l UNIT #2 UNIT SPENT FUEL
- 2 SPENT FUEL SKlt.llJER SKIMMER SURGE, SJROE STORAGE STORAGE POOL ~~ STORAGE POOL POOL I IS~[IJUER SURGE SKIMMER SURGE TANK \ POOL j... ..JI- IIJ~ STORAGE V TANKTANK
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TOP/FUEL RACK-TOP/FUEL R FA EL EL 5S6'-t I I EL 668'-2" EL 655'-2" I lEVELS LEVEL 3 j LEVEL 3j LEVEL I EL 665'-6" EL 665'-E' EL. 665'-6" EL 665'-5'"
TO TO Fe FC P.iMPS P} MPS - -t:.. TO FC TO Fe PUIJPS PUMPS I
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!jt LO'II LOW POOL ,oILo\~M lEVEL ALARM POOL LEVEL ELEVATION VI ELEVATION VIEW
Response to Response to Request Requestfor forAdditional AdditionalInformation Information (Order (OrderEA-1 2-051)
Enclosure 1 Page 4 of 11 Page 11 3.0 3.0 INSTRUMENTATION DESIGN FEATURES INSTRUMENTATION 3.2 Arrangement OIP The 01 P states, in part, that:
The current plan plan is to to install install SFP SFP level level sensors sensors in in the southwest southwest cornercorner of of the Unit Unit 1 SFP and in and in the the northwest northwest cornercorner of ofthe the Unit Unit22SFP SFPseparated separated by by aa distance in in excess of of 50 feet. The sensors sensors themselves themselveswill will be be mounted, mounted, to to the the extent extentpractical, practical, near nearthe thepool pool walls and walls and below the pool curb to minimize minimize their their exposure exposure to to damaging debris and and not not interfere with interfere withSFP SFP activities.
activities. Instrument channel channel electronics electronics and and power powersupplies supplieswill will be be located in seismic and missile protected areas in seismic areaseither eitherbelow below the the SFP SFPoperating operatingfloor floor or or in in buildings other buildings other than than the RB [Reactor Building]. Building]. The areas areas to to be beselected selectedwill will provide provide suitable radiation shielding shielding and environmental conditions for the equipment consistent for the consistent with instrument with instrumentmanufacturer's manufacturer's recommendations.
recommendations. Equipment Equipment and andcabling cabling for for power power supplies and indication indication for each channelchannel will will be separated separatedequivalent equivalentto tothat thatprovided providedfor for redundant safety related services as as required required byby the Quad Quad Cities Cities design basis.basis.
RAI-2
Please provide Please provide aa clearly clearly labeled labeled sketch sketchor ormarked-up marked-upplant plantdrawing drawingof of the theplan planview view ofof the the SFP SFP area, depicting depicting the SFP SFP inside inside dimensions, dimensions, the theplanned plannedlocations/placement locations/placementofofthe theprimary primary andand back-up SFP level level sensor, sensor, and andthetheproposed proposedrouting routingof ofthe thecables cablesthat thatwill will extend extend fromfrom the sensors toward sensors toward the thelocation location of of the the read-out/display read-ouVdisplay device. device.
Response
The current plan for the SFPI for the SFPI design of the system based basedon onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for for Quad Cities Cities is to begin the design phase phaseinin October Octoberof of 2013 2013 withwith the design completion completion and 100% 100% acceptance acceptanceof ofthethedesign designininMarch March of of 2014.
2014. The The requested requested information will willbe be provided provided with withthe the August August of of 2014, 2014, 6-month integrated integrated plan plan update.
update.
3.3 Mounting Mounting The OIP OIP states, states, in in part, part, that:
that:
Design of the the mounting mounting of ofthe the sensors sensors in in the SFP SFP shall shall bebe consistent consistentwith with the the seismic seismic Class Class II criteria. Installed Insta"ed equipment equipmentwill will be verified verified to be seismically adequate adequate for for the the seismic motions motions associated associatedwith with the themaximum maximum seismic seismicground groundmotionmotionconsidered consideredininthe the design design of of the the plant plant area areaininwhich which itit isis installed.
installed.
RAI-3
Please provide the the following:
following:
a) a) The The design design criteria criteria that that will be used to will be to estimate estimatethe thetotal total loading loading on on the themounting mounting device(s), including static weight including static weight loads loads and and dynamic dynamic loads.
loads. Describe Describethe themethodology methodology that that will will bebe used to estimate estimate the thetotal total loading, loading, inclusive inclusive of of design design basis basismaximum maximum seismicseismic
Responsetoto Request Response Requestfor forAdditional Additional Information Information (Order (Order EA-12-051)
Enclosure Page 55 of Page of 11 11 loads and loads and thethe hydrodynamic hydrodynamic loads that could result from pool sloshing or other effects effects that could that couldaccompany accompany such such seismic forces.
b) b) AAdescription description of ofthe the manner manner in which the level level sensor sensor(and (andstilling stillingwell, well, ifif appropriate) appropriate)will will be attached be attached to the refueling floorand/or refueling floor and/orother other support support structures structures for for each each planned point point ofofattachment attachment of ofthethe probe probe assembly.
assembly. Indicate Indicate in in aa schematic schematicthe theportions portionsof ofthe thelevel level sensor that will sensor serve as points of will serve of attachment attachment for for mechanical/
mechanical/mountingmounting or or electrical electrical connections conn ections..
c)c) AA description descriptionof ofthethe manner manner by by which whichthethe mechanical mechanical connections will will attach attach the level instrument instrument to topermanent permanent 8FP SFP structures structures so as as toto support support the the level level sensor sensor assembly.
assembly.
Response
Response The current The current plan plan forfor the the 8FPI SFPI design design of of the the system basedbased on on the thecurrent currentExelon Exelon Nuclear Nuclear program program schedule for Quad Cities to begin is to begin the design phase phasein in October Octoberof of 2013 2013 withwith the design completion design completion and and 100%
100% acceptance acceptance of the design in in March March of of 2014. requested 2014. The requested information will information willbe beprovided providedwith withthetheAugust Augustofof2014, 2014,6-month 6-monthintegrated integrated plan plan update.
3.4 3.4 Qualification Qualification The OIP The OIP states, states, in in part, part, that:
that:
Components Components of of the the instrument instrumentchannels channelswill will be bequalified qualifiedfor for shock shockand andvibration vibration using using oneone or or more more of of the the following following methods:
- components components are are supplied supplied by by manufacture manufacturers rs using usingcommercial commercial quality quality programs programs (such (suchasas IS09001, "Quality 1809001, "Quality management managemen t systems systems--Requiremen Requirements") ts") with withshock shockand andvibration vibration requirement requirements s included included in the purchase purchasespecificatio specification n atat levels levels commensur commensurate with ate with portable portable hand-held hand-held devicesdevicesor ortransportatio transportation n applications applications; ;
- components componentshave havesubstantial substantialhistory historyofofoperational operationalreliability reliabilityininenvironmen environments with ts with significant significant shock and vibration loadings, vibration loadings, such such as portable portable hand-held hand-held devices devicesor or transportatio transportation n applications applications; ; or or
- components components are areinherently inherently resistant resistant to to shock shock and and vibration vibration loadings, such as as cables.
cables.
For For seismic effects effects on instrument instrument channel channel components componentsused usedafterafteraapotential potentialseismic seismicevent event for for only installed components components (with (with the exception of of battery chargers chargers and andreplaceable replaceable batteries),
batteries), the thefollowing measures will following measures will be used usedto toverify verify that the the design designand andinstallation installationisis adequate. Applicable adequate. Applicablecomponents componentsare arerated ratedbybythe themanufactur manufacturer er (or(orotherwise otherwisetested)tested)for for seismic seismic effects effects at at levels levels commensur commensurate ate with with those those of of postulated design design basis basiseventevent conditions conditions in in the area areaof of instrument instrument channel channel component componentuse useusingusingone oneorormore moreofofthe the following following methods:
methods:
- instrument instrument channel channel components componentsuse useknown knownoperating operatingprinciples principlesand andare aresupplied suppliedby by manufactur manufacturers ers with with commercial commercial quality quality programs programs (such (such as as 1809001).
IS09001). The Theprocuremen procurement t specificatio speCification n and/or and/or instrument instrument channel channel design designshall shall include include the theseismic seismicrequirement requirements s and andspecify specify the theneed needfor forcommercial commercial design designand andtesting testingunder underseismic seismicloadings loadings consistent consistentwith with design designbasisbasisvalues valuesatatthe theinstalled installedlocations; locations;
Response to Request Request for Additional Additional Information Information (Order (OrderEA-12-051)
Enclosure 1 Page 66of11 Page of 11
- substantial history substantial historyof of operational operationalreliability reliability in in environments environmentswith withsignificant significantvibration, vibration, such asas for for portable portable hand-held hand-held devicesdevices or or transportation transportation applications.
applications. Such Sucha avibration vibration design envelope envelope shallshall be beinclusive inclusive of of the the effects effectsof of seismic seismicmotion motion imparted imparted to to the the components proposed proposed at atthe thelocation location of of the the proposed proposedinstallation; installation;
- adequacy of adequacy of seismic design and and installation installation is is demonstrated based based on on the the guidance guidancein in Sections 7, Sections 8, 9, and 7,8,9, and10 10ofofIEEE IEEE[Institute
[Institute of of Electrical Electrical and and Electronics Electronics Engineers]
Engineers]
Standard 344-2004, Standard 344-2004, "IEEE "IEEE Recommended RecommendedPractice Practicefor forSeismic SeismicQualification QualificationofofClass Class1 1EE Equipment for for Nuclear Power Generating Generating Stations,"
Stations," or or aasubstantially substantiallysimilar similarindustrial industrial standard;
- demonstration that proposedproposed devices devices are aresubstantially substantiallysimilarsimilar in in design to to models models thatthat have been previously previously tested for seismic effects effects in in excess excess of the plantplant design design basis at the location where the instrument is to be installed location installed (g-levels (g-Ievels and and frequency frequency ranges);
ranges); or or
- seismic qualification qualification usingusing seismic motionmotion consistent with that of with that of existing existing design design basis loading at the installation installation location.
location.
RAi-4 Please provide the following:
a) A A description of of the the specific method or combination of methods methods you you intend intend toto apply applyto to demonstrate the demonstrate the reliability reliability ofof the the permanently installed installed equipment under beyond-design-beyond-design-basis ambient ambient temperature, temperature,humidity, humidity, shock, shock, vibration, vibration, and and radiation radiation conditions.
conditions.
b) A b) description of A description ofthe the testing testing and/or and/or analyses analyses that will be conducted will be conducted to to provide provide assurance assurance that the equipment equipment will perform reliably will perform reliablyunderunderthe the worst-case worst-case credible design basis basis loading at loading at the the location where the location where the equipment will willbe bemounted.
mounted. Include Include a discussion of of this seismic reliability demonstration as reliability demonstration as it applies to a) the level sensor it applies sensor mounted mountedin in the the SFP area, area, and andb) b) any anycontrol control boxes, boxes,electronics, electronics, or orread-out read-outand andre-transmitting re-transmitting devicesdevices that will be employed to convey the level will be level information information from from thethe level level sensor sensor to to the the plant plant operators or emergency responders. responders.
c) A c) description of A description of the the specific method or combination of methods methods thatthat will will be used used to to confirm the confirm the reliability reliabilityof ofthe the permanently permanently installed equipment equipment such suchthatthatfollowing following aa seismic event event the the instrument instrumentwill will maintain its required accuracy. accuracy.
Response
The current plan for for the the SFPI SFPI design of the system based based on on the thecurrent currentExelon Exelon Nuclear Nuclear program schedule schedule forfor Quad Cities Cities isis to to begin begin thethe design design phasephaseininOctober Octoberofof2013 2013withwiththethe design completion completion and and 100% acceptance of of the design in in March March of of 2014.
2014. The requested requested information will information willbebeprovided provided with withthethe August August of of 2014, 2014, 6-month 6-month integrated plan plan update.
update.
3.5 Independence The OIP 01 P states, inin part, part, that:
that:
The primary primary instrument channel will be independent will be independent of the backup instrument channel. channel.
This independence independence will be achieved through physical and electrical will be electrical separation of each channels' components components commensurate commensuratewith with hazard hazardand andelectrical electricalisolation isolation needs.
needs.
Response to Request for AdditionalAdditional Information Information (Order (OrderEA-12-051)
EA-12-051) 1 Enclosure Page 7 of of 1111
RAI-5
Please provide the following:
a) A description of A description of how howthe thetwo twochannels channels ofofthe the proposed proposed level level measurement measurement system system meet meet this requirement so that the potential potential for a common cause cause event eventto toadversely adverselyaffect affectboth both channels isis minimized channels minimized to the extent extent practicable.
practicable.
b) Further information b) informationon onhow howeacheach level levelmeasurement measurement system, consisting of of level sensor sensor electronics, cabling, electronics, cabling, andand readout readout devices will be designed will be designed andand installed installed to to address address independence through the application independence application and selection of independent power sources, the the use of of physical and spatial separation, separation, independence independenceofofsignals signalssent senttotothe thelocation(s) location(s)ofof the readout devices, and and the the independence independenceof ofthe thedisplays.
displays.
Response
The current plan for for the the SFPI SFPI design of the system based basedon onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for for Quad Cities is to begin the design phase phaseinin October Octoberof of 2013 2013 with with the design completion completion and and 100% acceptance acceptance of of the design in in March March of of 2014.
2014. The requested requested information will information willbebeprovided providedwith withthe theAugust Augustofof2014, 2014,6-month 6-month integrated integrated plan plan update.
3.6 Power supplies The OIP states, in in part, that:
Each channel channel willwill be normally normally powered powered from from aadifferent different 120Vac 120Vac[120 [120volts-alternating volts-alternating current] bus. Upon current] Upon loss lossofofnormal normalac acpower, power,individual individual channel channel installed installedbatteries batterieswill will automatically maintain automatically maintaincontinuous continuous channel channel operation.
operation. The The batteries batteries will will be replaceable replaceable and be sizedsized toto maintain maintain channel channel operation operation until until off-site off-site resources can be be deployed deployed by by the mitigating strategies resulting mitigating strategies resulting from from Order Order EA-12-049 EA-12-049 (Ref.(Ref. 4).
4). Additionally, Additionally, each each channel will have provisions will have provisions for for connection connection to to another another suitable power source. source.
RAI-6
Please provide the following:
a) A description of A description of the the electrical electrical ac ac power sources sources and and capacities capacitiesfor forthe theprimary primary andand backup channels.
b) IfIfthe b) the level levelmeasurement measurement channels are are to to be be powered powered through through aabattery batterysystem system(either (either directly or through directly or through an uninterruptible power supply), please provide the design please provide the design criteria criteria that will will bebe applied applied to to size size the the battery battery in in aa manner manner that ensures, ensures, withwith margin, that the channel will be available to run reliably and continuously following will be following the the onset onset of the beyond-design-basis event beyond-design-basis event for for the the minimum duration needed, consistent minimum duration consistent withwith the plant plant mitigation strategies mitigation strategies for for beyond-design-basis beyond-design-basis external external events events(Order (OrderEA-12-049).
~~-~ ---~~----
Response to Request Request for for Additional Additional Information Information (Order (OrderEA-1 2-051)
EA-12-051) 1 Enclosure Page 8 of of 11 11
Response
Response The current plan forfor the the SFPI SFPI design of the system based basedon onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for Quad Cities is to begin the design phase phaseinin October Octoberof of 2013 2013 with with the design completion completion and 100% acceptance acceptance of of the design in March of in March of 2014.2014. The requested requested information will information willbe beprovided provided with withthe the August August of of 2014, 2014, 6-month integrated integrated plan plan update.
update.
3.7 Accuracy The OIP states, in in part, part, that:
The instrument channels channels will will be designed designed to to maintain maintain their their design design accuracy accuracyfollowing following aa interruption or power interruption or change change in in power source without recalibration.
recalibration. Instrument Instrument channel channel accuracy, to be be determined determinedduringduring detailed detailed design, design,willwill consider consider Spent SpentFuel FuelPool Pool conditions (e.g.,
conditions (e.g., saturated saturated water, steam environment, environment, concentrated borated water), as as well as, other applicable radiological well as, radiological and environmental conditions and include include display accuracy. Instrument Instrumentchannelchannelaccuracy accuracywill will be besufficient sufficient toto allow allow trained personnel personnelto to determine when the the actual actual level level exceeds exceedsthe thespecified specifiedlower lowerlevel levelofofeach eachindicating indicating range (levels (levels 1,1, 22 or or3)3) without without conflicting conflicting or ambiguous ambiguous indications.
indications.
RAI-7
Please provide the following:
a) An An estimate of of the the expected instrument channel accuracy accuracy performance performance under under both both a) a) normal SFP level conditions (approximately normal (approximately LL1 or higher) 1 or higher)and and b)b) at at the the beyond design-basis conditions conditions (i.e., radiation, temperature, temperature, humidity, humidity, post-seismic and and post-shock post-shock conditions) that conditions) that would would be be present present ifif the SFP level level were at at the the L2L2 and and L3L3 datum datum points.
points.
b) A b) description of the methodology A description methodology that that will will be used used for for determining determiningthe themaximum maximumallowedallowed deviation from deviation from thethe instrument instrument channel channel design accuracy accuracy thatthat will will be employed under under normal operating conditions normal conditions as an an acceptance acceptancecriterion criterionforfor aacalibration calibration procedure procedureto toflag flag to operators and and to to technicians technicians that that the the channel channelrequires requiresadjustment adjustmenttotowithinwithin the the normal normal condition design condition design accuracy.
Response
Response The current plan forfor the the SFPI SFPI design of the system based basedon onthe thecurrent currentExelon Exelon Nuclear Nuclear program schedule schedule for for Quad Quad Cities Cities is is to to begin begin the the design designphasephaseininOctober Octoberofof2013 2013with withthe the design completion completion and and 100% acceptance of of the design in in March March of of 2014.
2014. The requested requested information will information willbe beprovided provided with withthe the August August ofof 2014, 2014, 6-month 6-month integrated plan plan update.
update.
3.8 Testing The OIP states, in part, that:
Response to Response to Request for for Additional Information (Order (Order EA-1 2-051)
Enclosure Page 9 of 11 Page Instrument channel Instrument channel design will provide for will provide for routine routine testing testing and and calibration consistent with calibration consistent with the guidelines of NRC the NRC JLD-ISG-2012-03 JLD-ISG-2012-03 (Ref. (Ref. 2)
- 2) and and NEI NEI 12-02 (Ref. (Ref. 3).
3). Details Details will will be determined during determined during detailed detailed design design engineering.
RAI-8
Please provide Please provide the following:
a) AA description a) description of of the the capability capability andand provisions the proposed proposed levellevel sensing sensingequipment equipmentwill will have to enable enable periodic periodic testing and and calibration, calibration, including including how this capability enables the capability enables the equipment to to be tested tested in-situ.
in-situ.
b) A b) A description description of of how how suchsuch testing andand calibration calibration will enable the conduct will enable conduct of of regular regular channel checks of channel of each each independent channel against the other, and against any any other other permanently-installed SFP level instrumentation.
permanently-installed c) A c) A description description of of how how functional functionalchecks checks will willbebe performed, performed, and and the frequency frequency at at which which willbe they will beconducted.
conducted. Describe Describe howhow calibration calibration tests testswill will be performed, performed, and and the the frequency at which frequency whichtheytheywillwillbebeconducted.
conducted. Provide Provide aa discussion discussion as to how these surveillances will be incorporated into the plant will be plant surveillance surveillance program.
program.
d) A d) A description description of ofwhat whatpreventative preventativemaintenance maintenance tasks tasks are required required to be be performed performed during normal during normal operation, operation, and the plannedplanned maximum maximum surveillance surveillance interval interval that that is is necessary to necessary to ensure ensurethat thatthe thechannels channelsare arefully fullyconditioned conditionedto toaccurately accuratelyand andreliably reliably perform their perform their functions functions when when needed.
needed.
Response
Response The current plan for the SFPI design of the system based basedon onthethecurrent currentExelonExelonNuclear Nuclear program schedule for for Quad Cities is to begin the design design phase phaseininOctober Octoberof of 2013 2013 with with the design completion completion and 100% 100% acceptance acceptanceof ofthe thedesign designininMarch March of of 2014.
2014. Following Following thetheissue issueofof the the design, design, procedures procedureswill will start start being being developed developedwith with aaprojected projectedOctober October2014 2014completion completion date. The Therequested requestedinformation informationwill will be beprovided providedininthe theAugust August2014, 2014,6-month 6-monthintegrated integratedplan plan update.
update.
3.9 Display Display The The OIP OIP states, states, inin part, part, that:
that:
The The primary primary and and backup backup instrument instrument displays displayswillwill be located located at at the thecontrol control room, room, alternate alternate shutdown shutdown panel,panel, or or other other appropriate appropriate and accessible accessiblelocation.
location. TheThe specific specific location location willwill bebe determined during detailed detailed design.
design.An An appropriate appropriateand and accessible accessiblelocation locationwillwill include includethethefollowing following characteristics:
characteristics:
- occupied occupied promptly promptly accessible accessibleto tothe theappropriate appropriateplant plantstaff staffgiving giving appropriate appropriate consideration consideration to to various various drain drain down down scenarios, scenarios,
Response to Response to Request for Additional Information (Order (Order EA-12-051)
Enclosure Page 10 of 11 Page 11
- outside the outside the area area surrounding surrounding the SFP floor (e.g., an floor (e.g., an appropriate appropriate distance fromthe from the radiological radiologicalsources sources resulting resulting from from an an event event impacting impacting thethe Spent Fuel Pool),
Fuel Pool),
- inside aa structure inside structure providing providingprotection protectionagainstagainstadverse adverse weather, and
- outside of any Very outside Very High High radiation areas areasororLOCKED LOCKEDHIGH HIGH RAD RAD AREA AREA during normal during normal operation.
RAI-9
Please provide the following:
Please a) The specific a) specific location location for foreach each of of the the primary primary and and backup backup instrument channel displays.
b) IfIfthe b) the primary primaryand and backup backup display location location is other than the the main main control control room, room, provide provide justification for justification forprompt prompt accessibility accessibility to to displays displays including primary and alternate alternate route route evaluation, habitability evaluation, habitability at at display display location(s),
location(s), continual continual resource availability availability forfor personnel personnel responsible to promptly promptly read displays, displays, and andprovisions provisionsforforcommunications communicationswith with decision decision makers for for the the various various SFPSFP drain drain down down scenarios scenarios and external events.
c) The reasons c) reasons justifying justifying why the locations selected selected enable enablethe theinformation information from from these these instruments to be considered "promptly accessible" to "promptly accessible" to various various drain-down drain-down scenarios scenarios and external events.
Response
Response The current plan for for the the SFPI SFPI design of the system based basedon onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for Quad Cities is to begin the design phase phasein in October Octoberof of 2013 2013 withwith the design completion completion and and 100% acceptance acceptance of of the design in in March March of of 2014.
2014. The requested requested information information willwillbe be provided provided with withthethe August August of of 2014, 2014, 6-month integrated integrated planplan update.
update.
4.0 PROGRAM PROGRAM FEATURES FEATURES 4.2 Procedures Procedures The OIP 01 P states, states, in in part, part, that:
that:
Procedures Procedures will will be developed using using guidelines and and vendor vendor instructions instructions to address addressthe the maintenance, operation operation andand abnormal abnormal response responseissues issuesassociated associatedwith withthetheprimary primaryand and backup channels channels of of SFP SFPinstrumentation.
instrumentation.
RAI-10
RAI-10 Please Pleaseprovide provideaadescription descriptionof ofthe thestandards, standards,guidelines guidelinesand/or and/orcriteria criteriathat thatwill willbe beutilized utilized to to develop procedures for inspection, develop procedures for inspection, maintenance, repair, repair, operation, abnormal response, response, and and administrative controls associated administrative controls associated with with the SFPSFP level level instrumentation, as as well well as storage storage and and installation installation ofof portable portable instruments.
instruments.
Responseto Response to Request Request for for Additional Additional Information (Order EA-1 EA-12-051) 2-051)
Enclosure Enclosure 1 Page 11 Page 11 of of 11 11
Response
Response The current The current plan planforforthe theSFPI SFPIdesign design of ofthe the system system based on on the the current current Exelon Exelon Nuclear Nuclear program schedule program schedule for for Quad Quad Cities Cities isis to to begin begin thethe design design phase phase in in October October of 2013 with with the design completion design completion and and 100%
100% acceptance acceptance of of the design design inin March March of 2014. Following the issue 2014. Following issue of of the design, the design, procedures procedures will will start being developed developed with with aa projected projected October October 20142014completion completion date. The date. The requested requestedinformation information will be provided will be provided in in the the August August 2014, 2014, 6-month 6-month integrated integrated planplan update.
update.
4.3 4.3 Testing and Testing and Calibration The OIP The OIP states, in part, that:
The testing The testing and calibration calibration of the instrumenta instrumentationtion will will be consistent consistent with vendor with vendor recommend recommendations ations or other documented basis. basis. Calibration Calibrationwill will be be specific specific to the mounted instruments mounted instruments and and the the displays.
displays. Instrument Instrument performanc performance will be e will be trended trended as described in Exelon described procedural requirements.
Exelon procedural requirements.
RAI-11
RAI-11 Please provide the following:
Please a) Further information a) Further informationdescribing describingthe the maintenance maintenance and and testing testing program program the thelicensee licenseewill will establish establish and and implement implement to ensureensure that thatregular regular testing testing andandcalibration calibration is is performed performed and and verified verified by by inspection inspection and and audit audit to to demonstrate demonstrate conformance conformance with with design design and system readiness readiness requirement requirements. s. Include Includeaadescription descriptionof of your your plans plans for for ensuring ensuring that necessary necessary channel checks, functional tests, periodic channel checks, functional tests, periodic calibration, and calibration, andmaintenance maintenancewill will be beconducted conducted for the level for the measurement system level measurement system and anditsitssupporting supporting equipment.
equipment.
b) A b) A description description of of how how thethe guidance in NEI NEI 12-02 Section 4.3 regarding compensato compensatory ry actions actions forfor one one or or both both non-functio non-functioning ning channels channels willwill be addressed.
addressed.
c) A c) description of A description of what what compensatory compensatory actions are planned in event that in the event that one one of of the the instrument channels instrument channels cannot becannot berestored restoredtotofunctional functional status statuswithin within 9090 days.
days.
Response
Response The The current current plan plan for for the SFPI design design of of the the system system based basedon onthethecurrent currentExelon ExelonNuclear Nuclear program schedule for Quad Cities is program schedule for Quad Cities is to begin the to begin the design designphase phaseininOctober Octoberofof2013 2013with with the the design designcompletion completion and and 100%
100%acceptance acceptanceofofthe thedesign designininMarch Marchof of2014.
2014.Following Followingthe theissue issueofof the thedesign, deSign,procedures procedureswill willstart startbeing beingdeveloped developedwith withaaprojected projectedOctober October2014 2014completion completion date.
date.The Therequested requested information informationwill willbebeprovided providedininthe theAugust August2014, 2014,6-month 6-monthintegrated integratedplan plan update.
update.