RS-14-021, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
| ML14062A062 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/28/2014 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-14-021 | |
| Download: ML14062A062 (17) | |
Text
tio Order No. EA-12-051 RS-14-021 February 28, 2014 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-37 4
Subject:
Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
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. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012
- 4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012
- 5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (RS-13-031)
- 6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28,2013 (RS-13-120)
- 7. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2
- Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (T AC Nos. MF1119 and MF1120), dated November 26, 2013
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page2 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 the EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the LaSalle County 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. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station. The purpose of this letter is to provide the second 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. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference 7.
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 28111 day of February 2014.
Respectfully submitted, Glen T. Kaegi Director - Licensing & Regul ory Affairs Exelon Generation Company, LLC
Enclosure:
- 1. LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation
Enclosure LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (14 pages)
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction LaSalle County 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 First six month status report 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 First six month status report (Reference 6), and are current as of February 28, 2014.
- None 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 RAis July 5, 2013 Complete Submit 6 Month Updates:
Update 1 August28,2013 Complete Complete with Update 2 February 28, 2014 this submittal Update 3 August28,2014 Not Started Provide Final Safety Evaluation September 30, 2014 Not Started 1 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 I Milestone Target Completion Activity Revised Target Date Status Completion Date (SE) Info Modifications:
Conceptual Design 302012 Complete Begin Detailed Design 202013 Complete Engineering Issue Exelon Fleet contract to 402013 Complete procure SFPI Equipment Complete and Issue SFPI I 102014 Started 202014 Modification Package Begin Installation 402014 Not Started Complete SFPI Installation and I 102015 Not Started I Put Into Service I I 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 LaSalle County 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 Interim Safety Evaluation (IS E) and the status of each item.
Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete.
Continuous level indication will be (Addressed in Reference 6) provided by a guided wave radar system, submersible pressure transducer, or other appropriate level 2 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 sensing technology that will be determined during the detailed engineering phase of the project.
2 RAJ Question: Complete.
(RAI-1, Please provide following: (Addressed in Reference 4)
Ref. 4) a) For Level 1, specify how the identified location represents the higher of the two points described in the NEI12-02 guidance for this level.
b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of instrument channel consisting of permanent measurement channel equipment I (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Level 1, Level 2, and Level 3 as well as the top of the fuel. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1, Level 2, and Level 3 datum points.
3 RAJ Question: Complete.
(RAI-2, Please provide a clearly labeled (Addressed in Reference 4) I Ref. 4) sketch or marked-up plant drawing of l the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and back-up SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
4 RAJ Question: Started.
(RAI-3, Please provide the following: Note that the completion date for detailed Ref.4) a) The design criteria that will be design has changed from January 2014 used to estimate the total loading on to May 2014. All design information will the mounting device(s), including be provided in the August 2014 6-month static weight loads and dynamic loads. Describe the methodology that Integrated Plan update.
will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the 3 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic I the portions of the level sensor that l will serve as points of attachment I for mechanical/mounting or electrical connections.
c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to I
support the level sensor assembly.
RESPONSE
Mounting device total loading and attachments are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SF PI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100%
acceptance of the design in -May 2014.
The requested information will be provided in the August 2014, 6-month j Integrated Plan Update.
5 RAI Question: Started.
(RAI-4, Please provide the following: Note that the completion date for detailed Ref.4) a) A description of the specific design has changed from January 2014 I method or combination of methods to May 2014. All design information will you intend to apply to demonstrate be provided in the August 2014 6-month the reliability of the permanently Integrated Plan update.
installed equipment under BOB ambient temperature, humidity, shock, vibration, and radiation conditions. II b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably 4 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 under the worst-case credible design basis loading at the location where the equipment will be mounted.
Include a discussion of this seismic reliability demonstration as it applies to a} the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RESPONSE
Equipment reliability qualification information is not available at this time.
This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100% I acceptance of the design in May 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
6 RAI Question: Started.
(RAI-5, Please provide the following: Note that the completion date for detailed Ref.4) a) A description of how the two design has changed from January 2014 channels of the proposed level to May 2014. All design information will measurement system meet this requirement so that the potential for a be provided in the August 2014 6-month common cause event to adversely Integrated Plan update.
affect both channels is minimized to the extent practicable.
b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, 5 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RESPONSE
Channel independence information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SF PI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100% I acceptance of the design in May 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
7 RAI Question: Started.
(RAI-6, Please provide the following: Note that the completion date for detailed Ref.4) a) A description of the electrical ac design has changed from January 2014 power sources and capacities for the to May 2014. All design information will primary and backup channels.
b) Please provide the results of the be provided in the August 2014 6-month calculation depleting the battery Integrated Plan update.
backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the water level indication function until offsite resource availability is reasonably assured.
RESPONSE
Equipment total power supply configuration and characteristics are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100% acceptance of the 6 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 design in May 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
8 RAI Question: Started.
(RAI-7, Please provide the following: Note that the completion date for detailed Ref.4) a) An estimate of the expected design has changed from January 2014 instrument channel accuracy to May 2014. All design information will performance (e.g., in percent of be provided in the August 2014 6-month span) under both (a) normal SFP Integrated Plan update.
level conditions (approximately Level1 or higher) and (b) at the BOB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions} that would be present if the SFP water level were at the Level 2 and Level 3 datum points.
b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy. I
RESPONSE
Channel accuracy information is not I
available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100% acceptance of the design in May 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
9 RAI Question: Not Started.
(RAI-8, Please provide the following: Note that the completion date for detailed a) A description of the capability and design has changed from January 2014 7 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Ref.4) provisions the proposed water level to May 2014. All requested information sensing equipment will have to will be provided in the August 2014 6-enable periodic testing and month Integrated Plan update.
calibrationJ including how this capability enables the equipment to be tested in-situ.
b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
c) A description of how functional checks will be performed, and the I frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.
d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RESPONSE
Equipment testing, calibration, functional checks and maintenance requirements are not available at this time. This information will be I established during process and I l
procedure development following the detailed design phase. The current I plan for the design of the system SF PI based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with I design completion and 100%
acceptance of the design in May 2014.
Following the issue of the design, procedures will start beil}gdevelqped.
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LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
10 RAI Question: Started.
(RAI-9, Please provide the following: Note that the completion date for detailed Ref.4) a) The specific location for each of design has changed from January 2014 the primary and backup instrument to May 2014. All design information will channel displays.
be provided in the August 2014 6-month b) If the primary and backup display Integrated Plan update.
location is other than the main control room, provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events.
c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.
RESPONSE
Channel display location information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100%
acceptance of the design in May 2014.
The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
11 RAI Question: Not Started.
(RAI-10, Please provide a description of the Note that the completion date for detailed Ref.4) standards, guidelines and/or criteria design has changed from January 2014 that will be utilized to develop to May 2014. All requested information procedures for inspection, will be provided in the August 2014 9 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 maintenance, repair, operation, 6-month Integrated Plan update.
abnormal response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments. I RESPONSE: l I
Procedural details are not available at this time. This information will be I
I established during process and procedure development following the detailed design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100%
acceptance of the design in May 2014.
Following the issue of the design, procedures will start being developed.
The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
12 RAI Question: Not Started.
(RAI-11, Please provide the following: Note that the completion date for detailed Ref.4) a) Further information describing the design has changed from January 2014 maintenance and testing program the licensee will establish and implement to May 2014. All requested information I to ensure that regular testing and will be provided in the August 2014 6- I calibration Is performed and verified month Integrated Plan update.
by inspection and audit to demonstrate conformance with design and system readiness requirements. Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
b) A description of how the guidance in NEI12-02, Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.
c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 10 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 90 days.
RESPONSE
I Testing and calibration program requirements and compensatory actions are not available at this time. This information will be established during process and procedure development following the detailed design phase.
The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for LaSalle started the design phase in June of 2013 with design completion and 100% acceptance of the design in May 2014. Following the issue of the design, procedures will start being developed. The requested information will be provided in the August 2014, 6-month Integrated Plan Update.
Interim Safety Evaluation Open Items 01# Description Status 1 RAI Question: Not Started.
(RAI-1, Please provide additional information Ref. 5) describing how the final arrangement of the SFP instrumentation and routing of the cabling between the level instruments, the electronics and the displays, meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that '
may result from damage to the structure over the SFP.
2 RAJ Question: Not Started.
(RAI-3, For RAI2(a) above, please provide the analyses used to verify the design I
Ref. 5) I criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design-basis maximum seismic loads and hydrodynamic loads that could result from pool sloshing or other effects that could accompany such 11 of14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 seismic forces.
3 RAI Question: Not Started.
(RAI-4, For each of the mounting attachments Ref. 5) required to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.
4 RAI Question: Not Started.
(RAI-6, For RAI #5 above, please provide the Ref. 5) results for the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order I requirements.
5 RAI Question: Not Started.
(RAI-11, Please provide the following:
Ref. 5) a) The specific location for each of the primary and backup instrument channel displays.
b) Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include an estimate of the time available for personnel to access the display as well as the actual time it will take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event.
I Describe whether personnel would continuously monitor the display or access the display location on demand.
c) If a display will be located somewhere other than the control room or alternate shutdown panel, please describe the evaluation used to validate that the display location can be accessed without 12 of 14
LaSalle County Station, Units t and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 unreasonable delay following a BOB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display.
Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event.
Describe whether personnel are continuously stationed at the display or monitor the display periodically.
6 RAI Question: Not Started.
(RAI~12, Please provide a list of the procedures Ref. 5) addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP instrumentation.
Please provide a brief description of the specific technical objectives to be achieved within each procedure.
Note: RAis not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAisin Reference 3 and are listed in the Overall Integrated Plan Open Item Table.
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 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 031) 13 of 14
LaSalle County Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014
- 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 7, 2013.
- 4. Exelon Generation 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 3, 2013 (RS-13-158).
- 5. USNRC letter to Exelon Generation Company, LLC, "Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", dated November 26, 2013.
- 6. First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 28, 2013 (RS-13-120).
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