RS-14-196, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML14248A323
Person / Time
Site: Byron  Constellation icon.png
Issue date: 08/28/2014
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
"EA-12-051"; "RS-14-196"
Download: ML14248A323 (30)
v • d • e


Text

Exelon Generation Order No. EA-12-051 RS-14-196 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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-13-028)
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-13-114)
7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2014 (RS 018)
8. NRC letter to Exelon Generation Company, LLC, Byron 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 (TAC Nos. MF0872 and MF0873), dated November 4, 2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2014 Page 2 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 NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Byron 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. References 6 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition 0.2, of Reference 1 for Byron Station. The purpose of this letter is to provide the third six-month status report pursuant to Section IV, Condition 0.2, 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 8.

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 2014.

Respectfully submitted, 77 t

'Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - Byron Station, Units 1 and 2 NRC Project Manager, NRR - Byron Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Stephen R. Monarque, NRR/JLD/JPMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Joel S. Wiebe, NRR/DORLJLPL3-2, NRC Mr. John Hughey, NRR/JLD/MSD, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (26 pages)

Byron Station, Units 1 and 2 Third 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 Byron 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 Second 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 Second Six-Month status report (Reference 6), and are current as of August 28, 2014.

  • Provided responses to all RAls via ePortal on 3/31/14
  • Completed and Issued SFPI Modification Package 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 Activity Target Milestone Completion 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 5, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Provide Final Safety Evaluation March 31, 2014 Complete (SE) Information Update 3 August 28, 2014 Complete with Page 1 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Revised Target Activity Target Milestone Completion Date Status Completion Date this submittal Modifications:

Conceptual Design 302012 Complete Begin Detailed Design 102013 Complete Engineering Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Complete and Issue SFPI 202014 Complete Modification Package Begin Installation 202014 Complete Complete SFPI Installation and 402014 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 Byron 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 (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Items 01# Description Status 1 For Level 1, specify how the Complete.

identified location represents the (RAI-1a, higher of the two points described in (Addressed in Reference 7)

Ref.4) the NEI 12-02 guidance for this level.

Page 2 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status 2 Open Item:

Complete.

(Ref.1) Continuous level indication will be (Addressed in Reference 6) provided by a guided wave radar system, submersible pressure transducer, or other appropriate level sensing technology that will be determined during the detailed engineering phase of the project.

3 RAI Question:

Complete.

(RAI-lb, A clearly labeled sketch depicting (Addressed in Reference 4)

Ref. 4) the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (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.

4 RAI Question: Complete.

(RAI-2, Provide a clearly labeled sketch or (Addressed in Reference 7)

Ref.4) marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and backup 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.

5 RAI Question: Complete.

(RAI-3, Provide the following: a) All SFPIS equipment will be Ref.4) a) The design criteria that will be designed in accordance with the used to estimate the total loading Byron Station Safe Shutdown Page 3 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status on the mounting device(s), Earthquake (SSE) design including static weight loads and requirements.

dynamic loads. Describe the methodology that will be used to The vendor, Westinghouse, has estimate the total loading, evaluated the structural integrity inclusive of design basis of the mounting brackets in maximum seismic loads and the calculation CN-PEUS-13-24. The hydrodynamic loads that could GTSTRUDL model, used by result from pool sloshing or other Westinghouse to calculate the effects that could accompany stresses in the bracket assembly, such seismic forces. considers load combinations for b) A description of the manner in the dead load, live load and which the level sensor (and stilling seismic load on the bracket. The well, if appropriate) will be reactionary forces calculated from attached to the refueling floor these loads become the design and/or other support structures inputs to design the mounting for each planned point of bracket anchorage to the refuel attachment of the probe assembly. floor to withstand a Safe Indicate in a schematic the Shutdown Earthquake (SSE).

portions of the level sensor that will serve as points of attachment Seismic for mechanical/mounting or electrical connections. The seismic loads are obtained c) A description of the manner by from Byron Station's response which the mechanical connections spectra curves (Reference will attach the level instrument to Updated FSAR Chapter 3 Figures permanent SFP structures so as to for Byron Nuclear Generating support the level sensor assembly. Station). The following methodology was used in determining the stresses on the bracket assembly:

  • Frequency analysis, taking into account the dead weight and the hydrodynamic mass of the structure, is performed to obtain the natural frequencies of the structure in all three directions.

Page 4 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status

  • Modal responses are combined using the Ten Percent Method per U.S.

NRC Regulatory Guide 1.92, Revision 1, "Combining Modal Responses and Spatial Components in Seismic Response Analysis". This method is endorsed per Appendix A of the Updated FSAR Revision 14 for Byron Nuclear Generating Station.

  • The seismic loads for each of the three directions are combined by the Square Root of the Sum of Squares (SRSS) Method.
  • Sloshing analysis is performed to obtain liquid pressure and its impact on bracket design.
  • The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum. These combined results are compared with the allowable stress values.

Sloshinci Sloshing forces were obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach has been used to estimate the wave height and natural frequency. Horizontal and vertical impact force on the bracket components was calculated using the wave height and natural frequency obtained using TID-7024 approach. Using this methodology, sloshing forces Page 5 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status have been calculated and added to the total reactionary forces that would be applicable for bracket anchorage design. The analysis also determined that the level probe can withstand a credible design basis seismic event.

During the design basis event, the SFP water level is expected to rise and parts of the level sensor probe are assumed to become submerged in borated water. The load impact due to the rising water and submergence of the bracket components has also been considered for the overall sloshing impact. Reliable operation of the level measurement sensor with a submerged interconnecting cable has been demonstrated by analysis of previous Westinghouse testing of the cable, and the vendor's cable qualification. Boron build up on the probe has been analyzed to determine the potential effects on the sensor in WNA-TR-03149-G EN.

The following Westinghouse documents provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a. CN-PEUS-13-24 Pool-side Bracket Seismic Analysis
b. LTR-SEE-II-13-47, WNA-TR-03149-GEN Sloshing Analysis Page 6 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status

. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification of other components of SFPI Byron Station specific calculations BYR10-109 -

Seismic Qualification of Instrument Mounting Details Associated with Plant Process Computer Replacement, and BYR14-056 - Seismic Qualification of Weschler Indicator VX-252, are being developed to address the seismic qualification of the readout display (Weschler Instruments) in the main control room (MCR).

The design criteria used in this calculation meets the requirements to withstand a SSE and will meet the Byron Station safety related installation requirements. The methods used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, will be suspended from the launch plate via coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors. Attachment 1 shows a schematic of the level sensor with mechanical attachment points.

c) The bracket assembly that supports the sensor probe and launch plate will be mechanically connected to the SFP structure.

The mechanical connection Page 7 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status consists of four concrete expansion anchors that will bolt the bracket assembly to the SFP structure via the base plate. The concrete expansion anchors will be designed to withstand SSE and will meet the Byron Station safety related installation requirements. The qualification details of the bracket are provided in Westinghouse's Pool-side bracket Seismic Analysis CN-PEUS-13-24 and the qualification of the anchorage to the floor is provided in Byron Station specific calculation BYR13-192 Evaluation of SFPI Sensor Mounting Detail Anchorage and Mounting for OPLO4J and OPLO6J.

6 RAI Question: Complete.

(RAI-4, Provide the following: a) Beyond Design Basis Environment Ref.4) a) A description of the specific Westinghouse qualified the method or combination of components (probe, connector, methods that will be applied to cable) of the SFPIS located in the demonstrate the reliability of the SFP area to the beyond design permanently installed equipment basis environment. Components of under beyond-design basis the system were subjected to ambient temperature, humidity, beyond design basis conditions of shock, vibration, and radiation heat and humidity, thermal and conditions, radiation aging mechanisms. This b) A description of the testing and/or testing confirmed functionality of analyses that will be conducted to these system components under provide assurance that the these beyond design basis equipment will perform reliably environmental conditions.

under the worst-case credible Westinghouse performed testing to design basis loading at the ensure aging of the components in location where the equipment will the SFP area will not have a be mounted. Include a discussion significant effect on the ability of the of this seismic reliability equipment to perform following a demonstration as it applies to a) plant design basis earthquake.

the level sensor mounted in the Exelon has reviewed the documents SFP area, and b) any control and found acceptable. Reference Page 8 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status boxes, electronics, or read-out Westinghouse documents EQ-TP-and re-transmitting devices that 351, WNA-TR-03149-GEN, and EQ-will be employed to convey the TP-354 for description of specific level information from the level qualification methods.

sensor to the plant operators or Mild Environment Westinghouse emergency responders.

c) A description of the specific qualified the system components method or combination of (display panel, sensor) that reside in methods that will be used to the mild environment conditions to confirm the reliability of the determine that the components can permanently installed equipment satisfactorily perform to those such that following a seismic conditions. Westinghouse has event the instrument will maintain determined that aging does not have its required accuracy.

a significant effect on the ability of the equipment to perform following a plant design basis earthquake.

Exelon has reviewed the documents and found acceptable. Reference Westinghouse documents EQ-QR-269, WNA-TR-03149-GEN for description of specific methods.

MCR Display Byron Station specific calculation (BYR14-056 -

Seismic Qualification of Weschler Indicator VX-252) includes a Report of Qualification Testing performed by the vendor (Weschler Instruments).

The methods used by the vendor to qualify the readout display follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument. For temperature and humidity qualification of the displays IEEE 344-2004, IEEE 323-2003, NRC Regulatory Guides 1.100, Revision 3; 1.209, March 2007; and EPRI TR-107330 guidance was followed. The habitability of the MCR will be maintained as part of the FLEX strategies, and therefore, the Page 9 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status readout display in the MCR will not be subject to harsh environmental or radiological conditions.

Shock and Vibration SFPIS pool side brackets were analyzed for Safe Shutdown Earthquake design requirements per NRC order EA 051 and NEI 12-02 guidance. As provided by the NRC Order EA 051, the NEI 12-02 guidance and as clarified by the NRC interim staff guidance, the probe, coaxial cable, and the mounting brackets are "inherently resistant to shock and vibration loadings." As a result, no additional shock and vibration testing is required for these components. SFPIS pool side brackets for both the primary and backup Westinghouse SFP measurement channels will be permanently installed and fixed to rigid refuel floors, which are Seismic Category 1 structures. The SFPI system components, such as level sensor and its bracket, display enclosure and its bracket, were subjected to seismic testing, including shock and vibration test requirements. The results for shock and vibration tests were consistent with the anticipated shock and vibration expected to be seen by mounted equipment. The level sensor electronics are enclosed in a NEMA-4X housing. The display electronics panel utilizes a NEMA-4X rated stainless steel housing as well. These housings will be mounted to a seismically qualified Page 1 0 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status wall and will contain the active electronics, and aid in protecting the internal components from vibration induced damage.

Reference Westinghouse reports WNA-DS-02957, WNA-TR-04757-GEN for shock and vibration.

b) The seismic adequacy of the SFPIS (all components) is demonstrated by vendor testing and analysis in accordance with below listed standards:

  • IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class lE Electrical Equipment for Nuclear Power Generating Stations
  • IEEE-323-1974, Standard for Qualifying Class lE Equipment for Nuclear Power Generating Stations
  • Calculation BYR10-109, Seismic Qualification of Instrument Mounting Details Associated with Plant Process Computer Replacement
  • BYR14-056 - Seismic Qualification of Weschler Indicator VX-252 Seismic adequacy of the level sensor probe supporting bracket Page II of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status within the SFP area was demonstrated by analysis as discussed in response to RAI-3, Ref. 4 of the Overall Integrated Plan Open Items table.

c) Westinghouse has seismically qualified the SFPI instrument and its components. CN-PEUS-13-24 describes Pool-side Bracket Seismic Analysis, EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 describe remaining seismic qualifications of the instrument components. With the instrument being seismically qualified and installed as described in part (b) of this RAI response (RAI-4, Ref.

4 of Overall Integrated Plan Open Items table), including the readout display in the main control room, the instrument is assured to maintain reliable and accurate indication when required. Westinghouse report WNA-CN-00301-GEN and Byron Engineering Change 392445 provide the channel accuracy from measurement to display.

7 RAI Question:

Complete.

(RAI-6, Provide the following:

a) A description of how the two (Addressed in Reference 7)

Ref.4) channels of the proposed level measurement system meet this requirement so that the potential for a common cause event to adversely affect both channels is minimized to the extent practicable.

b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and Page 12 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status 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.

8 RAI Question: Complete.

(RAI-6, Provide the following: Response for part (a):

Ref 4) a) A description of the electrical ac power sources and capabilities for (Addressed in Reference 7) the primary and backup channels. Response for (b):

b) Please provide the results of the calculation depicting the battery The Westinghouse Report, WNA-CN-backup duty cycle requirements 00300-GEN, provides the results of the demonstrating that its capacity is calculation depicting the battery backup sufficient to maintain the level duty cycle. This calculation indication function until offsite demonstrates that battery capacity is resource availability assured. 4.22 days to maintain the level indicating function to the display location, located in the Electrical Penetration Area at Byron Station. The calculation also determines that the battery will last for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assuming the remote display in the MCR consumes a maximum of 0.064 Amps.

Byron Station is crediting the MCR display as the primary display. The remote display vendor (Weschler's) data sheet indicates the readout display is self-contained. It will be calibrated to consume no more than 0.022 Amps, which bounds the 0.064 Amps assumed in the Westinghouse calculation above.

Therefore, the Byron Station readout display of level indication in the MCR will be available for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation. The results of the calculation meet the NEI 12-02 requirements.

9 RAI Question: Started.

(RAI-7, Provide the following: a) The Westinghouse documents Ref.4) a) An estimate of the expected WNA-CN-00301 (Attachment 2, instrument channel accuracy item 17) and WNA-DS-02957-performance under both (a) normal GEN (Attachment 2, item 1)

Page 13 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status SFP level conditions (approximately describe the channel accuracy Levell or higher) and (b) at the under both (a) normal SFP level beyond design-basis conditions (i.e., conditions and (b) at the Beyond radiation, temperature, humidity, Design Basis (BDB) conditions post-seismic and post-shock that would be present if SFP level conditions) that would be present if were at Level 2 and Level 3 the SFP level were at the Level2 and datum points. Each instrument Level3 datum points, channel will be accurate to within b) A description of the methodology +/-3"during normal spent fuel pool that will be used for determining the level conditions. The instrument maximum allowed deviation from the channels will retain this accuracy instrument channel design accuracy after BDB conditions, in that will be employed under normal accordance with the above operating conditions as an Westinghouse documents. The acceptance criterion for a calibration same channel accuracy procedure to flag to operators and to requirements are applicable to technicians that the channel requires the readout display in the main adjustment to within the normal control room as the display condition design accuracy. enclosures are installed locally in the Electrical Penetration Area.

Byron Station has analyzed the channel accuracy to the main control room indicators in the Engineering Change package 392445, Revision 0 for the normal operating conditions and determined that the displayed level is accurate to within +/-5.06".

Byron is in the process of analyzing the channel accuracy to the main control room indicators for the BDB conditions.

Byron will complete the analysis by September 30, 2014. At this time Byron station believes the accuracy will be within the channel accuracy requirements of the Order (+/-1 foot) for BDB conditions.

b) The Westinghouse document WNA-TP-04709-GEN describes the methodology for routine testing/calibration verification and calibration methodology. This document also specifies the required accuracy criteria under Page 14 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status normal operating conditions.

Byron Station calibration and channel verification procedures will follow the guidance and criteria provided in this document.

Instrument channel calibration will be performed if the level indication reflects a value that is outside the acceptance band established in the Byron Station calibration and channel verification procedures.

Instrument channel loop accuracy and set point deviation/error are determined using the Byron Station Engineering Standard NES-EIC-20.04 for safety related instruments. The methodology used to determine the set point deviation in this standard is consistent with ANSI/ISA-67.04.01-2000. Per this methodology, since drift value was not specified by the vendor, a default random drift value of

+/-1% of span (or +/-1% of full scale, for conservatism) for mechanical components were assigned. A setting tolerance of twice the reference accuracy, which is a typical value, was applied to the indicator to yield an overall setting tolerance of +/- 2% of full scale. This value will be used for the calibration procedure being developed for this instrument loop. The resultant non-negligible terms (Reference Accuracy, Drift, Readability, Measurement and Test Equipment Effect, and Setting Tolerance) are all random terms, Page 15 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status and will be combined using the Square Root Sum of Squares (SRSS) methodology given in Engineering Standard NES-EIC-20.04. Thus, the maximum deviation introduced by the indicator, in percent of full span, is computed.

Calibration will be performed once per refueling cycle for Byron Station. Per Westinghouse document WNA-TP-04709-GEN calibration on a SFP level channel is to be completed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g.

25%). This is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation.

10 RAI Question: Started.

(RAI-8, Provide the following: a) Westinghouse calibration Ref.4) a) A description of the capability and procedure WNA-TP-04709-GEN provisions the proposed level and functional test procedure sensing equipment will have to WNA-TP-04613-GEN describe enable periodic testing and the capabilities and provisions of calibration, including how this SFPI periodic testing and capability enables the equipment to calibration, including in-situ testing. Westinghouse calibration be tested in-situ.

and functional test procedures b) A description of how such testing are acceptable for Byron.

and calibration will enable the However, Byron must use a conduct of regular channel checks of different in-situ test methodology each independent channel against to accommodate Byron's low the other, and against any other profile bracket installation.

permanently-installed SFP level Westinghouse provided letter instrumentation. LTR-SFPIS-14-55, Revision 0 c) A description of how functional (SFPIS 2 Point Verification checks will be performed, and the Methodology) describing the new frequency at which they will be in-situ test methodology to conducted. Describe how calibration accommodate Byron's low profile tests will be performed, and the bracket. Exelon has reviewed the frequency at which they will be letter and found acceptable.

conducted. b) The level displayed by the Page 16 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status d) A discussion as to how these channels will be verified per the surveillances will be incorporated Byron Station administrative and into the plant surveillance program. operating procedures, as e) A description of the preventive recommended by Westinghouse maintenance tasks required to be vendor technical manual WNA-performed during normal operation, G0-00127-GEN. If the level is and the planned maximum not within the required accuracy per Westinghouse recommended surveillance interval that is tolerance in WNA-TP-94709-necessary to assure that the GEN, channel calibration will be channels are fully conditioned to performed.

accurately and reliably perform their functions when needed. c) Functional checks will be performed per Westinghouse functionality test procedure WNA-TP-04613-GEN at the Westinghouse recommended frequency. Calibration tests will be performed per Westinghouse calibration procedure WNA-TP-04709-0EN at the Westinghouse recommended frequency.

d) Byron Station has developed calibration, functional test, and channel verification procedures per Westinghouse recommendations to ensure reliable, accurate and continuous SFPI functionality. Procedures (calibrations, functional checks, preventive maintenance, etc.) will be incorporated into plant programs per Exelon configuration control procedure CC-AA-103 (Configuration Change Control for Permanent Physical Plant Changes). This procedure controls implementation of engineering based configuration changes at Byron Station. As part of this process, Byron Station Departments review the Configuration Change content to determine the impact on their department activities, procedures and documentation. These reviews are documented in the associated modification package.

Page 17 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status Actions needed to implement the required changes to activities, to procedures and to documentation are tracked to completion in the Exelon Action Tracking system.

Due dates are assigned in the Action Tracking system.

e) Byron Station will develop preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-GO-00127-G EN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed by September 12, 2014.

11 RAI Question: Complete.

(RAI-9, Please provide the following: (Addressed in Reference 6)

Ref.4) a) The specific location for each of the primary and backup instrument channel displays.

b) If the primary and backup display 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.

Page 18 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Overall Integrated Plan Open Items 01# Description Status 12 RAI Question:

Complete.

(RAI-10, Please provide a description of the (Addressed in Reference 7)

Ref.4) standards, guidelines and/or criteria that will be utilized to develop procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments.

13 RAI Question:

Complete.

(RAI-11, Provide the following:

Ref.4) a) Further information describing the (Addressed in Reference 7) maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified 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 NEI 12-02 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 90 days.

Page 1 9 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete.

(RAI 1, Ref. 5) Please provide the (Addressed in Reference 7) results of the calculation used to determine the water elevation necessary for the pump's required NPSH to confirm that Level 1 has been adequately identified.

2 RAI Question: Complete.

(RAI-4, Ref. 5) For RAI 3(a) The following Westinghouse documents provide the analyses above, provide the used to verify the design criteria and describe the analyses used to methodology for seismic testing of the SFP instrumentation verify the design and electronics units, inclusive of design basis maximum criteria and seismic loads and hydrodynamic loads that could result from methodology for pool sloshing and other effects that could accompany such seismic testing of seismic forces:

the SFP a) CN-PEUS-13-24 Pool-side Bracket Seismic Analysis instrumentation b) LTR-SEE-II-13-47, WNA-TR-03149-GEN Sloshing and the Analysis electronics units, c) EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 including design Seismic Qualification of other components of SFPI basis maximum No equipment failures were noted as a result of seismic test seismic loads and runs. Seismic test data has been documented in the seismic the hydrodynamic test reports, referenced above.

loads that could result from pool Byron Station specific calculations BYR10-109 - Seismic sloshing or other Qualification of Instrument Mounting Details Associated with effects that could Plant Process Computer Replacement, and BYR14-056 -

accompany such Seismic Qualification of Weschler Indicator VX-252, will seismic forces. address the seismic qualification of the main control room indicators. The design criteria used in this calculation satisfies the requirements to withstand a SSE and will meet the Byron Station safety related installation requirements for mounting the readout displays in the main control room.

3 RAI Question: Complete.

(RAI-5, Ref. 5) For each of the (Addressed in Reference 7) mounting attachments Page 20 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 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/equipm ent.

4 RAI Question: Started.

(RAI-7, Ref. 5) For RAI #6 above, provide the results Below is a summary of the test conditions used by from the selected Westinghouse to qualify the SFPIS. These test conditions are methods, tests documented in Westinghouse documents EQ-QR-269, WNA-and analyses used TR-03149-GEN, EQ-TP-354, WNA-DS-02957 AND LTR-to demonstrate the SFPIS-13-35. Environmental Conditions for SFPIS Components installed in the Spent Fuel Pool Area at Byron qualification and Station are bounded by below test conditions, except for reliability of the radiation TID 12" above top of fuel rack for beyond design installed basis conditions (BDB). The BDB radiation TID, 12" above equipment in top of fuel rack for Byron is 4.E07 R y, per calculation BYR13-accordance with 051 NEI 12-02 Spent Fuel Pool Doses. The BDB radiation the Order value to which the Westinghouse equipment is qualified to is requirements. 1.E07 R y, per Section 5.1.1 of WNA-TR-03149-GEN. The radiation value of 4.E07 R y is higher than 1.E07 R y to which Westinghouse qualified the instrument to. However, this value of 4.E07 R y is applicable only when the water is at Level 3.

At Level 2 the TID reduces to 2.E07 R y and it further reduces to 8.E06 at Level 1 and above. With SFP water level at Level 3 the only components of SFPI that are exposed to high radiation are the stainless steel probe and the stainless steel anchor. The materials with which the probe and the anchor are manufactured are resistant to radiation effects. The stainless steel anchor and stainless steel probe can withstand 40 year dose. Westinghouse updated the design specification (WNA-DS-02957-GEN) and LTR-SFPIS-13-35, Revision 1 documentation to include the above technical justification.

Environmental Conditions for SFPIS Components in the Spent Fuel Pool Area Level sensor probe, coax coupler and connector assembly, launch plate and pool side bracket assembly, coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Page 21 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Parameter Normal BDB Temperature 50-140°F 212°F Pressure Atmospheric Atmospheric Humidity 100% (saturated 0-95% RH steam)

Radiation TID y 1E03 Rads 1E07 Rads (above pool)

Radiation TID y 1E09 Rads (12" above 1E07 Rads (probe and top of fuel weight only) rack)

Environmental Conditions Outside of the Spent Fuel Pool Area The level sensor transmitter and bracket, electronics display enclosure and bracket are designed and qualified to operate reliably in the below specified environmental conditions.

BDB (Level Parameter Normal BDB Sensor Electronics Only)

Temperature 50-120°F 140°F 140°F Pressure Atmospheri Atmospheri Atmospheric C C Humidity 0-95% 0-95%

0-95% RH (non- (non-condensing) condensing)

Page 22 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 Duration 3 days 3 days 3 days Radiation TID 5 1E03 R y 5 1E03 R 5 1E03 R Y

Byron Station specific calculation (BYR14-056 - Seismic Qualification of Weschler Indicator VX-252) describes the results of the qualification testing of the MCR readout display to the design basis temperature, humidity, and vibration to demonstrate its reliability. The display was also tested to demonstrate that it performed accurately under extreme heat and humidity conditions.

Thermal and Radiation Aging organic components in SFP area Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-03149-GEN provide thermal and radiation aging program details for the SFPI components. Westinghouse completed their thermal and radiation aging testing programs to qualify the SFPI components to 1.25 years. Exelon has reviewed the documents and found acceptable.

Additionally, Westinghouse is continuing their aging tests to age the system components to 10 years. These tests are projected to be completed towards end of Summer 2014. Final test reports are scheduled to be provided to Exelon by September 4, 2014. Exelon will complete the test report reviews by September 30, 2014.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirms that the SFPIS meets the seismic requirements of the vendor's design specification. Westinghouse's design specification satisfies the Byron Station installation requirements to withstand a SSE.

Vibration Justification As specified in the response for RAI-4, Ref. 4 in the Overall Integrated Plan Open Items table, components of the system (i.e., bracket, transmitter enclosure, display enclosure, and readout display in the MCR) will be permanently installed to meet the requirements to withstand a SSE and will meet the Byron Station safety related installation requirements.

Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were Page 23 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification The sloshing calculation performed by Westinghouse was reviewed for a design basis seismic event and found acceptable. Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

5 RAI Question: Complete.

(RAI-13, Ref. Provide a list of (Addressed in Reference 7)

5) the procedures addressing operation (both normal and abnormal response),

calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP instrumentation.

Provide a brief description of the specific technical objectives to be achieved within each procedure.

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, 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 028)

Page 24 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 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-13-156).
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 4, 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-13-114).
7. Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 28, 2014 (RS-14-018).

Page 25 of 26

Byron Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 ATTACHMENT 1 Schematic of the Level Sensor with Mechanical Attachment Points Page 26 of 26

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