RS-14-347, Revised Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
| ML14342A965 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 12/08/2014 |
| From: | Kaegi G Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-14-347 | |
| Download: ML14342A965 (8) | |
Text
ANNIP- Exelon Generation Order No. EA-12-051 RS-14-347 December 8, 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:
Revised Report of Full Compliance with 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, 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. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7,2013
- 7. Exelon Generation Company, LLC letter to NRC, Response to Request For Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051),
dated July 3, 2013
- 8. 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)
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 2
- 9. 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)
- 10. Exelon Generation Company, LLC 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), dated August 28, 2014 (RS-14-196)
- 11. 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
- 12. Exelon Generation Company, LLC Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated December 5, 2014 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed 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 (01P) pursuant to Section IV, Condition C. Reference 2 endorsed 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 01P.
Reference 1 required submission of a status report at six-month intervals following submittal of the 01P. References 8, 9, and 10 provided the first, second, and third six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Byron Station.
The purpose of this letter is to provide the report of full compliance with the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Byron Station, Units 1 and 2. This letter is also submitted to correct an administrative error identified in Reference 12 and replace Reference 12 in its entirety.
Byron Station has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Byron Station 01P Open Items have been addressed and closed as documented in References 8, 9, and 10, and are considered complete pending NRC Closure. The information provided herein documents full compliance for Byron Station, Units 1 and 2 with Reference 1.
EGC response to the NRC 01P Requests for Additional Information (0IP RAls), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAls) identified in References 6 and 11 have been addressed and closed as documented in References 7, 8, 9, and 10, and below, and are considered complete pending NRC Closure. The following table provides completion references for each NRC 01P RAI and ISE RAI.
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 3 01P RAI Nos. la, 2, 5, 10, 11 Reference 9 01P RAI No. lb Reference 7 01P RAI Nos. 3, 4, 6 Reference 10 01P RAI Nos. 7, 8 With this submittal as provided below 01P RAI No. 9 Reference 8 ISE RAI Nos. 1,5, 12 Reference 9 ISE RAI No. 4 Reference 10 ISE RAI No. 7 With this submittal as provided below Note: ISE RAls are not duplicated in the table above if previously issued as 01P RAls in Reference 6.
It is EGC's understanding that the NRC Site Audit Report contains no remaining audit open items regarding Byron Station compliance with NRC Order EA-12-051.
The table below documents the completion of the final remaining open actions as identified in Reference 10. 01P Item 13 in the table below provides a revised response to RAI No. 11.
As stated above, EGO provides the response for the following items and considers them to be complete for Byron Station.
Item Description Reference ISE Item 4 (RAI-7, Westinghouse documents EQ-QR-269, EQ-TP-Complete Ref. 11): 354, WNA-TA-03149-GEN (Attachment 2, item 6)
For RAI No. 6 above, provide thermal and radiation aging program Byron Station please provide the details for the SFPI components. Westinghouse has completed results for the completed their thermal and radiation aging receipt, review, selected methods, testing programs to qualify the SFPI components and acceptance tests and analyses to 1.25 years. Exelon has reviewed the of WEC 10-yr utilized to documents and found them acceptable. aging reports.
demonstrate the qualification and Additionally, Westinghouse has completed their reliability of the aging tests to age the system components to 10 installed equipment in years. The tests were completed satisfactorily for accordance with the Byron's configuration and the final test reports Order requirements.
were reviewed and found acceptable by Exelon.
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 4 01P Item 9 (RAI-7, a) The Westinghouse documents WNA-CN-Complete Ref. 6): 00301 (Attachment 2, item 17) and WNA-DS-a) An estimate of 02957-GEN (Attachment 2, item 1) describe Byron Station the expected the channel accuracy under both (a) normal has completed instrument channel SFP level conditions and (b) at the Beyond the evaluation of accuracy Design Basis (BDB) conditions that would be the completed performance under present if SFP level were at Level 2 and Level uncertainty both (a) normal SFP 3 datum points. Each instrument channel will calculations and level conditions be accurate to within +/-3" during normal spent channel (approximately Level fuel pool level conditions (local display). The accuracy 1 or higher) and (b) instrument channels will retain this accuracy requirements to at the beyond design- after BDB conditions, in accordance with the the Main Control basis conditions (i.e., above Westinghouse documents. The same Room for both radiation, channel accuracy requirements are applicable design basis temperature, to the readout display in the main control and BDB humidity, post-seismic room as the display enclosures are installed conditions.
and post-shock locally in the Electrical Penetration Area.
conditions) that would Byron Station has analyzed the channel be present if the SFP accuracy to the main control room indicators level were at the in the calculation BYR-14-137 for the normal Level 2 and Level 3 and BDB operating conditions and determined datum points, the displayed level is accurate to within +/-5".
The accuracy is within the channel accuracy requirements of the Order (+/-1 foot) for BDB conditions and meets the NEI 12-02 requirements.
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 5 01P Item 13 (RAI-11, Planned compensatory actions for unlikely Complete Ref. 6): extended out-of-service events are summarized c) A description of as follows: Byron Station what compensatory Required Compensatory revised the actions are planned in Channel(s) Restoration Action if compensatory the event that one of Out-of- Action Required action plan the instrument Service Restoration requirements channels cannot be Action not applicable to restored to functional completed conditions status within 90 days. within where the Specified Time instrument 1 Restore Immediately channel(s) are channel to initiate action not restored to functional in accordance functional status status within with Note within the 90 days (or if below specified time, channel as specified in restoration not the Note. The expected condition will be within 90 days, entered into the then proceed corrective action to program in lieu Compensatory of a report to Action) PORC.
2 Initiate action Immediately within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> initiate action to restore one in accordance channel to with Note functional below status and restore one channel to functional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Note: Initiate an Issue Report to enter the condition into the Corrective Action Program.
Identify the equipment out of service time is greater than the specified allowed out of service time, develop and implement an alternate method of monitoring, determine the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 6 01P Item 10 (RAI-8, Byron Station has developed preventive Complete Ref. 6) maintenance tasks for the SFPI per e) A description of Byron Station Westinghouse recommendation identified in the what preventive has completed technical manual WNA-G0-00127-G EN maintenance tasks the development (Attachment 2, item 19) to assure that the are required to be of the preventive channels are fully conditioned to accurately and performed during maintenance reliably perform their functions when needed.
normal operation, and tasks.
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.
MILESTONE SCHEDULE ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Submit Responses to RAls July 5, 2013 Submit 6 Month Updates:
Update 1 August 28, 2013 Update 2 February 28, 2014 Provide Final Safety Evaluation (SE) Information March 31, 2014 Update 3 August 28, 2014 Modifications:
Conceptual Design 302012 Begin Detailed Design Engineering 102013 Issue Exelon Fleet contract to procure SFPI 202013 Equipment Complete and Issue SFPI Modification Package 202014 Begin Installation 202014 Complete SFPI Installation and Put Into Service October 3, 2014
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 7 ORDER EA-12-051 COMPLIANCE ELEMENTS
SUMMARY
The elements identified below for Byron Station, as well as the site overall integrated plan response submittal (Reference 5), the 6-Month Status Reports (References 8, 9, and 10), and any additional docketed correspondence, demonstrate compliance with Order EA-12-051.
IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Byron Station has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.
INSTRUMENT DESIGN FEATURES - COMPLETE The design of the instruments installed at Byron Station complies with the requirements specified in the Order and described in NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051." The instruments have been installed in accordance with the station design control process.
The instruments have been arranged to provide reasonable protection against missiles.
The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their design accuracy following a power interruption and are designed to allow for routine testing and calibration.
The instrument display is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.
PROGRAM FEATURES - COMPLETE Training for Byron Station, Units 1 and 2 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.
Operating and maintenance procedures for Byron Station have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the instruments are maintained at their design accuracy.
U.S. Nuclear Regulatory Commission Revised Report of Full Compliance with Order EA-12-051 December 8, 2014 Page 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 8111 day of December 2014.
Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC 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 Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRC Ms. Jessica A. Kratchman, NRR/JLD/JPSB, NRC Mr. Joel S. Wiebe, NRR/DORULIDL3-2, NRC Mr. John Hughey, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety