RS-15-027, Fourth 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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Fourth 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)
ML15058A622
Person / Time
Site: Clinton Constellation icon.png
Issue date: 02/27/2015
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-027
Download: ML15058A622 (36)
v • d • e


Text

ANP- Exelon Generation, Order No. EA-12-051 RS-15-027 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Fourth 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-13-029)
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-13-116)
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 019)
8. 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-14-197)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 27, 2015 Page 2

9. NRC letter to Exelon Generation Company, LLC, Clinton Power Station, Unit 1 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 (TAO No. MF0791), dated November 15, 2013 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGO). Reference 1 was immediately effective and directs EGO 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 EGO initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Clinton Power Station, Unit 1 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, 7 and 8 provided the first, second, and third six-month status reports, respectively, pursuant to Section IV, Condition 0.2, of Reference 1 for Clinton Power Station.

The purpose of this letter is to provide the fourth 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 9.

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 27th day of February 2015.

Respectfully submitted,

/0 Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Clinton Power Station, Unit 1 Fourth 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 February 27, 2015 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Clinton Power Station, Unit 1 NRC Project Manager, NRR Clinton Power Station, Unit 1 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. Blake Purnell, NRR/DORL/LPL3-2, NRC Mr. John Boska, NRR/JLD/MSD, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (32 pages)

Clinton Power Station, Unit 1 Fourth 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 Clinton Power Station, Unit 1, (CPS) 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 Third 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 Third Six-Month status report (Reference 8), and are current as of February 27, 2015.

  • SFPLI Equipment has been delivered
  • Installation has started 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 NRC Order implementation date.

Revised Target Completion Activity Target Milestone Date Status Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls July 5, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete Page 1 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Revised Target Completion Activity Target Milestone Date Status Completion Date Complete with Update 4 February 27, 2015 this submittal Provide Final Safety Evaluation September 30, 2014 Complete (SE) Info Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Engineering 402013 Complete Design Complete and Issue SFPI 302014 Started 102015 Modification Package Begin Installation 402014 Started Complete SFPI Installation and 202015 Not Started Put Into Service 4 Changes to Compliance Method There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation CPS expects to comply with the NRC Order implementation date and no relief/relaxation is required at this time.

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

Page 2 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete.

(Ref. Continuous (Addressed in Reference 1)

1) level indication will be 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.

1 RAI Question: Complete (RAI a) For Level 1, (Addressed in Reference 4)

-1, specify how Ref. the identified

3) location represents the higher of the two points described in the NEI 12-02 guidance for this level.

b) A clearly labeled sketch depicting the elevation view of the proposed Page 3 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 typical mounting arrangement for the portions of 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 racks. 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.

Page 4 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 2 RAI Question: Complete (RAI Please provide

_2 a clearly

' labeled sketch Provided in the attached sketch "NRC RAI Question 1". NOTE: The Ref

' or marked-up method of grounding the bracket assembly may deviate from this

3) plant drawing sketch when further installation/design details are developed.

of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/place ment 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.

3 RAI Question: Completed with this submittal (RAI Please provide a) All SFPIS equipment will be designed in accordance with the the following: Clinton Power Station (CPS) Safe Shutdown Earthquake (SSE) design a) The design Ref. . requirements.

criteria that will

3) be used to The vendor, Westinghouse, evaluated the structural integrity of the estimate the mounting brackets in calculation CN-PEUS-14-13. The GTSTRUDL total loading model was used by Westinghouse to calculate the stresses in the on the mounting bracket assembly, considers load combinations for the dead load, live device(s), load and seismic load on the bracket. The reactionary forces including static calculated from these loads became the design inputs to design the weight loads mounting bracket anchorage to the refuel floor to withstand a Safe and dynamic Shutdown Earthquake (SSE).

loads.

Describe the methodology Page 5 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 that will be Seismic used to estimate the The seismic loads are obtained from the Clinton Power Station total loading, response spectra curves (Reference Updated FSAR Chapter 3 inclusive of Figures 3.7 for CPS). The following methodology was used in design basis determining the stresses on the bracket assembly:

maximum seismic loads

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

loads that could result

sloshing or other effects

  • Modal responses are combined using the Ten Percent Method that could per U.S. NRC Regulatory Guide 1.92, Revision 1, "Combining Modal accompany Responses and Spatial Components in Seismic Response Analysis".

such seismic This method is endorsed per Chapter 3 of the Updated FSAR Revision forces. 11 for CPS.

b) A description of

  • The seismic loads for each of the three directions are the manner in combined by the Square Root of the Sum of Squares (SRSS) Method.

which the level sensor (and

  • Sloshing analysis is performed to obtain liquid pressure and its stilling well, if impact on bracket design.

appropriate) will be

  • The seismic results are combined with the dead load results attached to the and the hydrodynamic pressure results in absolute sum. These refueling floor combined results are compared with the allowable stress values.

and/or other support Sloshing structures for Sloshing forces were obtained by analysis. The TID-7024, Nuclear each planned Reactors and Earthquakes, 1963, by the US Atomic Energy point of attachment of Commission, approach has been used to estimate the wave height the probe and natural frequency. Horizontal and vertical impact force on the assembly. bracket components will be calculated using the wave height and Indicate in a natural frequency obtained using TID-7024 approach. Using this schematic the methodology, sloshing forces are calculated and added to the total portions of the reactionary forces that would be applicable for bracket anchorage level sensor that will serve design. The analysis also determines that the level probe can as points of withstand a credible design basis seismic event. During the design attachment for basis event, the SFP water level is expected to rise and parts of the mechanical/mo level sensor probe are assumed to become submerged in water. The unting or load impact due to the rising water and submergence of the bracket electrical components have also been considered for the overall sloshing connections.

impact. Reliable operation of the level measurement sensor with a c) A description of submerged interconnecting cable has been demonstrated by analysis the manner by of previous Westinghouse testing of the cable, and the vendor's cable which the qualification. Boron build-up on the probe has been analyzed to mechanical Page 6 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 connections determine the potential effects on the sensor.

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

SFP

a. CN-PEUS-14-13 Seismic Analysis of the SFP Mounting structures so as to support bracket at Clinton Power Station the level b. LTR-SEE-II-13-47, WNA-TR-03149-G EN Sloshing Analysis sensor assembly. c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification of other components of SFPI Part a)

Clinton Power Station specific calculations for mounting details Complete associated with Transmitter and SFPLI Monitors have been completed Part b)

Complete as part of the Engineering Change (EC 392333) package for the Part c) - modification. The methods used in the calculations followed IEEE Complete Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, is 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. Note that the connection to station ground may deviate from this sketch as the design details are further established in the EC 392333.

c) The bracket assembly that supports the sensor probe and launch plate will be mechanically connected to the Fuel Building structure (see Attachment 1). The mechanical connection consists of four concrete expansion anchors that will bolt the bracket assembly to the Fuel Building structure via the base plate. The concrete expansion anchors are designed to withstand an SSE and will meet the CPS seismic related installation requirements. The qualification details of the bracket will be provided in Westinghouse's Pool-side bracket Seismic Analysis and the qualification of the anchorage to the floor is provided in the supporting CPS specific calculation performed as part of the Engineering Change modification.

4 RAI Question: Completed with this submittal (RAI Please a) Beyond Design Basis Environment Westinghouse qualified

_4, provide the the components (probe, connector, cable) of the Spent Fuel Pool Ref. following: Instrumentation System (SFPIS) located in the SFP area to the

3) a) A beyond design basis environment. Components of the system were description of subjected to beyond design basis conditions of heat and humidity, method or thermal and radiation aging mechanisms. This testing confirmed combination functionality of these system components under these beyond design of methods basis environmental conditions. Westinghouse performed testing to Page 7 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 that will be ensure aging of the components in the SFP area will not have a applied to significant effect on the ability of the equipment to perform following a demonstrate plant design basis earthquake. Exelon has reviewed the documents the reliability and found them acceptable. Reference Westinghouse documents EQ-of the permanently TP-351, WNA-TR-03149-GEN, and EQ-TP-354 for description of installed specific qualification methods.

equipment Mild Environment Westinghouse qualified the system components under beyond- (display panel, sensor) that reside in the mild environment conditions design-basis to determine that the components can satisfactorily perform to those (BDB) ambient conditions. Westinghouse has determined that aging does not have a temperature, humidity, significant effect on the ability of the equipment to perform following a shock, plant design basis earthquake. Exelon has reviewed the documents vibration, and and found them acceptable. Reference Westinghouse documents EQ-radiation QR-269, WNA-TR-03149-GEN for description of specific methods.

conditions. The habitability of the monitor display locations will be maintained as b) A part of the FLEX strategies, and therefore, the readout display in the description of Auxiliary and Control Buildings will not be subject to harsh the testing environmental or radiological conditions.

and/or analyses that Shock and Vibration SFPIS pool side brackets are analyzed for Safe will be Shutdown Earthquake design requirements per NRC order EA-12-051 conducted to and NEI 12-02 guidance. As provided by the NRC Order EA-12-051, provide the NEI 12-02 guidance and as clarified by the NRC interim staff assurance guidance, the probe, coaxial cable, and the mounting brackets are that the "inherently resistant to shock and vibration loadings." As a result, no equipment will perform additional CPS site specific shock and vibration testing is required for reliably under these components. SFPIS pool side brackets for both the primary and the worst-case backup Westinghouse SFP measurement channels are being credible permanently installed and fixed to rigid refuel floors, which are Seismic design basis Category 1 structures. The SFPI system components, such as level loading at the sensor and its mounting bracket were subjected to seismic testing, location where including shock and vibration test requirements. The results for shock the equipment and vibration tests were consistent with the anticipated shock and will be vibration expected to be seen by mounted equipment. The level mounted.

Include a monitoring electronics is enclosed in a NEMA-4X housing which is a discussion of seismic rated stainless steel housing as well. These housings will be this seismic mounted to a seismically qualified wall and structure and will contain reliability the active electronics, and aid in protecting the internal components demonstration from vibration induced damage.

as it applies to (i) the level Reference Westinghouse reports WNA-DS-02957, WNA-TR-04757-sensor GEN for shock and vibration.

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

control boxes, electronics, or IEEE 344-2004, IEEE Recommended Practice for Seismic Page 8 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 read-out and Qualification of Class lE Electrical Equipment for Nuclear Power re- Generating Stations transmitting devices that

  • A calculation which will be prepared in support of the EC for sensor to the mounting the SFPLI monitoring equipment (Pool Side Bracket, plant Transmitter and Display Enclosure).

operators or Seismic adequacy of the level sensor probe supporting bracket within emergency the SFP area was demonstrated by analysis as discussed in response responders.

c) A to RAI-3.

description of 0 Westinghouse has seismically qualified the SFPI instrument the specific and its components. A CPS specific calculation and EQ analysis has method or been performed which supports the Pool-side Bracket Seismic combination Analysis and EQ requirements. With the i nstrument being seismically of methods that will be qualified and installed as described in RAI 2 response, including the used to monitor display in the Auxiliary and Control Building, the instrument is confirm the assured to maintain reliable and accurate indication when required.

reliability of Westinghouse report WNA-CN-00301-GEN and Clinton Power Station the EC 392333, provides the details of the equipment accuracy from permanently measurement to display.

installed equipment such that following a seismic event the instrument will maintain its required accuracy.

Part a)

Complete Part b)

Complete Part c)

Complete 5 RAI Question: Completed with this submittal (RAI Please provide a) The two channel locations of the spent fuel probe and the following: mounting meet the requirements of NEI 12-02 section 3.2 Ref. a) A Arrangement. More specifically, to ensure adequate channel description of

3) how the two separation, one level sensor probe is being mounted approximately Page 9 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 channels of the on the northwest corner of the pool while the other level sensor probe proposed level is being mounted near the center of the east wall of the pool. This measurement means the two level sensor probes are separated by a distance of system meet this approximately 34' which is a longer distance than the shorter requirement so dimension of the spent fuel pool as specified by NEI 12-02 guidance.

that the b) The information related to physical separation, is depicted in potential for a common cause the attached sketch NRC RAI Question 1, which shows the location of event to the probe and mounting brackets, cable routing for the two individual adversely transmitters, and the cable routing and location of the monitors in the affect both Auxiliary Building and the Control Building. The independent power channels is sources are described in the Clinton Power Station EC 392333 and minimized to consist of powering each train from a separate Motor Control Center.

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 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.

Part a)

Complete Part b)

Complete Page 10 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 6 RAI Question: Complete with this submittal (RAI Please provide a) A detailed description of the electrical AC power sources is

-6, the following: included in the EC 392333 Design Summary.

a) A Ref. b) The Westinghouse Report, WNA-CN-00300-GEN, provides the description

3) of the results of the calculation depicting the battery back-up duty electrical cycle. This calculation demonstrates that battery capacity is AC 4.22 days to maintain the level indication function to the power sources display. Therefore, the Clinton Power Station readout display and of level indication 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 capacities operation. The results of the calculation meet the NEI 12-02 for the primary and reqirements.

backup channels.

b) If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BDB event for the minimum duration needed, consistent with the plant Page 11 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 mitigation strategies for BDB external events (Order EA-12-049).

Complete 7 RAI Question: Started (RAI Please a) The Westinghouse documents WNA-CN-00301-G EN and provide the WNA-DS-02957-GEN describe the channel accuracy under both (a)

Ref. following: normal SFP level conditions and (b) at the Beyond Design Basis

3) a) An estimate (BDB) conditions that would be present if SFP level were at Level 2 of the and Level 3 datum points. Each instrument channel will be accurate to expected instrument within +/-3"during normal spent fuel pool level conditions. The channel instrument channels will retain this accuracy after BDB conditions, in accuracy accordance with the above Westinghouse documents. This value is performance within the channel accuracy requirements of the Order (+/-1 foot).

under both (a) b) The Westinghouse document WNA-TP-04709- describes the normal SFP level methodology for routine testing/calibration verification and calibration conditions methodology. This document also specifies the required accuracy (approximatel criteria under normal operating conditions. Clinton Power Station y Level 1 or calibration and channel verification procedures will follow the guidance higher) and (b) and criteria provided in this document.

at the BDB conditions Instrument channel calibration will be performed if the level indication (i.e., radiation, reflects a value that is outside the acceptance band established in the temperature, Clinton Power Station calibration and channel verification procedures humidity, forecast for issuance in the first quarter of 2015.

post-seismic Instrument channel loop accuracy and set point deviation/error is and post-shock addressed in the EC 392333 as defined in Westinghouse document conditions) WNA-CN-00301-GEN.

that would be Functional check will be performed once per refueling cycle for Clinton present if the Power Station. Per Westinghouse document WNA-TP-04709-GEN SFP level were at the Level 2 calibration on a SFP level channel is to be completed within 60 days of and Level 3 a planned refueling outage considering normal testing scheduling datum points. allowances (e.g., 25%). This is in compliance with the NEI 12-02 b) A guidance for Spent Fuel Pool Instrumentation.

description of the methodology that will be used for determining the maximum allowed Page 12 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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.

Part a)

Complete Part b) Fcst Completion 3/31/15 8 RAI Question: Started (RAI Please a) Westinghouse calibration procedure WNA-TP-04709-GEN and

-8, provide the functional test procedure WNA-TP-04613-GEN describe the Ref. following: capabilities and provisions of SFPI periodic testing and calibration, a) A including in-situ testing. Clinton Power Station will use these 3) description of documents as the basis for performing the SFPI periodic testing and the capability and calibration.

provisions the b) The level displayed by the channels will be verified per the proposed Clinton Power Station administrative and operating procedures, as level sensing recommended by Westinghouse vendor technical manual WNA-GO-equipment will 00127-GEN. If the level is not within the required accuracy per have to enable periodic Westinghouse recommended tolerance in WNA-TP-04709-GEN, testing and channel calibration will be performed.

calibration, c) Functional checks will be performed per Westinghouse including how functionality test procedure WNA-TP-04613-GEN at the Westinghouse this capability Page 13 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 enables the recommended frequency. Calibration tests will be performed per equipment to Westinghouse calibration procedure WNA-TP-04709-GEN at the be tested in- Westinghouse recommended frequency. In accordance with Clinton situ. Power Station (CPS) maintenance and operating programs, CPS will b) A develop calibration, functional test, and channel verification description of how such procedures per Westinghouse recommendations to ensure reliable, testing and accurate and continuous SFPI functionality by March 31, 2015. This calibration will action will be tracked as part of the EC 392333 Design Attribute enable the Review process as defined in CC-AA-102, "Design Input and conduct of Configuration Change Impact Screening" procedure.

regular channel d) By March 31, 2015, CPS will develop preventive maintenance checks of tasks for the SFPI per Westinghouse recommendation identified in the each technical manual WNA-G0-00127-GEN to assure that the channels independent are fully conditioned to accurately and reliably perform their functions channel when needed. This action will be tracked as part of the EC 392333 against the Design Attribute Review process as defined in CC-AA-102, "Design other, and Input and Configuration Change Impact Screening" procedure.

against any other permanently-installed SFP level instrumentatio n.

c) A description of how functional checks will be performed, and the 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 Page 14 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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.

Part a) Fcst Complete 3/31/15 Part b) Fcst Complete 3/31/15 Part c) Fcst Complete 3/31/15 Part d) Fcst Complete 3/31/15 9 RAI Question: Replaced by Interim SE RAI #11 (RAI Please

_g, provide the Ref. following:

3) a) The specific location for Page 15 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 the primary and backup instrument channel displays.

b) If the primary and backup displays are not located in the main control room, please provide a description of the selected location(s) for the primary and backup

displays, including prompt accessibility to displays, primary and alternate route evaluation, habitability at display location(s),

continual resource availability for personnel responsible to promptly read displays, and provisions for communicatio ns with decision makers for the various SFP drain down scenarios and external events.

c) The reasons justifying why the locations selected will Page 16 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.

10 RAI Question: Replaced by Interim SE RAI #12 (RAI Please

-10, provide a Ref. description of

3) the 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 instrumentatio n, as well as storage and installation of portable instruments.

11 RAI Question: Started (RAI Please Response for a:

-11, provide the Page 17 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Ref. following: Performance tests (functional checks) and Operator performance

3) a) Further checks will be described in detail in the vendor operator's manual, and information the applicable information is planned to be contained in plant operating describing the procedures.

maintenance and testing Operational performance tests are planned to be performed program the periodically as recommended by the equipment vendor.

licensee will establish and Channel functional tests per plant procedures with limits established in implement to consideration of vendor equipment specifications are planned to be ensure that performed at appropriate frequencies established equivalent to or regular testing more frequently than existing SFPI.

and calibration is Manual calibration and performance checks are planned to be performed and performed in a periodic scheduled fashion with additional maintenance verified by on an as-needed basis when flagged by the system's automated inspection diagnostic testing features.

and audit to Channel calibration tests per maintenance procedures with limits demonstrate conformance established in considerati on of vendor equipment specifications are with design planned to be performed at frequencies established in consideration of and system vendor recommendations.

readiness SFPI channel/equipment maintenance/preventative maintenance and requirements.

testing program requirements to ensure design and system readiness Please include a description are planned to be established in accordance with Exelon's processes of your plans and procedures and in consideration of vendor recommendations to for ensuring ensure that appropriate regular testing, channel checks, functional that necessary tests, periodic calibration, and maintenance is performed (and channel available for inspection and audit). Subject maintenance and testing checks, program requirements are planned to be developed during the SFPI functional modification design process.

tests, periodic calibration, Response for b, c:

and Both primary and backup SFPI channels incorporate permanent maintenance installation (with no reliance on portable, post-event installation) of conducted for relatively simple and robust augmented quality equipment. Permanent the level installation coupled with stocking of adequate spare parts reasonably measurement diminishes the likelihood that a single channel (and greatly diminishes system and its the likelihood that both channels) is (are) out-of-service for an supporting extended period of time. Planned compensatory actions for unlikely equipment. extended out-of-service events will be controlled by CC-CL-118-1001 b) A Diverse and Flexible Coping Strategies (FLEX) and Spent Fuel Pool description of Instrumentation Program Implementation and are summarized as how the follows:

guidance in NEI12-02, # Required Compensatory Action if Required Restoration Section 4.3 Channel(s) Restoration Action not completed within Specified Time regarding Out-of-compensatory Page 18 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 actions for Service Action one or both non- 1 Restore Immediately initiate action functioning Channel to channels will in accordance with note below functional be addressed.

status within c) A description of 90 days (or if what channel compensatory restoration not actions are expected planned in the within 90 event that one days, then of the proceed to instrument Compensatory channels Action cannot be restored to functional 2 Initiate action Immediately initiate action status within within 24 90 days. hours to in accordance with note below restore one Part a) Forcast channel to Complete functional 3/31/15 status and Part b) & c) restore one Complete 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.

Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Completed with this submittal (RA For RAI 2(a) The following Westinghouse documents provide the analyses used to verify 1-3, above, please the design criteria and describe the methodology for seismic testing of the SFP Page 19 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Ref. provide the instrumentation and electronics units, inclusive of design basis maximum

5) analyses seismic loads and hydrodynamic loads that could result from pool sloshing and used to verify other effects that could accompany such seismic forces:

the design criteria and a. CN-PEUS-14-13 Seismic Analysis of the SFP Mounting Bracket at methodology Clinton Power Station for seismic testing of the b. LTR-SEE-II-13-47, WNA-TR-03149-G EN Sloshing Analysis SFP c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification instrumentati of other components of SFPI on and the electronics No equipment failures were noted as a result of seismic test runs. Seismic test units, data has been documented in the seismic test reports, referenced above.

including, CPS specific calculations which support the EC 392333 are identified as part design basis maximum of the Affected Documents for the modification and addresses the seismic seismic loads qualification of the monitors and transmitters. The design criteria used in these and the calculations satisfies the requirements to withstand a SSE and meet the CPS hydrodynami seismic related installation requirements for mounting the readout displays and c loads that transmitters in the Auxiliary Building and Control Building.

could result from pool sloshing or other effects that could accompany such seismic forces.

Complete 2 RAI Question: Complete with this submittal (RA For each of Clinton Power Station calculations IP-S-0302, Evaluation of SFPI Sensor 1-4, the mounting Mounting Bracket Anchor Plate Detail, and 1P-S-0303, Evaluate Mounting Ref. attachments Details for Level Transmitters and Electrical Enclosures, and EC 392333 were

5) required to performed. The design criteria used in these calculations and EC 392333 attach SFP meets the requirements to withstand a SSE and will meet the Clinton Power level Station safety related installation requirements. The methods used in the equipment to calculations follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for plant seismic qualification of the instruments. The analysis has been finalized.

structures, please describe the design inputs, and the methodology that was used to qualify the structural Page 20 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 integrity of the affected structures/

equipment.

Complete 3 RAI Question: Complete with this submittal (RA For RAI #5 Below is a summary of the test conditions used by Westinghouse to qualify the 1-6, above, please SFPIS. These test conditions are also documented in Westinghouse Ref. provide the documents EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-354 LTR-SFPIS-13-35,

5) results for the and WNA-DS-02957-GEN. Environmental Conditions for SFPIS Components selected installed in the Spent Fuel Pool Area at Clinton Power Station will be verified methods, as bounded as part of EC 392333 Design Summary. The materials with which tests and the probe and the anchor are manufactured are resistant to radiation effects.

analyses The stainless steel anchor and stainless steel probe can withstand 40-year used to dose. Westinghouse updated the design specification (WNA-DS-02957-GEN) demonstrate the and LTR-SFPIS-13-35, Revision 1 documentation to include the above qualification technical justification.

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

with the Order requirements. Parameter Normal BDB Complete Temperature 50-140°F 212°F Pressure Atmospheric Atmospheric Humidity 0-95% RH 100% (saturated steam)

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

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

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 Parameter Normal BDB (Level Sensor Electronics Only)

Page 21 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Temperature 50-120°F 140°F 140°F Pressure Atmospheric Atmospheric Atmospheric Humidity 0-95%

0-95%

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

Duration 3 days 3 days 3 days Radiation 5 1E03 R y 5 1E03 R 5 1E03 R TID y Clinton specific calculations which support the seismic installation and environmental analysis of the display enclosures and transmitters are included on the Affected Document List (ADL) for the EC 392333.

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 them acceptable.

Additionally, Westinghouse has completed their aging tests to age the system components to 10 years. The tests were completed satisfactorily and the final test reports were reviewed and found acceptable for Clinton Station.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirm that the SFPIS meets the seismic requirements of NEI 12-02. Westinghouse's design and supporting analysis satisfies the Clinton Power Station installation requirements to withstand a SSE.

Vibration Justification As specified in RAI-2, components of the system i.e., bracket, transmitter enclosure, display enclosure, and readout display in the Auxiliary and Control Building, will be permanently installed to meet the requirements to withstand a SSE and will meet the Clinton Power Station seismic related installation requirements. Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification Page 22 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 The sloshing calculation developed by Westinghouse has been reviewed for a design basis seismic event for acceptability as part of EC 392333 preparation.

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.

4 RAI Question: Complete with this submittal (RA Please provide a) The Clinton Power Station (CPS) electrical ac power sources for the 1-8, the following: primary and backup Spent Fuel Pool Level Indication channels are Ref. a) A designed to be two separate Balance of Plant Motor Control Centers fed

5) description of from different Unit Subs. The details of this power is defined in the CPS the electrical EC 392333.

ac power sources and b) The Westinghouse Report, WNA-CN-00300-GEN, provides the results capacities for of the calculation depicting the battery backup duty cycle. This calculation the primary demonstrates that battery capacity is 4.22 days to maintain the level and backup indicating function to the display location, located in the Control and channels.

b) Please Auxiliary Building. The results of the calculation meet the NEI 12-02 provide the requirements. Reference Section 5.4.1 of Ref 2.

results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until of resource availability is reasonably assured.

Part a)

Complete Part b) -

Complete Page 23 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 5 RAI Question: Complete (RA Please a) The specific location of the primary and backup instrument channel I- provide the display (monitor) is depicted on the attached sketch, NRC RAI Question 1.

11, following: b) Clinton Power Station will have a display near the Remote (alternate)

Ref. a) The Shutdown Panel as shown on the attached sketch NRC RAI Question 1. This

5) specific location for location was selected since it has been proven that it can be accessed without the primary unreasonable delay during an event including a BDB event and is analyzed for and backup Remote Shutdown Panel design basis accident radiation and habitability instrument conditions. Time to access this display is the same as that addressed in the channel UFSAR for access to the Remote Shutdown Panel. This area BDB condition is display. addressed in RAI #6, "Environmental Conditions Outside of the Spent Fuel b) If a display Pool Area". The Display Enclosure (monitor) will be periodically checked as will be part of Operator rounds.

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 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 Page 24 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 personnel to access the display.

Additionally, please include a description of the radiological and environmenta I conditions on the paths personnel might take.

Describe whether the display location remains habitable for radiological, heat and humidity, and other environmenta I conditions following a BDB event.

Describe whether personnel are continuously stationed at the display or monitor the display periodically.

Part a)

Complete Part b) -

Complete 6 RAI Question: Started (RA Please provide The procedures will be assigned and developed as part of the EC Design I- a list of the Attribute Review process in accordance with CC-AA-102 "Design Input and 12, procedures Configuration Change Impact Screening". The procedure numbers, titles and Ref. addressing technical objectives will be developed prior to the EC being Released for

5) operation Operations by March 31, 2015.

(both normal Page 25 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 and abnormal response),

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

n. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

Fcst Complete 3/31/15 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 029).
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 Page 26 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA 051)", dated July 3,2013 (RS-13-157).

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 15, 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-13-116).
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-14-019).
8. Third 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, 2014. (RS-14-197).

9 Attachments Attachment 1 CPS Schematic of the Level Sensor with Mechanical Attachment Points Attachment 2 Planned Cable Paths and Component Location Sketch Page 27 of 32

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' PLANNNED CABLE PATHS AND COMPONENT LOCATION SKETCH GVVR CABLE BRACKET ARRANGEMENT AT SOUTH SIDE OF FUEL POOL (REF. S-28-1403 / SECT. 28-3)

Page 30 of 32

Clinton Power Station, Unit 1 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015

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