RS-15-033, 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)
ML15058A631
Person / Time
Site: Quad Cities  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-15-033
Download: ML15058A631 (22)
v • d • e


Text

IOW Exelon Generation Order No. EA-12-051 RS-15-033 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

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-13-035)
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-13-128)
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 025)
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-14-203)

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, Quad Cities Nuclear Power 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. MF1052 and MF1053), dated October 9, 2013 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 Quad Cities Nuclear Power 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, 7, and 8 provided the first, second, and third six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Quad Cities Nuclear Power Station. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference 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,

/ , 7 Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Quad Cities Nuclear Power Station, Units 1 and 2 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 Ill NRC Senior Resident Inspector Quad Cities Nuclear Power Station, Units 1 and 2 NRC Project Manager, NRR Quad Cities Nuclear Power 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. Blake Purnell, NRR/DORULPL3-2, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (18 pages)

Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 Quad Cities Nuclear Power Station, Units 1 and 2 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 Quad Cities Nuclear Power 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 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 9), and are current as of the issuance of this report.

  • None 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Revised Target Completion Target Milestone Activity Status Date Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls July 3, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete Update 4 February 28, 2015 Complete with this submittal Provide Final Safety Evaluation September 30, 2014 Complete Page 1 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 Revised Target Completion Target Milestone Activity Status Date Completion Date (SE) Info Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin (Site Specific) Detailed 402013 Complete Engineering Design Complete and Issue SFPI 202014 Complete Modification Package Begin Installation 402014 Complete Complete SFPI Installation and 102015 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 Quad Cities Nuclear Power 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(Ref. 1) or the Draft Safety Evaluation (SE)(Ref. 5) and the status of each item. All incomplete RAI questions from the Draft Safety Evaluation are included as Open Items in the Tables below.

Page 2 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Overall Integrated Plan Open Items(01) 01# Description Status 1 Open Item: Complete.

(Ref.1) Continuous level (Addressed in Reference 7) 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.

2 RAI Question: Complete.

(RAI-2, Please provide a clearly (Addressed in Reference 9)

Ref.4) labeled sketch or 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 back-up SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.

3 RAI Question: Complete (RAI-3, Please provide the (Addressed in Reference 9)

Ref.4) following:

a) The design criteria that will be used to estimate the total loading on the mounting device(s),

including static weight loads and dynamic loads.

Describe the methodology that will be used to estimate the total loading, Page 3 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

4 RAI Question: Complete (RAI-4, Please provide the (Addressed in Reference 9)

Ref.4) following:

a) A description of the specific method or combination of methods you intend to apply to demonstrate the reliability of the permanently Page 4 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 installed equipment under beyond-design-basis ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

Page 5 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 5 RAI Question: Complete (RAI-5, Please provide the (Addressed in Reference 9)

Ref.4) following:

a) A description of how the two 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 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.

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

Ref.4) following:

a) A description of the electrical ac power sources and capabilities for the primary and backup channels.

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Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

7 RAI Question: Complete (RAI-7, Please provide the (Addressed in Reference 9)

Ref.4) following:

a) An estimate of the expected instrument channel accuracy performance under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the 16 beyond design-basis conditions (i.e.,

radiation, temperature, humidity, postseismic and post- shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points.

b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to Page 7 of 18

Quad Cities Nuclear Power Station. Units I and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 technicians that the channel requires adjustment to within the normal condition design accuracy.

8 RAI Question: Started (RAI-8, Please provide the a) Westinghouse calibration procedure WNA-TP-Ref.4) following: 04709-GEN and functional test procedure WNA-TP-04613-GEN describe the capabilities and provisions a) A description of the of SFPI periodic testing and calibration, including in-capability and provisions situ testing.

the proposed level sensing equipment will have to b) The level displayed by the channels will be enable periodic testing verified per the Quad Cities Station administrative and calibration, including and operating procedures, as recommended by how this capability Westinghouse vendor technical manual WNA-GO-enables the equipment to 00127-GEN. If the level is not within the required be tested in-situ, accuracy per Westinghouse recommended tolerance in WNA-TP-04709-GEN, channel b) A description of how calibration will be performed.

such testing and calibration will enable the c) Functional checks will be performed per conduct of regular channel Westinghouse functionality test procedure WNA-TP-checks of each 04613-0 EN at the Westinghouse recommended independent channel frequency. Calibration tests will be performed per against the other, and Westinghouse calibration procedure WNA-TP-against any other 04709-GEN at the Westinghouse recommended permanently-installed SFP frequency. In accordance with Quad Cities Station level instrumentation, modification process, maintenance and operating surveillances will be developed, by March 16, 2015, c) A description of how for calibration, functional test, and channel functional checks will be verification procedures per Westinghouse performed, and the recommendations to ensure reliable, accurate and frequency at which they continuous SFPI functionality.

will be conducted.

Describe how calibration d) Quad Cities Station will develop, by March 16, tests will be performed, 2015, preventive maintenance tasks for the SFPI and the frequency at which per Westinghouse recommendation identified in the they will be conducted. technical manual WNA-G0-00127-GEN to assure Provide a discussion as to that the channels are fully conditioned to accurately how these surveillances and reliably perform their functions when needed.

will be incorporated into the plant surveillance program.

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Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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.

9 RAI Question: Replaced by Interim SE RAI #12 (Ref. 5).

(RAI-9, Please provide the Ref.4) following:

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 Page 9 of 18

Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 external events.

10 RAI Question: Replaced by Interim SE RAI #13 (Ref. 5).

(RAH 0, Please provide a Ref.4) description of 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 instrumentation, as well as storage and installation of portable instruments.

11 RAI Question: Complete (see also Reference 9)

(RAI-11, c) A description of what Quad Cities Station revised the compensatory Ref.4) compensatory actions are action plan requirements applicable to conditions planned in the event that where the instrument channel(s) are not restored to one of the instrument functional status within the specified time, as channels cannot be specified in the Note. The condition will be entered restored to functional into the corrective action program in lieu of a report status within 90 days. to PORC.

  1. Channel(s) Required Compensatory Out-of- Restoration Action if Service Action Required Restoration Action not completed within Specified Time 1 Restore channel Immediately to functional initiate action in status within 90 accordance with days (or if Note below channel restoration not expected within Page 10 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 90 days, then proceed to Compensatory Action) 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 in to restore one accordance with channel to Note below functional 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.

12 RAI Question: Complete (RAI-1, Please provide the (Addressed in Reference 4)

Ref. 4) following:

a) For level L1, specify how the identified 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 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 Li, L2, and L3 as well as Page 11 of 18

Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 the top of the fuel. Indicate on this sketch the portion of the level sensormeasurement range that is sensitive to measurement of the fuel pool level, with respect to the L-1, L2, and L3 datum points.

Draft Safety Evaluation Open Items (Ref. 5 & 6) 01# Description Status 1 RAI Question: Complete (RAI-1, Please provide the (Addressed in Reference 8)

Ref. 5, following:

6) a) Describe the impact of the installation of the gates between the SFPs and transfer canal on the reliability of the SFP level instrumentation for each SFP. Describe the compensatory measures that would be taken to ensure reliable indication in each SFP when the gates are installed.

b) Describe the elevation for the bottom of the gate opening or highest elevation of the bottom of the transfer canal to demonstrate that both the primary and backup SFP level instrument channels can measure the same Level 3 elevation in both SFPs.

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Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPL1 February 27, 2015 2 RAI Question: Complete with this Submittal (RA1-4, For RAI3(a) above, The following Westinghouse documents provide the Ref. 5) please provide the analyses used to verify the design criteria and describe the analyses used to verify methodology for seismic testing of the SFP instrumentation the design criteria and and electronics units, inclusive of design basis maximum methodology for seismic loads and hydrodynamic loads that could result seismic testing of the from pool sloshing and other effects that could accompany SFP instrumentation such seismic forces:

and the electronics

a. CN-PEUS-14-5 Pool-side Bracket Seismic Analysis units, including design
b. LTR-SEE-11-13-47, WNA-TR-03149-GEN Sloshing basis maximum seismic loads and the Analysis hydrodynamic loads C. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 that could result from Seismic Qualification of other components of SFPI pool sloshing or other No equipment failures were noted as a result of seismic test effects that could runs. Seismic test data has been documented in the accompany such seismic test reports, referenced above.

seismic forces. Quad Cities Station specific calculation QDC-1900-S-2109 Seismic Qualification of SFPI Transmitter and Display boxes will address the seismic qualification of the display panel indicators. This analysis has been finalized.

3 RAI Question: Complete with this submittal (RAI-5, For each of the Quad Cities Station specific calculations QDC-1900-S-2108 Ref.5) mounting attachments Evaluation of SFPI Sensor Mounting Detail Anchorage required to attach SFP and QDC-1900-S-2109 and EC 393703 were performed.

level equipment to The design criteria used in this calculation and EC 393703 plant structures, meets the requirements to withstand a SSE and will meet please describe the design inputs and the Quad Cities Station safety related installation methodology used to requirements. The methods used in the calculation follow qualify the structural IEEE Standard 344-2004 and IEEE Standard 323-2003 for integrity of the affected seismic qualification of the instrument. This analysis has structures and been finalized.

equipment.

4 RAI Question: Complete with this submittal (RAI-7, For RAI #6 above, Below is a summary of the test conditions used by Ref. 5) please provide the Westinghouse to qualify the SFPIS. Environmental results for the selected Conditions for SFPIS Components installed in the Spent methods, tests and Fuel Pool Area at Quad Cities Station are bounded by analyses utilized to below test conditions, except for radiation Total Integrated demonstrate the qualification and Dose (TID) 12" above top of fuel rack for beyond design reliability of the basis conditions (BDB). The BDB radiation TID, 12" above installed equipment in top of fuel rack for Quad Cities is 4.E07 R y, per calculation accordance with the BYR13-051 NEI 12-02 Spent Fuel Pool Doses. The BDB Order requirements. radiation value to which the Westinghouse equipment is Page 13 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 qualified to is 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. 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 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, and coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Normal Parameter BDB for Exelon Plants 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 1E07 Rads (12" above top (probe and weight of fuel rack) only)

Environmental Conditions Outside of the Spent Fuel Pool Area Page 14 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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)

Temperature 50-120°F 140°F 140°F Pressure Atmos- Atmos-Atmospheric pheric pheric Humidity 0-95% 0-95%

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

Duration 3 days 3 days 3 days Radiation TID 5 1E03 R 5 1E03 R y 5 1E03 R y V V 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 SFR 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 for Byron Station's configuration and the final test reports were reviewed and found acceptable by Exelon for Quad Cities.

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Quad Cities Nuclear Power Station. Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27. 2015 5 RAI Question: Complete (RAI- Please provide the (Addressed in Reference 9) 12, following:

Ref. 5) a) The specific location for each of the primary and backup instrument channel displays.

b) If a display will be located somewhere other than the control room or alternate shutdown panel, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event.

Include the time available for personnel to access the display as credited in the evaluation, as we as the actual time (e.g.,

based on walk-throughs) that it will take for personnel to access the display.

Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BDB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

Page 16 of 18

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 6 RAI Question: Complete (RAI- Please provide a list of (Addressed in Reference 9) 13, the procedures Ref. 5) addressing operation (both normal and abnormal response),

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

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

7 Potential Draft Safety Evaluation Impacts(Ref. 5)

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 035)
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-12-051)", dated July 3, 2013 (RS-13-159).
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 October 9, 2013.

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Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015

6. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated November 26, 2013.
7. 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-13-128).
8. 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-14-025).
9. 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-14-203).

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