RS-15-206, Fifth 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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Fifth 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)
ML15243A091
Person / Time
Site: Ginna Constellation icon.png
Issue date: 08/28/2015
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-206
Download: ML15243A091 (15)
v • d • e


Text

Exelon Generation @,

Order No. EA-12-051 RS-15-206 August28,2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Fifth 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. Constellation Energy Nuclear Group, LLC letter to NRC, 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 26, 2012

5. Constellation Energy Nuclear Group, LLC letter to NRC, 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
6. Constellation Energy Nuclear Group, LLC letter to NRC, Supplement to 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 March 8, 2013

7. Constellation Energy Nuclear Group, LLC letter to NRC, 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 27, 2013 (R. E. Ginna Nuclear Power Plant)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2015 Page 2

8. Constellation Energy Nuclear Group, LLC letter to NRC, 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 24, 2014 (R. E. Ginna Nuclear Power Plant)
9. Exelon Generation Company, LLC letter to NRC, 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 26, 2014 (R. E. Ginna Nuclear Power Plant)
10. Exelon Generation Company, LLC letter to NRC, 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), dated February 20, 2015 (RS-15-062)
11. NRC letter to Constellation Energy Nuclear Group, LLC, R. E. Ginna Nuclear Power Plant- 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 No. MF1147), dated December 5, 2013
12. Letter from J. P. Beska (NRC) to J. E. Pacher (EGC), R. E. Ginna Nuclear Power Plant -

Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1152 and MF1147), dated June 18, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC), previously Constellation Energy Nuclear Group, LLC (Exelon, the licensee). 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. References 5 and 6 provided the R. E. Ginna Nuclear Power Plant 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 7, 8, 9, and 1O provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for the R. E. Ginna Nuclear Power Plant. The purpose of this letter is to provide the fifth 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 11, and any NRC Audit Report open items contained in Reference 12.

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August28,2015 Page 3 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 281h day of August 2015.

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

R. E. Ginna Nuclear Power Plant Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC

Enclosure R. E. Ginna Nuclear Power Plant Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (11 pages)

ENCLOSURE R. E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION 1 Introduction R. E. Ginna Nuclear Power Plant, LLC (Ginna) 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 Fourth 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 Fourth Six-Month status report (Reference 3), and are current as of July 24, 2015.

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

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

Revised Target Completion Activity Target Milestone Date Status Completion Date Submit 60 Day Status Report October 26, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls September 23, 2013 Complete Submit 6 Month Updates:

Update 1 August 27, 2013 Complete Update 2 February 24, 2014 Complete Update 3 August 28, 2014 Complete Update 4 February 28, 2015 Complete Provide Final Safety Evaluation September 30, 2014 Complete (SE) Information Complete with Update 5 August28,2015 this Submittal Page 1 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION Revised Target Completion Activity Target Milestone Date Status Completion Date Modifications:

Commence Engineering and 102014 Complete 302013 Design Complete Engineering and 202014 Complete 402013 Design Receipt of SFP Instruments 102015 Complete 102014 Commence Installation of SFP 102015 Complete 402014 Instruments Close out Project/Plant Turnover 202015 Complete 102015 4 Changes to Compliance Method No changes to the compliance methodology have occurred since the February 2015 status report (Reference 3).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ginna 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 As noted in the memorandum from C. A. Hunt (NRC) to M. A. Mitchell (NRC), Summary of the November 26, 2013 Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation (Reference 4), the ISE questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation. The following table provides a summary of the open items documented in the Interim Safety Evaluation (SE) (Reference 5) and the status of each item. (Note: All open items are complete.)

Page 2 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete.

(RAl-1, Ref. 5) Please provide (See the 2/2014 OIP Update - Reference 7) additional information describing how the proposed arrangement of the waveguides and routing of the cabling between the radar horns and the electronics in the Intermediate Floor (Elevation 253 ft. O in.)

meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.

2 RAI Question: Complete.

(RAl-2, Ref. 5) Please provide the (See the 2/2015 OIP Update - Reference 3) analyses verifying the seismic testing of the horn and waveguide assembly and the electronics units, and the analysis of the combined maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly exposed to the potential sloshing effects. Show the SFP instrument design configuration will be maintained during and following the maximum Page 3 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION seismic ground motion considered in the design of the SFP structure.

3 RAI Question: Complete.

(RAl-3, Ref. 5) For each of the (See the 2/2014 OIP Update - Reference 7) mounting attachments required to attach SFP Level equipment to plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/

equipment.

4 RAI Question: Complete.

(RAl-4, Ref. 5) Please provide analysis (See the 2/2014 OIP Update - Reference 7) of the maximum expected radiological conditions (dose rate and total integrated dose) to which the equipment will be exposed. Also, please provide documentation indicating how it was determined that the electronics for this equipment are capable of withstanding a total integrated dose of 1x10 3 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

5 RAI Question: Complete.

(RAl-5, Ref. 5) Please provide (See the 2/2015 OIP Update - Reference 3) information indicating (a) whether the ao 0 c rating for the sensor electronics is a continuous duty rating; and, (b) the maximum Page 4 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION expected ambient temperature in the room in which the sensor electronics will be located under Beyond Design Basis (BOB) conditions with no ac power available to run Heating Ventilation and Air Conditioning (HV AC) systems.

6 RAI Question: Complete.

(RAl-6, Ref. 5) Please provide (See the 2/2015 OIP Update - Reference 3) information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BOB conditions, with no ac power available to run HV AC systems, and whether the sensor electronics are capable of continuously performing their required functions under this expected humidity condition.

7 RAI Question: Complete.

(RAl-7, Ref. 5) Please provide (See the 2/2014 OIP Update - Reference 7) information describing the evaluation of the comparative sensor design, the shock test method, test results, and forces applied to the sensor applicable to its successful tests, demonstrating the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of severe shock.

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ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION 8 RAI Question: Complete.

(RAl-8, Ref. 5) Please provide (See the 2/2014 OIP Update - Reference 7) information describing the evaluation of the comparative sensor design, the vibration test method, test results, and the forces and their frequency ranges and directions applied to the sensor applicable to its successful tests, demonstrating the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

9 RAI Question: Complete.

(RAl-9, Ref. 5) Please provide (See the 2/2014 OIP Update - Reference 7) information describing the evaluation of the comparative display panel ratings against postulated plant conditions. Also provide results of the manufacturer's shock and vibration test methods, test results, and the forces and their frequency ranges and directions applied to the display panel associated with its successful tests.

10 RAI Question: Complete.

(RAl-10, Ref. 5) Please provide the (See the 2/2014 OIP Update - Reference 7) results of seismic testing for shock and vibration effects to demonstrate the reliability of the components within the Page 6 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION power and control panel under shock and vibration conditions.

11 RAI Question: Complete.

(RAl-11, Ref. 5) Please provide analysis (See the 2/2014 OIP Update - Reference 7) of the seismic testing results and show that the instrument performance reliability, following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Ginna, has been adequately demonstrated.

12 RAI Question: Complete.

(RAl-12, Ref. 5) Please provide the NRC (See the 2/2014 OIP Update - Reference 7) staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.

13 RAI Question: Complete.

(RAl-13, Ref. 5) Please provide the (See the 2/2014 OIP Update - Reference 7) results of the calculation depicting the battery backup duty cycle requirements, demonstrating battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

14 RAI Question: Complete.

(RAl-14, Ref. 5) Please provide the (See the 8/2014 OIP Update - Reference 8) analysis verifying Page 7 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION proposed instrument performance is consistent with these estimated accuracy normal and BOB values. Please demonstrate the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

15 RAI Question: Complete.

(RAl-15, Ref. 5) Please describe the (See the 8/2014 OIP Update - Reference 8) evaluation used to validate that the display locations can be accessed without unreasonable delay following a BOB event.

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

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

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

Describe whether the display locations remain habitable for radiological, heat and humidity, and other environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display locations or monitor the displays Page 8 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION periodically.

16 RAI Question: Complete.

(RAl-16, Ref. 5) Please provide a list of (See the 8/2014 OIP Update - Reference 8) the procedures addressing operation (both normal and abnormal response),

calibration, test, maintenance, and inspection that will be developed for use of the SFP instrumentation. The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.

17 RAI Question: Complete.

(RAl-17, Ref. 5) Please provide the (See the 8/2014 OIP Update - Reference 8) following:

a. Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

Please include a description of the plans for ensuring that necessary channel checks, functional tests, periodic calibration, Page 9 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION and maintenance will be conducted for the level measurement system and its supporting equipment.

b. Information describing compensatory actions when both channels are out-of-order, and the implementation procedures.
c. Additional information describing expedited and compensatory actions in the maintenance procedure to address a condition when one of the instrument channels cannot be restored to functional status within 90 days.

18 RAI Question: Complete.

(RAl-18, Ref. 5) Please provide a (See the 8/2014 OIP Update - Reference 8) description of the in-situ calibration process at the SFP location that will result in the channel calibration being maintained at its design accuracy.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 10 of 11

ENCLOSURE R.E. GINNA NUCLEAR POWER PLANT SIX-MONTH STATUS REPORT (AUGUST 2015)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Constellation Energy Nuclear Generation, LLC, letter to USNRC, "Supplement to Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation," dated March 8, 2013 (FLL-13-14)
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. Exelon Generation, letter to USN RC, "February 2015 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 20, 2015 (RS-15-062)
4. Memorandum from C. A. Hunt (USNRC) to M. A. Mitchell (USNRC), "Summary of the November 26, 2013 Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," dated December 26, 2013
5. USN RC letter to Constellation Energy Nuclear Generation, LLC, "Constellation Energy Nuclear Group, R.E. Ginna Nuclear Power Plant, 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. MF1147)," dated December 5, 2013
6. Constellation Energy Nuclear Group, LLC letter to NRC, 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 27, 2013 (R. E. Ginna Nuclear Power Plant)
7. Constellation Energy Nuclear Group, LLC letter to NRC, 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 24, 2014 (R. E. Ginna Nuclear Power Plant)
8. Exelon Generation Company, LLC letter to NRC, 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 26, 2014 (R. E. Ginna Nuclear Power Plant)

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