RS-16-004, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

ML16012A219
Person / Time
Site:	Dresden
Issue date:	01/12/2016
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-16-004, TAC MF1046, TAC MF1047, TAC MF1050, TAC MF1051
Download: ML16012A219 (8)

Text

Exelon Generation.

Order No. EA-12-051 RS-16-004 January 12, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

Subject:

Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (RS-13-030)

6. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 26, 2013

7. Exelon Generation Company, LLC letter to NRC, Response to Request For Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051),

dated July 18, 2013 (RS-13-176)

8. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2013 (RS-13-118)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 2

9. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2014 (RS-14-020)

10. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2014 (RS-14-198)

11. Exelon Generation Company, LLC 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 27, 2015 (RS-15-028) 12.Exelon Generation Company, LLC 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), dated August 28, 2015 (RS-15-202) 13.NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3 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. MF1 050 and MF1 051), dated October 29, 2013 14.NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3 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. MF1 046, MF1 047, MF1 050, MF1 051), dated October 9, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed EGC to install reliable spent fuel pool level instrumentation.

Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorsed industry guidance document NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding reliable spent fuel pool instrumentation.

Reference 5 provided the Dresden Nuclear Power Station, Units 2 and 3 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 8, 9, 10, 11, and 12 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Dresden Nuclear Power Station, Units 2 and 3.

The purpose of this letter is to provide the report of full compliance with the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (Reference 1) pursuant to Section IV, Condition C.3 of the Order for Dresden Nuclear Power Station, Units 2 and 3.

Dresden Nuclear Power Station, Units 2 and 3 have installed two independent full scale level monitors for each Spent Fuel Pool (SFP) in response to Order EA-12-051. Dresden Nuclear

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 3 Power Station, Units 2 and 3 OIP Open Items have been addressed and closed as documented in References 8, 9, 10, 11, and 12, and are considered complete pending NRC closure. The information provided herein documents full compliance for Dresden Nuclear Power Station, Units 2 and 3 with Reference 1.

EGC's response to the NRC OIP Requests for Additional Information (OIP RAIs), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAIs) identified in References 6 and 13 have been addressed and closed as documented in References 7, 8, 9, 10, 11, 12, and below, and are considered complete pending NRC closure. The following table provides completion references for each NRC OIP RAI and ISE RAI.

OIP Open Item No. 1 Reference 8 OIP RAI No. 1 Reference 7 0 P RAI Nos. 2, 3, 4, 5, 6b, and 7 Reference 12 OIP RAI Nos. 6a, 8 Reference 12 and updated with this ISE RAI No. 8a submittal as provided below OIP RAI No. 11 Reference 12 ISE RAI Nos. 3, 4, 6, 8b, 11 (replaces Reference 12 OIP RAI 9), and 12 (replaces OIP RAI 10 Table Notes:

• ISE RAIs are not duplicated in the table above if previously issued as OIP RAIs in Reference 6.

EGC's response to the NRC audit questions and additional audit open items have been addressed as documented in the NRC Site Audit Report (Reference 14). Reference 14 contains no remaining audit open items regarding Dresden Nuclear Power Station, Units 2 and 3 compliance with NRC Order EA-12-051.

The table below documents the completion of the final remaining open actions as identified in Reference 12. As stated above, EGC provides the response for the following items and considers them to be complete for Dresden Nuclear Power Station, Units 2 and 3.

Item Description Reference OIP Item 7 (RAI-6a, Ref. 6) a) The primary and backup SFPLI Complete.

instrument channels will be normally RAI Question: powered from 120 VAC. Upon loss With this Please provide the of normal AC power, individual Compliance following: batteries installed in each channel's submittal.

electronics / UPS enclosure will a) A description of the automatically maintain continuous electrical ac power sources channel operation for at least (3) and capacities for the days. The power cables will be primary and backup routed so that spatial and physical channels. separation is maintained between

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 4 the primary and backup channels.

Additionally, a receptacle and a selector switch are installed in each channel electronics / UPS enclosure to directly connect emergency power to the SFPLI.

The U2 secondary SFPI AC power supply required an interim power source configuration between November 18, 2015 and December 4, 2015 due to elevated plant risks involved with the power connection to the permanent power source. The interim power source configuration was reviewed and is compliant with References 1 and 3.

CHIP Item 9 (RAI-8, Ref. 6) a) Westinghouse calibration procedure WNA-TP-04709-GEN and functional test procedure WNA-TP-04613-GEN Complete.

RAI Question: describe the capabilities and provisions of SFPI periodic testing With this Please provide the and calibration, including in-situ Compliance following:

testing. Westinghouse calibration submittal.

a) A description of the and functional test procedures are capability and provisions acceptable for Dresden Station.

the proposed level sensing Dresden Station has reviewed the procedures to ensure the instrument equipment will have to can be calibrated, functionally enable periodic testing and tested, and in-situ tested per the calibration, including how Order requirements.

this capability enables the equipment to be tested in- b) The level displayed by the channels situ. has been verified per the Dresden Station administrative and operating b) A description of how procedures, as recommended by such testing and calibration Westinghouse vendor technical manual WNA-GO-00127-GEN. If the will enable the conduct of level is not within the required regular channel checks of accuracy per Westinghouse each independent channel recommended tolerances in WNA-against the other, and TP-04709-GEN, channel calibration against any other will be performed.

permanently-installed SFP level instrumentation. c) Functional checks will be performed per Westinghouse functionality test c) A description of how procedure WNA-TP-04613-GEN at the frequency determined by Dresden calibration tests and Station maintenance and operating functional checks will be programs based on the performed, and the Westinghouse recommended frequency at which they will

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 5 be conducted. Discuss how frequency. Calibration tests will be these surveillances will be performed per Westinghouse incorporated into the plant calibration procedure WNA-TP-surveillance program. 04709-GEN at the frequency determined by Dresden Station d) A description of what maintenance and operating programs preventive maintenance based on the Westinghouse tasks are required to be recommended frequency. In performed during normal accordance with Dresden Station maintenance and operating operation, and the planned programs, Dresden Station has maximum surveillance developed calibration, functional test, interval that is necessary to and channel verification procedures ensure that the channels are per Westinghouse recommendations fully conditioned to to ensure reliable, accurate and accurately and reliably continuous SFPI functionality.

perform their functions when needed. d) Dresden Station has developed preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-GO-00127-GEN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

ISE Item 4 (RAII-8a, Ref. 13) a) The primary and backup SFPLI Complete.

instrument channels will be normally RAI Question: powered from 120 VAC. Upon loss With this Please provide the of normal AC power, individual Compliance following: batteries installed in each channel's submittal.

electronics / UPS enclosure will a) A description of the automatically maintain continuous electrical ac power sources channel operation for at least (3) and capacities for the days. The power cables will be primary and backup routed so that spatial and physical channels. separation is maintained between the primary and backup channels.

Additionally, a receptacle and a selector switch are installed in each channel electronics / UPS enclosure to directly connect emergency power to the SFPLI.

The U2 secondary SFPI AC power supply required an interim power source configuration between November 18, 2015 and December 4, 2015 due to elevated plant risks involved with the power connection

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 6 to the permanent power source. The interim power source configuration was reviewed and is compliant with References 1 and 3.

MILESTONE SCHEDULE ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Submit Responses to RAls July 18, 2013 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 August 28, 2014 Update 4 February 27, 2015 Update 5 August 28, 2015 Modifications:

Conceptual Design 3Q2012 Issue Exelon Fleet contract to procure SFPI 2Q2013 Equipment Begin Detailed Engineering Design for Unit 2 3Q2014 Complete and Issue SFPI Modification Package for 1 Q2015 Unit 2 Begin Detailed Engineering Design for Unit 3 3Q2014 Complete and Issue SFPI Modification Package for 1 Q2015 Unit 3 Begin SFPI Installation for Unit 2 2Q2015 Complete SFPI Installation for Unit 2 and Put Into November 18, 2015 Service Begin SFPI Installation for Unit 3 2Q2015 Complete SFPI Installation for Unit 3 and Put Into December 4, 2015 Service ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Dresden Nuclear Power Station, Units 2 and 3, as well as the site overall integrated plan response submittal (Reference 5), and the 6-Month Status Reports (References 8, 9, 10, 11, and 12), demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Dresden Nuclear Power Station, Units 2 and 3 have identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 7 INSTRUMENT DESIGN FEATURES - COMPLETE The design of the instruments installed at Dresden Nuclear Power Station, Units 2 and 3 complies with the requirements specified in the Order and described in NEI 12-02 "Industry Guidance for Compliance with NRC Order EA-12-051". The instruments have been installed in accordance with the station design control process.

The instruments have been arranged to provide reasonable protection against missiles.

The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their design accuracy following a power interruption and are designed to allow for routine testing and calibration.

The instrument display is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.

PROGRAM FEATURES - COMPLETE Training for Dresden Nuclear Power Station, Units 2 and 3 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures for Dresden Nuclear Power Station, Units 2 and 3 have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

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 12th day of January 2016.

Respectfully submitted, 4s$

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

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 12, 2016 Page 8 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Dresden Nuclear Power Station NRC Project Manager, NRR Dresden Nuclear Power Station Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency Division of Nuclear Safety