RS-16-013, 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)
| ML16020A026 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/20/2016 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-16-013, TMl-16-003 | |
| Download: ML16020A026 (9) | |
Text
Exelon Generation<!>
Order No. EA-12-051 RS-16-013 TMl-16-003 January 20, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
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-13-036)
- 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 24, 2013 (RS-13-095)
- 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-13-130)
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 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-14-026) 1O. 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-14-204) 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-15-034)
- 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-15-205)
- 13. NRC letter to Exelon Generation Company, LLC, Three Mile Island Nuclear 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 (TAC No. MF0866), dated November 13, 2013 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 Three Mile Island Nuclear Station, Unit 1 OIP.
Reference 1 required submission of a status report at six-month intervals following submittal of the 01 P. 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 Three Mile Island Nuclear Station, Unit 1.
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 Three Mile Island Nuclear Station, Unit 1.
Three Mile Island Nuclear Station, Unit 1 has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1 with Reference 1.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 3 EGC's response to the NRC OIP Requests for Additional Information (OIP RAls), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAls) 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 (RAI 1a) Reference 12 and updated with this submittal as provided below OIP Open Item No. 2 Reference 8 OIP RAI No. 1b Reference 12 and updated with this submittal as provided below OIPRAI Nos.2,3,4,5,6, 7,9, 10, and Reference 12 11 OIP RAI No. 8 Reference 12 and updated with this submittal as provided below ISE RAI No. 2, 5, 6, 8, 10, 13, and 14 Reference 12 Table Notes:
It is EGC's understanding that the NRC Site Audit Report contains no remaining audit open items regarding Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1.
Item Description Reference OIP Item 1 (RAl-1a, Ref. 6)
Complete NEI 12-02, Section 2.3.1 identifies that Level 1 will be the HIGHER of two levels. With this RAI Question:
Compliance For Level 1, specify how the The first level is the suction loss due to submittal.
identified location uncovering of the Spent Fuel (SF) represents the higher of the cooling suction pipe. This level was two points described in the initially identified by TMI as elevation NEI 12-02 guidance for this 340' 4". Further investigation under level. Calculation C-1101-251-E410-012, "Available NPSH for SF Coolant Pumps",
revealed that loss of suction by vortexing is as high as 341' 11" at the design flow
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 4 of 1000 gpm.
The second level is the loss of SF cooling pump NPSH under saturated conditions. According to the Calculation C-1101-251-E410-012, at design flow (1,000 gpm) and 212°F fluid, adequate NPSH exists and suction line voiding will not occur at 343' 6".
Both these levels have been finalized and the required Level 1 per NEI 12-02 guidance is 343' 6", based on SFP worst case (212°F) scenario per Calculation C-1101-251-E410-012.
OIP Item 3 (RAl-1 b, Ref. 6)
Complete RAI Question: See Attachment 1 for the sketch that clearly defines the following: With this A clearly labeled sketch Compliance depicting the elevation view The top of the highest fuel is 319' 4" submittal.
of the proposed typical mounting arrangement for elevation. This is the 0.00' indication for the portions of the both SF level indication systems.
instrument channel Level 1 represents loss of SF cooling consisting of permanent suction. This point is at 343' 6" elevation measurement channel and a SFPI indicated level of 24.17'.
equipment (e.g., fixed level sensors and/or stilling wells, Level 2 represents 1O' of water over the and mounting brackets). fuel. This point is 329' 4" elevation and Indicate on this sketch the a SFPI indicated level of 10.00'.
datum values representing Level 1, Level2,and Level3 Level 3 at TMI is 321' 3" and a SFPI as well as the top of the fuel. indicated level of 1.92'. This level is 3" Indicate on this sketch the above the weir for the gate that portion of the level sensor separates the two SF pools to measurement range that is demonstrate that both the primary and sensitive to measurement of backup SFP level instrument channels can the fuel pool level, with measure the same Level 3 elevation in respect to the Level 1, Level both SFPs. The 3" above the weir allows 2, and Level 3 datum points. for instrument accuracy.
OIP Item 10 (RAl-8, Ref. 6) a) Westinghouse provided test Complete RAI Question: equipment that provides the capability to enable periodic With this Provide the following:
testing and calibration of the Compliance a) A description of the proposed level sensing submittal.
capabilitv and provisions
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 5 the proposed level sensing equipment. Westinghouse equipment will have to calibration procedure WNA-TP-enable periodic testing and 04709-GEN and functional test calibration, including how procedure WNA-TP-04613-GEN this capability enables the provide instructions to use the equipment to be tested in- test equipment to perform situ. periodic testing and calibration, b) A description of how including in-situ testing. TMI in-such testing and calibration situ test methodology is based on the Westinghouse Two Point will enable the conduct of Verification Method, LTR-SFPIS-regular channel checks of 14-55.
each independent channel against the other, and b) The level displayed by the against any other channels will be verified per the permanently-installed SFP TMI operating procedures, as level instrumentation. recommended by Westinghouse c) A description of how vendor technical manual WNA-functional checks will be G0-00127-GEN. If the level is not within the required accuracy performed, and the per Westinghouse recommended frequency at which they will tolerance in WNA-TP-04709-be conducted. Describe how GEN, channel calibration will be calibration tests will be performed.
performed, and the frequency at which they will c) The functional test and calibration be conducted. Provide a are combined in the same discussion as to how these procedure, MA-TM-145-251. The surveillances will be TMI procedure is associated with incorporated into the plant a PM that establishes the surveillance program. required performance of the d) A description of what procedure 60 days prior to a preventive maintenance scheduled refueling outage.
tasks required to be These procedures are based on performed during normal the Westinghouse Two Point operation, and the planned Verification Method and WNA-TP-maximum surveillance 04709-GEN Spent Fuel Pool interval that is necessary to Instrument System Calibration Procedure. The procedure ensure that the channels are establishes the current water fully conditioned to level by measuring the distance accurately and reliably to the water referenced from the perform their functions bottom of the launch plate. This when needed. measured distance is then compared to the level indication obtaining the As-Found indication value. The probe is then lifted out of the water to a predetermined mark on the probe. The water level at the predetermined mark is then recorded. The probe is lowered back into the water freelv
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 6 suspended from the launch plate.
The level indication is recorded. If all three As-Found Level indications are within the tolerance specified, the procedure is exited. If the As-Found values are not within tolerance the calibration is performed to bring the indication within the calibration requirements. The calibration steps of the TMI procedures were taken from Westinghouse document WNA-TP-04709-GEN Spent Fuel Pool Instrument System Calibration Procedure.
d) TMI 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.
MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall lnteQrated Plan February 28, 2013 Submit Responses to RAls July 24, 2013 Submit 6 Month Updates:
Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 AUQUSt28,2014 Update 4 February 27, 2015 Update 5 August28,2015 Modifications:
Conceptual DesiQn 302012 Issue Exelon Fleet contract to procure SFPI 202013 Equipment Begin Detailed Design Engineering . 402013 Complete and Issue SFPI Modification Package 102015 BeQin Installation 202015 Complete SFPI Installation and Put Into Service November 24, 2015
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 7 ORDER EA-12-051 COMPLIANCE ELEMENTS
SUMMARY
The elements identified below for Three Mile Island Nuclear Station, Unit 1, as well as the site overall integrated plan response submittal (Reference 5), and the 6-Month Status Reports (References 8, 9, 1O, 11, and 12), demonstrate compliance with Order EA-12-051.
IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Three Mile Island Nuclear Station, Unit 1 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.
INSTRUMENT DESIGN FEATURES- COMPLETE The design of the instruments installed at Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.
Operating and maintenance procedures for Three Mile Island Nuclear Station, Unit 1 have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the instruments are maintained at their design accuracy.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 8 This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h day of January 2016.
Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC : TMl-1 Spent Fuel Pool Elevation Sketch cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Mr. John D. Hughey, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection
)>C:....:IJC
-!l>CD*
S' c:: "'C
(") ::::i 0 .
(J)
ATTACHMENT 1 - TMI-1 SPENT FUEL POOL ELEVATION SKETCH :::r Q) ;:::::i. z 3-<oc::
._NORTH CDI\)-(")
- I 0 "Tl CD
...... l'\J=.,c:: Q) 63'-5' 33'-9' o__., o:D CD l~EV.
mo co
'11-3 c::
ELEV. 348'-0' .* .. . 347'-lD' SF*T*2A
- HIGH LEVEL ALARM - ELEV. 345'-0' NORMAL 'WATER LEVEL ELEV. 344'-6' SF*T*2Bmv. 346 ,_9 f
- a.1 ,-,_: ... ELEV. 348'-0' - llALK llAY LEVEL f*.:;
"'C -
Q)
- i
(") '<
Q) 0 24.17' INDICATED LEVEL=ELEV. 343'-61 LEVEL 1 LOSS OF SF L_ ~~ CD ()
- E 0
- !! CODLING SUCTION I I 27.427' CSF -LI-12198 :=-:3
~~
BASED ON 212 DEG. F :::r 3 V 28.5' CSF-LI-1219A PRIMARY 'WATER TEMPERATURE I ~
15 I INDICATION BACKUP LEVEL SENSOR RANGD ~
0 c;;*
., en LEVEL SENSOR
- .:~' a.-*
CD 0 INDICATION RANGD
~1 * . -~ .
-~* -*' ., ::::i 10.00' INDICATED LEVEL=ELEV. 329'-4'1
<I:
L.:J I
~~~j: m
)>
LEVEL 2 r-- *~i-~ I 1.92' INDICATED LEVEL=ELEV. 321' -3'
- 1 I\)
ELEV. 321'-0' I LEVEL 3 I*:,*,'./ *
- ELEV. 319'-4' * ~,
- .~:
- HIP ar run_ RACK - ELEV. 319'-4' ELEV. 319'-4' 0
01
. ~~ TOP OF FUEL RACK - ELEV. 319'-1'
- - -*1t
!'~~::*.~
~;,. :;
- -~~.~
.~::~:'.
-~-.i
- 4*
- ~
ELEV. 305'-0' :Ji ELEV. 305'-0'
- ~**
, :,~::~*::..::>. :*~~~.::-~. .*;:~. ~: "'. *:.. *:~*, ::* .~ -}~~~ ~~-~~-~' ; : -~l: :;~ .....:... ;:: .: ;';_::;*.~~:>:: ~-'.~ .*. . :*~~"'~_:
CAD FILE: FUEL POOL.DWG 07/30/15
Exelon Generation<!>
Order No. EA-12-051 RS-16-013 TMl-16-003 January 20, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
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-13-036)
- 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 24, 2013 (RS-13-095)
- 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-13-130)
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 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-14-026) 1O. 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-14-204) 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-15-034)
- 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-15-205)
- 13. NRC letter to Exelon Generation Company, LLC, Three Mile Island Nuclear 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 (TAC No. MF0866), dated November 13, 2013 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 Three Mile Island Nuclear Station, Unit 1 OIP.
Reference 1 required submission of a status report at six-month intervals following submittal of the 01 P. 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 Three Mile Island Nuclear Station, Unit 1.
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 Three Mile Island Nuclear Station, Unit 1.
Three Mile Island Nuclear Station, Unit 1 has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1 with Reference 1.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 3 EGC's response to the NRC OIP Requests for Additional Information (OIP RAls), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAls) 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 (RAI 1a) Reference 12 and updated with this submittal as provided below OIP Open Item No. 2 Reference 8 OIP RAI No. 1b Reference 12 and updated with this submittal as provided below OIPRAI Nos.2,3,4,5,6, 7,9, 10, and Reference 12 11 OIP RAI No. 8 Reference 12 and updated with this submittal as provided below ISE RAI No. 2, 5, 6, 8, 10, 13, and 14 Reference 12 Table Notes:
It is EGC's understanding that the NRC Site Audit Report contains no remaining audit open items regarding Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1.
Item Description Reference OIP Item 1 (RAl-1a, Ref. 6)
Complete NEI 12-02, Section 2.3.1 identifies that Level 1 will be the HIGHER of two levels. With this RAI Question:
Compliance For Level 1, specify how the The first level is the suction loss due to submittal.
identified location uncovering of the Spent Fuel (SF) represents the higher of the cooling suction pipe. This level was two points described in the initially identified by TMI as elevation NEI 12-02 guidance for this 340' 4". Further investigation under level. Calculation C-1101-251-E410-012, "Available NPSH for SF Coolant Pumps",
revealed that loss of suction by vortexing is as high as 341' 11" at the design flow
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 4 of 1000 gpm.
The second level is the loss of SF cooling pump NPSH under saturated conditions. According to the Calculation C-1101-251-E410-012, at design flow (1,000 gpm) and 212°F fluid, adequate NPSH exists and suction line voiding will not occur at 343' 6".
Both these levels have been finalized and the required Level 1 per NEI 12-02 guidance is 343' 6", based on SFP worst case (212°F) scenario per Calculation C-1101-251-E410-012.
OIP Item 3 (RAl-1 b, Ref. 6)
Complete RAI Question: See Attachment 1 for the sketch that clearly defines the following: With this A clearly labeled sketch Compliance depicting the elevation view The top of the highest fuel is 319' 4" submittal.
of the proposed typical mounting arrangement for elevation. This is the 0.00' indication for the portions of the both SF level indication systems.
instrument channel Level 1 represents loss of SF cooling consisting of permanent suction. This point is at 343' 6" elevation measurement channel and a SFPI indicated level of 24.17'.
equipment (e.g., fixed level sensors and/or stilling wells, Level 2 represents 1O' of water over the and mounting brackets). fuel. This point is 329' 4" elevation and Indicate on this sketch the a SFPI indicated level of 10.00'.
datum values representing Level 1, Level2,and Level3 Level 3 at TMI is 321' 3" and a SFPI as well as the top of the fuel. indicated level of 1.92'. This level is 3" Indicate on this sketch the above the weir for the gate that portion of the level sensor separates the two SF pools to measurement range that is demonstrate that both the primary and sensitive to measurement of backup SFP level instrument channels can the fuel pool level, with measure the same Level 3 elevation in respect to the Level 1, Level both SFPs. The 3" above the weir allows 2, and Level 3 datum points. for instrument accuracy.
OIP Item 10 (RAl-8, Ref. 6) a) Westinghouse provided test Complete RAI Question: equipment that provides the capability to enable periodic With this Provide the following:
testing and calibration of the Compliance a) A description of the proposed level sensing submittal.
capabilitv and provisions
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 5 the proposed level sensing equipment. Westinghouse equipment will have to calibration procedure WNA-TP-enable periodic testing and 04709-GEN and functional test calibration, including how procedure WNA-TP-04613-GEN this capability enables the provide instructions to use the equipment to be tested in- test equipment to perform situ. periodic testing and calibration, b) A description of how including in-situ testing. TMI in-such testing and calibration situ test methodology is based on the Westinghouse Two Point will enable the conduct of Verification Method, LTR-SFPIS-regular channel checks of 14-55.
each independent channel against the other, and b) The level displayed by the against any other channels will be verified per the permanently-installed SFP TMI operating procedures, as level instrumentation. recommended by Westinghouse c) A description of how vendor technical manual WNA-functional checks will be G0-00127-GEN. If the level is not within the required accuracy performed, and the per Westinghouse recommended frequency at which they will tolerance in WNA-TP-04709-be conducted. Describe how GEN, channel calibration will be calibration tests will be performed.
performed, and the frequency at which they will c) The functional test and calibration be conducted. Provide a are combined in the same discussion as to how these procedure, MA-TM-145-251. The surveillances will be TMI procedure is associated with incorporated into the plant a PM that establishes the surveillance program. required performance of the d) A description of what procedure 60 days prior to a preventive maintenance scheduled refueling outage.
tasks required to be These procedures are based on performed during normal the Westinghouse Two Point operation, and the planned Verification Method and WNA-TP-maximum surveillance 04709-GEN Spent Fuel Pool interval that is necessary to Instrument System Calibration Procedure. The procedure ensure that the channels are establishes the current water fully conditioned to level by measuring the distance accurately and reliably to the water referenced from the perform their functions bottom of the launch plate. This when needed. measured distance is then compared to the level indication obtaining the As-Found indication value. The probe is then lifted out of the water to a predetermined mark on the probe. The water level at the predetermined mark is then recorded. The probe is lowered back into the water freelv
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 6 suspended from the launch plate.
The level indication is recorded. If all three As-Found Level indications are within the tolerance specified, the procedure is exited. If the As-Found values are not within tolerance the calibration is performed to bring the indication within the calibration requirements. The calibration steps of the TMI procedures were taken from Westinghouse document WNA-TP-04709-GEN Spent Fuel Pool Instrument System Calibration Procedure.
d) TMI 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.
MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall lnteQrated Plan February 28, 2013 Submit Responses to RAls July 24, 2013 Submit 6 Month Updates:
Update 1 August 28, 2013 Update 2 February 28, 2014 Update 3 AUQUSt28,2014 Update 4 February 27, 2015 Update 5 August28,2015 Modifications:
Conceptual DesiQn 302012 Issue Exelon Fleet contract to procure SFPI 202013 Equipment Begin Detailed Design Engineering . 402013 Complete and Issue SFPI Modification Package 102015 BeQin Installation 202015 Complete SFPI Installation and Put Into Service November 24, 2015
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 7 ORDER EA-12-051 COMPLIANCE ELEMENTS
SUMMARY
The elements identified below for Three Mile Island Nuclear Station, Unit 1, as well as the site overall integrated plan response submittal (Reference 5), and the 6-Month Status Reports (References 8, 9, 1O, 11, and 12), demonstrate compliance with Order EA-12-051.
IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Three Mile Island Nuclear Station, Unit 1 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.
INSTRUMENT DESIGN FEATURES- COMPLETE The design of the instruments installed at Three Mile Island Nuclear Station, Unit 1 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 Three Mile Island Nuclear Station, Unit 1 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.
Operating and maintenance procedures for Three Mile Island Nuclear Station, Unit 1 have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the instruments are maintained at their design accuracy.
U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 January 20, 2016 Page 8 This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h day of January 2016.
Respectfully submitted, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC : TMl-1 Spent Fuel Pool Elevation Sketch cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Mr. John D. Hughey, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection
)>C:....:IJC
-!l>CD*
S' c:: "'C
(") ::::i 0 .
(J)
ATTACHMENT 1 - TMI-1 SPENT FUEL POOL ELEVATION SKETCH :::r Q) ;:::::i. z 3-<oc::
._NORTH CDI\)-(")
- I 0 "Tl CD
...... l'\J=.,c:: Q) 63'-5' 33'-9' o__., o:D CD l~EV.
mo co
'11-3 c::
ELEV. 348'-0' .* .. . 347'-lD' SF*T*2A
- HIGH LEVEL ALARM - ELEV. 345'-0' NORMAL 'WATER LEVEL ELEV. 344'-6' SF*T*2Bmv. 346 ,_9 f
- a.1 ,-,_: ... ELEV. 348'-0' - llALK llAY LEVEL f*.:;
"'C -
Q)
- i
(") '<
Q) 0 24.17' INDICATED LEVEL=ELEV. 343'-61 LEVEL 1 LOSS OF SF L_ ~~ CD ()
- E 0
- !! CODLING SUCTION I I 27.427' CSF -LI-12198 :=-:3
~~
BASED ON 212 DEG. F :::r 3 V 28.5' CSF-LI-1219A PRIMARY 'WATER TEMPERATURE I ~
15 I INDICATION BACKUP LEVEL SENSOR RANGD ~
0 c;;*
., en LEVEL SENSOR
- .:~' a.-*
CD 0 INDICATION RANGD
~1 * . -~ .
-~* -*' ., ::::i 10.00' INDICATED LEVEL=ELEV. 329'-4'1
<I:
L.:J I
~~~j: m
)>
LEVEL 2 r-- *~i-~ I 1.92' INDICATED LEVEL=ELEV. 321' -3'
- 1 I\)
ELEV. 321'-0' I LEVEL 3 I*:,*,'./ *
- ELEV. 319'-4' * ~,
- .~:
- HIP ar run_ RACK - ELEV. 319'-4' ELEV. 319'-4' 0
01
. ~~ TOP OF FUEL RACK - ELEV. 319'-1'
- - -*1t
!'~~::*.~
~;,. :;
- -~~.~
.~::~:'.
-~-.i
- 4*
- ~
ELEV. 305'-0' :Ji ELEV. 305'-0'
- ~**
, :,~::~*::..::>. :*~~~.::-~. .*;:~. ~: "'. *:.. *:~*, ::* .~ -}~~~ ~~-~~-~' ; : -~l: :;~ .....:... ;:: .: ;';_::;*.~~:>:: ~-'.~ .*. . :*~~"'~_:
CAD FILE: FUEL POOL.DWG 07/30/15