View source for RS-13-159, Response to Request for Additional - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation

{{Adams
| number = ML13186A003
| issue date = 07/03/2013
| title = Response to Request for Additional - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation
| author name = Kaegi G
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000254, 05000265
| license number = DPR-029, DPR-030
| contact person = 
| case reference number = EA-12-051, RS-13-159
| document type = Letter type:RS
| page count = 14
| project = 
| stage = Request
}}

=Text=
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Generatti Order Order No.No. EA-12-051 EA-12-051 RS-13-159 RS-13-159 July  3,2013 July 3,  2013 Nuclear Regulatory U.S. Nuclear     Regulatory Commission Commission ATTN: Document Control Control Desk Desk Washington, DC   DC 20555-0001 20555-0001 Quad Cities Quad    Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22 Renewed Facility Operating License Nos. DPR-29          DPR-29 and and DPR-30 DPR-30 NRC Docket Nos. 50-254 and 50-265       50-265 ResponsetotoRequest

==Subject:==
Response            Request     forAdditional for    AdditionalInformation Information -- Overall Overall Integrated Plan in Response Response to Commission Order Order Modifying Modifying License Requirements Requirements for   for Reliable Reliable Spent SpentFuel FuelPool Pool Instrumentation (Order (Order No.No. EA-12-051)
EA-12-051)

==References:==

Exelon Generation Company, LLC
: 1. Exelon                                          Letter to LLC Letter      to USNRC, USNRC, Overall OverallIntegrated Integrated PlanPlan inin Response

===Response===
to March 12, 2012 Commission Order         Order Modifying        Licenses with Modifying Licenses        with Regard Regard to to Requirements for Reliable Spent Fuel for                     Fuel Pool Pool Instrumentation Instrumentation (Order(Order Number NumberEA-1         2-051), dated EA-12-051),       dated February February 28,2013     (RS-13-035) 28, 2013 (RS-13-035)
: 2. NRCNRC Order Number EA-1   EA-12-051, 2-051, Issuance Issuance ofof Order Order toto Modify Modify Licenses      with Regard Licenses with      Regardto   to Reliable Reliable Spent Fuel Pool Instrumentation, Instrumentation, dated dated March March 12, 12, 2012 2012
: 3. USNRC letter to Exelon GenerationGeneration Company, Company,LLC,   LLC, Request Requestfor forAdditional Additional Information Information Regarding Overall Regarding    Overall Integrated Plan for ReliableReliable Spent Fuel  Fuel Pool Pool Instrumentation, Instrumentation, dated dated June 7, 2013 In In Reference         Exelon Generation Reference 1, Exelon       Generation Company, Company, LLC                   provided the LLC (EGC) provided          the Quad Cities Nuclear Power Power Station, Station, Units Units 11 and and 2, 2, Overall Overall Integrated IntegratedPlan PlanininResponse Response to  to the the March March 12, 12, 2012 2012 Commission Order Order Modifying       Licenses with Modifying Licenses         with Regard to Requirements for        for Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation,     pursuant Instrumentation, pursuant to     to  NRC     Order Order   No.       051 EA-12-051 EA              (Reference     2).
purpose of The purpose      of this letter is to provide the response responseto   tothe theNRC NRCrequest requestfor foradditional additionalinformation information (Reference 3) regarding the Quad    Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 22Overall Overall Integrated Integrated Plan Plan in in Response Response to  to the the Commission Commission Order  OrderModifying Modifying Licenses with   with Regard to Requirements Requirements for    for Reliable Reliable Spent Spent Fuel Fuel Pool Pool Instrumentation Instrumentation (Order (Order No.No. EA-12-051).
EA-12-051). Subsequent                issuanceof Subsequent to issuance           of Reference Reference 3, thethe NRC NRC identified identified that Request Requestfor  for Additional Additional Information Information ItemItem No.
No. 6.a 6.a was also applicable applicable toto Quad Quad Cities Cities Nuclear Nuclear Power Power Station, Station, Units Units 11 and and 2. This item
: 2. This    item is included and addressed addressed in in Enclosure Enclosure 11to  to this this letter.
letter.
The Quad Cities Nuclear The                   Nuclear Power Power Station, Station, Units Units 11 and and 22 Spent Fuel Pool Instrumentation design is proceeding proceeding on the schedule schedule identified identified in in the Overall Integrated Plan  Plan provided provided in  in Reference Reference 1. 1.
The enclosed responses The               responsestotothe theNRCNRCrequest requestfor foradditional additional information information are intended intended not not toto provide provide preliminaryor preliminary     orconceptual conceptual information.
information. The requested requestedinformation, information, when when fully fully developed, developed, will  will be

U.S. Nuclear U.S. Nuclear Regulatory Commission Response to Response       to Request Request for Additional Information (Order  (Order EA-1     2-051)
EA-12-051)
July 3,2013 July  3, 2013 Page 22 Page provided upon provided     upon detailed detailed design design completion completion based based on  on the the milestone schedule dates provided in       in each   response.
each response.
This letter This   letter contains contains nono new new regulatory regulatory commitments.
commitments. If         you have If you   have any questions questions regarding regarding this this response, please response,      please contact contact David David P.
P. Helker Helker at 610-765-5525.
IIdeclare declare under under penalty of of perjury perjury that that the the foregoing foregoing isis true true and and correct. Executed Executedon onthe   3rd day the3rd   day of  July   2013.
of July 2013.
Respectfully submitted, Respectfully
   ~~~
Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Exelon                               LLC

==Enclosure:==
: 1. Quad CitiesCities Nuclear Power Station, Station, Units Units 11 and and 22 -- Response ResponsetotoRequest RequestforforAdditional Additional Information --Overall Information       OverallIntegrated Integrated Plan Plan inin Response Response to    to Commission CommissionOrder OrderModifying Modifying License License Requirements for Requirements       for Reliable Reliable Spent SpentFuel FuelPool PoolInstrumentation Instrumentation(Order (OrderNo.
No.EA-12-051)
EA-12-051) cc:     Director, Office of Nuclear Nuclear Reactor Reactor Regulation Regulation NRC Regional Administrator Administrator -- Region Region III III NRC NRC Senior Resident Inspector - Quad     QuadCitiesCities Nuclear Nuclear Power PowerStation, Station, Units Units 11 and and 22 NRC Project Manager, NRR - Quad      QuadCities Cities Nuclear NuclearPower PowerStation, Station,Units Units11and and22 Mr.
Mr. Robert J. J. Fretz, Fretz,Jr, Jr,NRRIJLD/PMB, NRRIJLD/PMB, NRC     NRC Mr. Robert Robert L.L. Dennig, Dennig, NRRIDSS/SCVB, NRRIDSS/SCVB, NRC       NRC Mr. Blake Purnell, Purnell, NRC NRC Project Project Manager, Manager, NRR   NRR Illinois  Emergency Management Illinois Emergency      Management Agency Agency--Division Division of of Nuclear Nuclear Safety Safety

Enclosure Enclosure 11 Quad Quad Cities Nuclear Nuclear Power Station, Station, Units 1 and 2 Response to Request for Additional Information Information Overall Integrated Plan in Response to Commission Order Modifying Overall License Requirements for Reliable Spent Fuel Pool Instrumentation License (Order No. EA-12-051)
EA-12-0S1)
(11 (11 pages)

Response to Response       to Request Request for  for Additional Information (Order EA-12-051)       EA-12-051)
Enclosure Page 1 of 11 Page          11 1.0

==1.0       INTRODUCTION==

INTRODUCTION Byletter By   letterdated dated February February28,    28, 2013 2013 (Agency (Agencywide   wideDocuments DocumentsAccess   Access and   and Management Management System (ADAMS) Accession No. ML13060A124), Exelon Generation Company, LLC, submitted an (ADAMS)       Accession       No. ML13060A124),             Exelon     Generation        Company,        LLC, overall integrated overall   integrated plan  plan (OIP)
(OIP) ininresponse response to the March 12,              2012, U.S.
12,2012,        U.S. Nuclear Nuclear Regulatory Regulatory Commission (NRC)
Commission        (NRC) Order Order modifying modifyinglicenses licenses withwith regard regard to  to reliable reliable spent fuel pool (SFP) instrumentation (Order EA-12-051; instrumentation                   EA-12-051; ADAMS  ADAMS Accession No.           No. ML12054A679)
ML12054A679) for        for Quad Quad Cities Cities Nuclear Power Nuclear     Power Station, Station, Units Units 11and  and 2.2. The NRC NRC staff endorsed endorsed NuclearNuclear Energy Energy Institute, Institute, NEI 12-02, "Industry NEI12-02,       "IndustryGuidance Guidance for    for Compliance Compliance with    with NRC NRC Order EA-12-051, to Modify                       Licenses Modify Licenses with   Regard with Regard      to  Reliable      SFP     Instrumentation,"         Revision      1,  dated Instrumentation," Revision 1, dated August 2012 (ADAMSAugust     2012     (ADAMS Accession No. ML12240A307),
ML12240A307), with        withexceptions exceptions as documented documentedin          in NRC NRC Interim Interim StaffStaff Guidance, Guidance, JLD-ISG-2012-03, "Compliance with JLD-ISG-2012-03,                                with Order Order EA-12-051, EA-12-051, Reliable Spent        Spent FuelFuelPool Pool Instrumentation," Revision Instrumentation,"         Revision 0, dated dated August August 29,  29, 2012 2012(ADAMS (ADAMS Accession AccessionNo.      No.ML12221A339).
ML12221A339).
NRC staff The NRC       staffhas has reviewed reviewedthe    the February February 28,  28, 2013, 2013, response response by the licensee and determined        determined that the following        request for following request                additional information for additional       information (RAI) (RAI)isisneeded needed to    to complete complete its technical review.
2.0      LEVELS OF REQUIRED MONITORING           MONITORING The OIP 01 P states, in  in part, part, that:
Level adequate Level    adequate to    to support supportoperation operationof     ofthe thenormal normalfuel  fuelpool poolcooling coolingsystem system(L1): (L 1):
For both units, indicated level on either primary           primary or backup backup instrument instrumentchannelchannel must be greater greater than than 23  23 feet feet 11inch inch (elevation (elevation 689'  689' 3")
3") plus instrument accuracy above the top of           the storage racks based on of the                                    on the the design design accuracy accuracy of    of the instrument channel (which       (which is to be determined) and          and aaresolution resolution of   of 11foot foot oror better for      both the for both     the primary primary and  and backup backup instrument instrument channels.
channels. This is based     based on   on the the 11  inch opening 11 inch    opening of    of the the SFP weirweir gate design demonstrating demonstrating aa water     water level level above above 23 feet 11 inchinch (elevation (elevation 689'3")
689' 3") isis adequate adequatefor     fornormal normalfuel  fuelpool poolcooling cooling system system operation.
Level     adequate to Level adequate          to provide provide substantial substantial radiation radiation shielding shielding for   for aa person personstanding standingon    on the spent spent fuelfuel pool pool operating operating deck deck (L2):
(L2): For Forboth bothunits, units,indicated indicatedlevel levelon  oneither either the the primary primary or backup instrument  instrument channel channel of   of greater greaterthanthan10    10feet feet(elevation (elevation676'  676' 2")
2")   plus   instrument        channel instrument channel accuracy   accuracy       above     the   top   of  the of the     storage     racks     based based on specification specification of this level as        as adequate adequateininNRC   NRCJLD-ISG-2012-03 JLD-ISG-2012-03(Ref.         (Ref.2)   2)and and NEI NEI 12-02 (Ref.   (Ref. 3),
3), the the specified specified design accuracyaccuracy of   of the instrument instrument channel, channel, and   and the the relatively relatively low        sensitivityof low sensitivity       ofdose dose rates rates to changes changes in     in water water depth depthatatthis thislevel.
level.
This monitoring monitoring level  level ensures ensures there is    is an adequate adequatewater  waterlevel level to to provide provide substantial substantial radiation radiation shielding shielding for for a person person standing standingon    onthethespent spentfuelfuelpool pool operating operating deck   deck from from direct direct gamma gamma radiation radiation fromfrom stored spent   spentfuel.
fuel.
Level Level where fuel remains covered       covered (L3):(L3): For For both both units, units, indicated indicated level level onon either eitherthe the primary primary or backup instrument channel of greater than 0 feet (elevation                       (elevation 6662")
666' 2")plusplus instrument instrument channel accuracy above the                  the top top of of the storage storage racks racks based basedupon   uponthe thedesign design accuracy accuracy (which (which is to  to bebe determined) determined) of     of the the instrument instrumentchannelchannelfor    forboth both the theprimary primary and and backup backup instrument instrument channels.
channels. This This monitoring monitoring level          assures that level assures        that water wateris   is covering covering thethe stored stored fuel fuel seated seatedinin the theracks.
racks.

Response to Response   to Request for Additional Information Information (Order (Order EA-12-051)
EA-12-051)
Enclosure 1 Page 2 of 11 Page       11

===RAI-1===
Please provide the following:
Please a) For a)   For level level LL1,    specify how the 1, specify          the identified identified location location represents the higher of the two points described in the NEI 12-02 guidance    guidance for for this this level.
level.
b) A b)  A clearly clearly labeled labeled sketch sketch depicting the elevation elevation viewview of the proposed proposedtypical typical mounting mounting arrangement for the portions of          of instrument instrument channel channel consisting consisting of of permanent permanent measurement channel measurement          channel equipment equipment(e.g., (e.g., fixed fixed level level sensors sensorsand/or and/orstilling stilling wells, and mounting brackets).
mounting       brackets). Indicate Indicate onon this this sketch sketch thethe datum datum values valuesrepresenting representingL1,   L1,L2, L2, and and L3 as L3   as well well asas the top top of of the the fuel.
fuel. Indicate Indicate on this sketch the     the portion portion of the level     sensor level sensor measurement range measurement           range that thatisis sensitive sensitiveto  tomeasurement measurementofofthe     thefuel fuelpool poollevel, level, with with respect respect to the L1, L 1, L2, L2, and L3 datum points.

===Response===
a) The Spent Fuel Pool a)                          Pool at Quad Cities Cities Station has skimmers and scuppers    scupperslocated locatedat  atthe the 689' 3"'   elevation that 3'" elevation      that water water must must flow flowinto.
into. From From there there the the water is routed to    to surge tanks from       whichthe from which        the Fuel Fuel Pool Pool Cooling Coolingand   and Cleanup Cleanup (FC)(FC)pumps pumps draw draw suction.
suction. The suction trip suction    trip isis at at an an approximate approximate 667'  6676"  6" elevation.
elevation. Thus Thusthethe689' 689'3"'
3'"elevation elevation reflects reflects the higher higher    of  the  two   points   noted   in NEI in NEI     12-02,   section   2.3.1.
Please reference b) Please     reference the  the sketch sketch below.
below. Instrument Instrumentprobe probemounting mounting details details in in the the Spent SpentFuel Fuel area will Pool area      will be provided in accordance accordancewith    with the the response responsetotoRAI-3.
RAI-3.

Response to Request for Additional Information             Information (Order       (Order EA-12-051)
EA-12-051)
Enclosure Enclosure 11 Page 3 of     of 1111
                                                                                                      !      11 EL, 689'-9" EL. 689'-(r                                            r          EL. 689'-9 FlOOR EL EL 6il0'-6" r&deg; i
                  .~:_. 1'"1.
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                          ----, 1 I
EL
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rNORMALL 'riATE' I/EEL EL WATER LEVEL 6Il9'-6" rbty'-6' LEVEL kr.'.~.,                 4
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                                                                                                                                                                                                   ,- -c LEVEL iTER LEVEL EL 669'-3"-7 EL. 6Il9'-:l",
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LEVEL FlOw"R FLOOR EL 690'-6" EL  690'$
LEVEL......
LEVEL-1 PROBE   IE L lEVEL' EL IlB1r-J" EL 66W-3&deg; LEVEL 1 Ir-LEVEL PROBE
                                                                                                                                                                             !l:
UNIT #1 LNIT   # 1 SPENT SPENT FUEL   FLEL                                                                                             gL..l      UNIT #2 UNIT            SPENT FUEL
                                                                                                                                                                                                  #2 SPENT          FUEL SKlt.llJER SKIMMER SURGE, SJROE STORAGE STORAGE POOL                                                                                                                ~~         STORAGE POOL    POOL                                I IS~[IJUER     SURGE SKIMMER SURGE TANK                    \                                      POOL j... ..JI-                                                                            IIJ~       STORAGE                                             V TANKTANK
                                                                                       ~I L..I,
                                                                                            ~~          1 1                EL. 616'-2" LEVEL EL. 515'-t     lEVEL 22         1 1          I ~~
                                                                                                                                                                          "I.JI-
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TF'':SFEH CANAL CF' L                                                                                      5'-5'
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TOP/fJEL T:j /F. ELRACK, i':CK-IF-EL  EL 6S6'-8Yl:'
TOP/FUEL RACK-TOP/FUEL     R FA EL EL 5S6'-t            I I                                                                       EL 668'-2" EL    655'-2"        I lEVELS LEVEL 3             j                                                                                                           LEVEL 3j LEVEL               I EL  665'-6" EL 665'-E'                                                                                                                                                                                                                      EL. 665'-6" EL  665'-5'"
TO TO Fe FC P.iMPS P} MPS -                                                                                                                                                                                                           -t:.. TO FC TO Fe PUIJPS PUMPS I
uIT ~I Uf\IT       I    UNIT #2 33'4 33'-0"                                   ..1                                                 I..                                33'-0" 33'-i"                             a
                                        !jt LO'II LOW POOL           ,oILo\~M lEVEL ALARM POOL LEVEL ELEVATION VI ELEVATION             VIEW

Response to Response    to Request Requestfor     forAdditional AdditionalInformation Information (Order  (OrderEA-1       2-051)
EA-12-051)
Enclosure 1 Page 4 of 11 Page       11 3.0 3.0     INSTRUMENTATION DESIGN FEATURES INSTRUMENTATION 3.2     Arrangement OIP The 01  P states, in part, that:
The current plan  plan is to to install install SFP SFP level level sensors sensors in in the southwest southwest cornercorner of of the Unit Unit 1 SFP and in and  in the the northwest northwest cornercorner of ofthe the Unit Unit22SFP  SFPseparated separated by   by aa distance in    in excess of   of 50 feet. The sensors sensors themselves themselveswill   will be be mounted, mounted, to  to the the extent extentpractical, practical, near nearthe thepool pool walls and walls  and below the pool curb to minimize      minimize their  their exposure exposure to   to damaging debris and        and not not interfere with interfere    withSFP SFP activities.
activities. Instrument channel   channel electronics electronics and  and power powersupplies supplieswill will be be located in     seismic and missile protected areas in seismic                                        areaseither eitherbelow below the the SFP SFPoperating operatingfloor floor or or in in buildings other buildings     other than than the RB [Reactor Building]. Building]. The areas areas to to be beselected selectedwill will provide provide suitable radiation shielding shielding and environmental conditions for                     the equipment consistent for the                     consistent with instrument with  instrumentmanufacturer's manufacturer's recommendations.
recommendations. Equipment     Equipment and   andcabling cabling for for power power supplies and indication indication for each channelchannel will   will be separated separatedequivalent equivalentto    tothat thatprovided providedfor for redundant safety related services as              as required required byby the Quad Quad Cities Cities design basis.basis.

===RAI-2===
Please provide Please  provide aa clearly clearly labeled labeled sketch sketchor  ormarked-up marked-upplant   plantdrawing drawingof    of the theplan planview view ofof the the SFP SFP area, depicting depicting the SFP  SFP inside inside dimensions, dimensions, the     theplanned plannedlocations/placement locations/placementofofthe         theprimary primary andand back-up SFP level level sensor, sensor, and  andthetheproposed proposedrouting  routingof ofthe thecables cablesthat thatwill will extend extend fromfrom the sensors toward sensors  toward the thelocation location of of the the read-out/display read-ouVdisplay device. device.

===Response===
The current plan for        the SFPI for the    SFPI design of the system based          basedon   onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for     for Quad Cities Cities is to begin the design phase       phaseinin October Octoberof     of 2013 2013 withwith the design completion completion and 100%     100% acceptance acceptanceof      ofthethedesign designininMarch March of  of 2014.
2014. The The requested requested information will willbe be provided provided with withthe the August August of     of 2014, 2014, 6-month integrated integrated plan plan update.
update.
3.3     Mounting Mounting The OIP OIP states, states, in in part, part, that:
that:
Design of the  the mounting mounting of    ofthe the sensors sensors in    in the SFP SFP shall shall bebe consistent consistentwith  with the the seismic seismic Class Class II criteria. Installed Insta"ed equipment equipmentwill     will be verified verified to be seismically adequate  adequate for   for the the seismic motions motions associated associatedwith   with the themaximum maximum seismic seismicground groundmotionmotionconsidered consideredininthe    the design design of of the the plant plant area areaininwhich which itit isis installed.
installed.

===RAI-3===
Please provide the  the following:
following:
a) a) The The design design criteria criteria that that will   be used to will be            to estimate estimatethe thetotal total loading loading on  on the themounting mounting device(s), including           static weight including static       weight loads loads and  and dynamic dynamic loads.
loads. Describe Describethe  themethodology methodology that that will will bebe used to estimate estimate the thetotal total loading, loading, inclusive inclusive of  of design design basis basismaximum maximum seismicseismic

Responsetoto Request Response             Requestfor    forAdditional Additional Information Information (Order (Order EA-12-051)
EA-12-051)
Enclosure Page 55 of Page         of 11 11 loads and loads     and thethe hydrodynamic hydrodynamic loads that could result from pool sloshing or other effects                             effects that could that     couldaccompany accompany such     such seismic forces.
b) b) AAdescription description of   ofthe the manner manner in which the level      level sensor sensor(and   (andstilling stillingwell, well, ifif appropriate) appropriate)will will be   attached be attached to the refueling                floorand/or refueling floor        and/orother other support support structures structures for  for each each planned point   point ofofattachment attachment of     ofthethe probe probe assembly.
assembly. Indicate Indicate in   in aa schematic schematicthe     theportions portionsof    ofthe thelevel level sensor that will sensor                   serve as points of will serve                    of attachment attachment for   for mechanical/
mechanical/mountingmounting or      or electrical electrical connections conn     ections..
c)c) AA description descriptionof     ofthethe manner manner by   by which whichthethe mechanical mechanical connections will            will attach attach the level instrument instrument to      topermanent permanent 8FP    SFP structures structures so as    as toto support support the  the level level sensor sensor assembly.
assembly.

===Response===
Response The current The     current plan plan forfor the the 8FPI SFPI design design of of the the system basedbased on    on the thecurrent currentExelon Exelon Nuclear Nuclear program program       schedule       for  Quad      Cities      to begin is to   begin the design phase    phasein     in October Octoberof    of 2013 2013 withwith the design completion design    completion and      and 100%
100% acceptance acceptance of the design in             in March March of    of 2014.             requested 2014. The requested information will information        willbe beprovided providedwith  withthetheAugust Augustofof2014, 2014,6-month 6-monthintegrated integrated plan plan update.
3.4 3.4        Qualification Qualification The OIP The    OIP states, states, in in part, part, that:
that:
Components Components of        of the the instrument instrumentchannels channelswill   will be bequalified qualifiedfor    for shock shockand  andvibration vibration using using oneone or or more more of  of the the following following methods:
     **    components components are       are supplied supplied by  by manufacture manufacturers     rs using usingcommercial commercial quality  quality programs programs (such  (suchasas IS09001,       "Quality 1809001, "Quality management  managemen         t systems systems--Requiremen Requirements")     ts") with withshock shockand  andvibration vibration requirement requirements       s included included in the purchase purchasespecificatio specification     n atat levels levels commensur commensurate             with ate with portable portable hand-held hand-held devicesdevicesor    ortransportatio transportation    n applications applications;      ;
    **    components componentshave       havesubstantial substantialhistory historyofofoperational operationalreliability reliabilityininenvironmen environments         with ts with significant significant       shock     and   vibration      loadings, vibration loadings, such     such as portable portable hand-held hand-held devices devicesor    or transportatio transportation      n applications applications;    ; or or
    **    components components are       areinherently inherently resistant resistant to to shock shock and and vibration vibration loadings, such as           as cables.
cables.
For For seismic effects effects on instrument instrument channel channel components componentsused        usedafterafteraapotential potentialseismic seismicevent event for for only installed components components (with    (with the exception of       of battery chargers chargers and   andreplaceable replaceable batteries),
batteries), the thefollowing         measures will following measures             will be used usedto  toverify verify that the    the design designand  andinstallation installationisis adequate.        Applicable adequate. Applicablecomponents     componentsare       arerated ratedbybythe themanufactur manufacturer     er (or(orotherwise otherwisetested)tested)for for seismic seismic effects effects at at levels levels commensur commensurate     ate with with those those of  of postulated design  design basis basiseventevent conditions conditions in   in the area areaof  of instrument instrument channel channel component componentuse       useusingusingone oneorormore moreofofthe  the following following methods:
methods:
    ** instrument instrument channel channel components componentsuse        useknown knownoperating operatingprinciples principlesand   andare aresupplied suppliedby by manufactur manufacturers    ers with with commercial commercial quality quality programs programs (such   (such as  as 1809001).
IS09001). The     Theprocuremen procurement   t specificatio speCification     n and/or and/or instrument instrument channel channel design designshall shall include include the theseismic seismicrequirement requirements  s and andspecify specify the theneed needfor  forcommercial commercial design designand  andtesting testingunder underseismic seismicloadings loadings consistent consistentwith    with design designbasisbasisvalues valuesatatthe theinstalled installedlocations; locations;

Response to Request Request for Additional Additional Information Information (Order (OrderEA-12-051)
EA-12-051)
Enclosure   1 Page 66of11 Page      of 11
* substantial history substantial    historyof  of operational operationalreliability reliability in in environments environmentswith     withsignificant significantvibration, vibration, such asas for for portable portable hand-held hand-held devicesdevices or  or transportation transportation applications.
applications. Such  Sucha avibration vibration design envelope envelope shallshall be beinclusive inclusive of  of the the effects effectsof  of seismic seismicmotion motion imparted imparted to  to the the components proposed proposed at   atthe thelocation location of  of the the proposed proposedinstallation; installation;
* adequacy of adequacy      of seismic design and     and installation installation is    is demonstrated based   based on  on the the guidance guidancein      in Sections 7, Sections       8, 9, and 7,8,9,     and10  10ofofIEEE IEEE[Institute
[Institute of  of Electrical Electrical and and Electronics Electronics Engineers]
Engineers]
Standard 344-2004, Standard     344-2004, "IEEE "IEEE Recommended RecommendedPractice      Practicefor  forSeismic SeismicQualification QualificationofofClass Class1 1EE Equipment for  for Nuclear Power Generating Generating Stations,"
Stations," or   or aasubstantially substantiallysimilar similarindustrial industrial standard;
* demonstration that proposedproposed devices devices are  aresubstantially substantiallysimilarsimilar in in design to   to models models thatthat have been previously previously tested for seismic effects       effects in  in excess excess of the plantplant design design basis at the location where the instrument is to be installed location                                               installed (g-levels (g-Ievels and and frequency frequency ranges);
ranges); or  or
* seismic qualification qualification usingusing seismic motionmotion consistent with              that of with that    of existing existing design design basis loading at the installation installation location.
location.
RAi-4 Please provide the following:
a) A A description of   of the the specific method or combination of methods               methods you you intend intend toto apply applyto   to demonstrate the demonstrate       the reliability reliability ofof the the permanently installed installed equipment under beyond-design-beyond-design-basis ambient ambient temperature, temperature,humidity, humidity, shock, shock, vibration, vibration, and and radiation radiation conditions.
conditions.
b) A b)       description of A description      ofthe the testing testing and/or and/or analyses analyses that will          be conducted will be    conducted to    to provide provide assurance assurance that the equipment equipment will        perform reliably will perform       reliablyunderunderthe  the worst-case worst-case credible design basis      basis loading at loading    at the the location      where the location where          the equipment will     willbe bemounted.
mounted. Include Include a discussion of         of this seismic reliability       demonstration as reliability demonstration            as it   applies to a) the level sensor it applies                          sensor mounted mountedin    in the the SFP area, area, and andb) b) any anycontrol control boxes, boxes,electronics, electronics, or     orread-out read-outand  andre-transmitting re-transmitting devicesdevices that will   be employed to convey the level will be                                       level information information from  from thethe level level sensor sensor to to the the plant plant operators or emergency responders. responders.
c) A c)       description of A description      of the the specific method or combination of methods              methods thatthat will will be used used to to confirm the confirm    the reliability reliabilityof  ofthe the permanently permanently installed equipment   equipment such  suchthatthatfollowing following aa seismic event event the the instrument instrumentwill   will maintain its required accuracy. accuracy.

===Response===
The current plan for  for the the SFPI SFPI design of the system based          based on  on the thecurrent currentExelon Exelon Nuclear Nuclear program schedule schedule forfor Quad Cities Cities isis to to begin begin thethe design design phasephaseininOctober Octoberofof2013 2013withwiththethe design completion completion and  and 100% acceptance of            of the design in      in March March of   of 2014.
2014. The requested requested information will information    willbebeprovided provided with withthethe August August of  of 2014, 2014, 6-month 6-month integrated plan      plan update.
update.
3.5      Independence The OIP 01 P states, inin part, part, that:
that:
The primary primary instrument channel will                be independent will be    independent of the backup instrument channel.            channel.
This independence independence will          be achieved through physical and electrical will be                                                   electrical separation of each channels' components components commensurate commensuratewith        with hazard hazardand  andelectrical electricalisolation isolation needs.
needs.

Response to Request for AdditionalAdditional Information Information (Order (OrderEA-12-051)
EA-12-051) 1 Enclosure Page 7 of of 1111

===RAI-5===
Please provide the following:
a) A    description of A description        of how howthe thetwo twochannels channels ofofthe the proposed proposed level level measurement measurement system  system meet meet this requirement so that the potential   potential for a common cause    cause event eventto  toadversely adverselyaffect affectboth both channels isis minimized channels          minimized to the extent extent practicable.
practicable.
b) Further information b)             informationon     onhow howeacheach level levelmeasurement measurement system, consisting of             of level sensor sensor electronics, cabling, electronics,      cabling, andand readout readout devices will         be designed will be    designed andand installed installed to to address address independence through the application independence                           application and selection of independent power sources, the                  the use of of physical and spatial separation, separation, independence independenceofofsignals  signalssent senttotothe thelocation(s) location(s)ofof the readout devices, and       and the the independence independenceof     ofthe thedisplays.
displays.

===Response===
The current plan for  for the the SFPI SFPI design of the system based      basedon   onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for    for Quad Cities is to begin the design phase         phaseinin October Octoberof   of 2013 2013 with with the design completion completion and    and 100% acceptance acceptance of   of the design in   in March March of  of 2014.
2014. The requested requested information will information    willbebeprovided providedwith  withthe theAugust Augustofof2014, 2014,6-month 6-month integrated integrated plan plan update.
3.6    Power supplies The OIP states, in   in part, that:
Each channel channel willwill be normally normally powered powered from from aadifferent different 120Vac 120Vac[120 [120volts-alternating volts-alternating current] bus. Upon current]             Upon loss lossofofnormal normalac  acpower, power,individual individual channel channel installed installedbatteries batterieswill will automatically maintain automatically        maintaincontinuous continuous channel channel operation.
operation. The  The batteries batteries will will be replaceable replaceable and be sizedsized toto maintain maintain channel channel operation operation until until off-site off-site resources can be     be deployed deployed by by the mitigating       strategies resulting mitigating strategies       resulting from from Order Order EA-12-049 EA-12-049 (Ref.(Ref. 4).
4). Additionally, Additionally, each each channel will       have provisions will have     provisions for for connection connection to  to another another suitable power source. source.

===RAI-6===
Please provide the following:
a) A    description of A description        of the the electrical electrical ac ac power sources sources and and capacities capacitiesfor forthe theprimary primary andand backup channels.
b) IfIfthe b)      the level levelmeasurement measurement channels are        are to to be be powered powered through through aabattery batterysystem system(either (either directly     or through directly or through         an   uninterruptible    power     supply),   please    provide    the  design please provide the design criteria criteria that will will bebe applied applied to to size size the the battery battery in in aa manner manner that ensures, ensures, withwith margin, that the channel will       be available to run reliably and continuously following will be                                                            following the the onset onset of the beyond-design-basis event beyond-design-basis             event for for the the minimum       duration needed, consistent minimum duration                     consistent withwith the plant plant mitigation strategies mitigation      strategies for for beyond-design-basis beyond-design-basis external  external events events(Order (OrderEA-12-049).
EA-12-049).

                                                                                                                       ~~-~  ---~~----
Response to Request Request for for Additional Additional Information Information (Order (OrderEA-1       2-051)
EA-12-051) 1 Enclosure Page 8 of of 11 11

===Response===
Response The current plan forfor the the SFPI SFPI design of the system based       basedon  onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for Quad Cities is to begin the design phase               phaseinin October Octoberof   of 2013 2013 with with the design completion completion      and    100%     acceptance acceptance of   of  the  design    in  March     of in March of 2014.2014. The   requested requested information will information   willbe beprovided provided with withthe the August August of of 2014, 2014, 6-month integrated integrated plan plan update.
update.
3.7    Accuracy The OIP states, in in part, part, that:
The instrument channels channels will will be designed designed to  to maintain maintain their their design design accuracy accuracyfollowing following aa interruption or power interruption          or change change in  in power source without recalibration.
recalibration. Instrument Instrument channel channel accuracy, to be  be determined determinedduringduring detailed detailed design, design,willwill consider consider Spent SpentFuel FuelPool Pool conditions (e.g.,
conditions     (e.g., saturated saturated water, steam environment, environment, concentrated borated water), as                   as well   as, other applicable radiological well as,                           radiological and environmental conditions and include            include display accuracy. Instrument Instrumentchannelchannelaccuracy accuracywill will be besufficient sufficient toto allow allow trained personnel personnelto    to determine when the      the actual actual level level exceeds exceedsthe  thespecified specifiedlower lowerlevel levelofofeach eachindicating indicating range (levels (levels 1,1, 22 or or3)3) without without conflicting conflicting or ambiguous ambiguous indications.
indications.

===RAI-7===
Please provide the following:
a) An An estimate of   of the the expected instrument channel accuracy        accuracy performance performance under under both both a)  a) normal SFP level conditions (approximately normal                                  (approximately LL1         or higher) 1 or  higher)and and b)b) at at the the beyond design-basis conditions conditions (i.e., radiation, temperature, temperature, humidity, humidity, post-seismic and      and post-shock post-shock conditions) that conditions)     that would would be  be present present ifif the SFP level level were at  at the the L2L2 and and L3L3 datum datum points.
points.
b) A b)     description of the methodology A description                methodology that  that will will be used used for for determining determiningthe   themaximum maximumallowedallowed deviation from deviation    from thethe instrument instrument channel channel design accuracy accuracy thatthat will will be employed under  under normal operating conditions normal                    conditions as an   an acceptance acceptancecriterion criterionforfor aacalibration calibration procedure procedureto     toflag flag to operators and and to  to technicians technicians that that the the channel channelrequires requiresadjustment adjustmenttotowithinwithin the the normal normal condition design condition    design accuracy.

===Response===
Response The current plan forfor the the SFPI SFPI design of the system based       basedon  onthe thecurrent currentExelon Exelon Nuclear Nuclear program schedule schedule for for Quad Quad Cities Cities is is to to begin begin the the design designphasephaseininOctober Octoberofof2013 2013with withthe the design completion completion and  and 100% acceptance of          of the design in    in March March of  of 2014.
2014. The requested requested information will information   willbe beprovided provided with withthe the August August ofof 2014, 2014, 6-month 6-month integrated plan   plan update.
update.
3.8    Testing The OIP states, in part, that:

Response to Response     to Request for   for Additional Information (Order   (Order EA-1       2-051)
EA-12-051)
Enclosure Page 9 of 11 Page Instrument channel Instrument       channel design will        provide for will provide     for routine routine testing testing and and calibration        consistent with calibration consistent         with the guidelines of NRC the                      NRC JLD-ISG-2012-03 JLD-ISG-2012-03 (Ref.     (Ref. 2)
: 2) and and NEI NEI 12-02 (Ref.  (Ref. 3).
3). Details Details will will be determined during determined       during detailed detailed design design engineering.

===RAI-8===
Please provide Please    provide the following:
a) AA description a)      description of  of the the capability capability andand provisions the proposed proposed levellevel sensing sensingequipment equipmentwill  will have to enable enable periodic periodic testing and  and calibration, calibration, including including how this capability             enables the capability enables        the equipment to    to be tested tested in-situ.
in-situ.
b) A b)   A description description of  of how how suchsuch testing andand calibration calibration will      enable the conduct will enable            conduct of of regular regular channel checks of channel                of each each independent channel against the other, and against any                       any other other permanently-installed SFP level instrumentation.
permanently-installed c) A c)   A description description of  of how how functional functionalchecks checks will willbebe performed, performed, and  and the frequency frequency at  at which which willbe they will    beconducted.
conducted. Describe Describe howhow calibration calibration tests testswill will be performed, performed, and    and the the frequency at which frequency          whichtheytheywillwillbebeconducted.
conducted. Provide Provide aa discussion discussion as to how these surveillances will       be incorporated into the plant will be                                 plant surveillance surveillance program.
program.
d) A d)   A description description of   ofwhat whatpreventative preventativemaintenance maintenance tasks  tasks are required required to be     be performed performed during normal during   normal operation, operation, and the plannedplanned maximum maximum surveillance surveillance interval interval that that is is necessary to necessary      to ensure ensurethat thatthe thechannels channelsare arefully fullyconditioned conditionedto     toaccurately accuratelyand   andreliably reliably perform their perform    their functions functions when when needed.
needed.

===Response===
Response The current plan for the SFPI design of the system based              basedon   onthethecurrent currentExelonExelonNuclear Nuclear program schedule for     for Quad Cities is to begin the design     design phase phaseininOctober Octoberof     of 2013 2013 with with the design completion completion and 100%   100% acceptance acceptanceof    ofthe thedesign designininMarch March of of 2014.
2014. Following Following thetheissue issueofof the the design, design, procedures procedureswill   will start start being being developed developedwith  with aaprojected projectedOctober October2014   2014completion completion date. The Therequested requestedinformation informationwill  will be beprovided providedininthe theAugust August2014, 2014,6-month 6-monthintegrated integratedplan plan update.
update.
3.9     Display Display The The OIP OIP states, states, inin part, part, that:
that:
The The primary primary and and backup backup instrument instrument displays displayswillwill be located located at  at the thecontrol control room, room, alternate alternate shutdown shutdown panel,panel, or or other other appropriate appropriate and accessible accessiblelocation.
location. TheThe specific specific location location willwill bebe determined during detailed detailed design.
design.An  An appropriate appropriateand   and accessible accessiblelocation locationwillwill include includethethefollowing following characteristics:
characteristics:
        **   occupied occupied promptly promptly accessible accessibleto   tothe theappropriate appropriateplant plantstaff staffgiving giving appropriate appropriate consideration consideration to    to various various drain drain down down scenarios, scenarios,

Response to Response      to Request for Additional Information (Order         (Order EA-12-051)
EA-12-051)
Enclosure Page 10 of 11 Page           11
         **    outside the outside    the area area surrounding surrounding the SFP floor           (e.g., an floor (e.g.,  an appropriate appropriate distance fromthe from    the radiological radiologicalsources sources resulting resulting from from an an event event impacting impacting thethe Spent Fuel  Pool),
Fuel Pool),
         **    inside aa structure inside      structure providing providingprotection protectionagainstagainstadverse adverse weather, and
         **    outside of any Very outside               Very High High radiation areas areasororLOCKED LOCKEDHIGH    HIGH RAD RAD AREA AREA during normal during    normal operation.

===RAI-9===
Please provide the following:
Please a) The specific a)          specific location location for foreach each of of the the primary primary and and backup backup instrument channel displays.
b) IfIfthe b)       the primary primaryand  and backup backup display location location is other than the  the main main control control room, room, provide provide justification for justification    forprompt prompt accessibility accessibility to  to displays displays including primary and alternate  alternate route route evaluation, habitability evaluation,     habitability at  at display display location(s),
location(s), continual continual resource availability availability forfor personnel personnel responsible to promptly promptly read displays, displays, and andprovisions provisionsforforcommunications communicationswith      with decision decision makers for for the the various various SFPSFP drain drain down down scenarios scenarios and external events.
c) The reasons c)          reasons justifying justifying why the locations selected selected enable enablethe theinformation information from from these these instruments to be considered "promptly                   accessible" to "promptly accessible"          to various various drain-down drain-down scenarios scenarios and external events.

===Response===
Response The current plan for  for the the SFPI SFPI design of the system based       basedon onthe thecurrent currentExelon ExelonNuclear Nuclear program schedule for Quad Cities is to begin the design phase                 phasein  in October Octoberof  of 2013 2013 withwith the design completion completion and  and 100% acceptance acceptance of     of the design in in March March of  of 2014.
2014. The requested requested information information willwillbe be provided provided with withthethe August August of   of 2014, 2014, 6-month integrated integrated planplan update.
update.
4.0      PROGRAM PROGRAM FEATURES FEATURES 4.2      Procedures Procedures The OIP 01 P states, states, in in part, part, that:
that:
Procedures Procedures will  will be developed using   using guidelines and   and vendor vendor instructions instructions to address addressthe the maintenance, operation operation andand abnormal abnormal response responseissues issuesassociated associatedwith withthetheprimary primaryand and backup channels channels of    of SFP SFPinstrumentation.
instrumentation.

===RAI-10===
RAI-10 Please Pleaseprovide provideaadescription descriptionof    ofthe thestandards, standards,guidelines guidelinesand/or and/orcriteria criteriathat thatwill willbe beutilized utilized to to develop    procedures      for   inspection, develop procedures for inspection,              maintenance,        repair, repair, operation,      abnormal     response, response, and  and administrative     controls associated administrative controls         associated with with the SFPSFP level level instrumentation, as    as well well as storage storage and and installation installation ofof portable portable instruments.
instruments.

Responseto Response      to Request Request for  for Additional Additional Information (Order EA-1       EA-12-051) 2-051)
Enclosure Enclosure    1 Page 11 Page   11 of of 11 11

===Response===
Response The current The   current plan planforforthe theSFPI SFPIdesign design of  ofthe the system system based on    on the the current current Exelon Exelon Nuclear Nuclear program   schedule program schedule for     for Quad Quad Cities Cities isis to to begin begin thethe design design phase phase in in October October of 2013 with   with the design completion design   completion and    and 100%
100% acceptance acceptance of    of the design design inin March March of 2014.         Following the issue 2014. Following               issue of of the design, the  design, procedures procedures will  will start being developed developed with  with aa projected projected October October 20142014completion completion date. The date. The requested requestedinformation information will      be provided will be    provided in  in the the August August 2014, 2014, 6-month 6-month integrated integrated planplan update.
update.
4.3 4.3      Testing and Testing      and Calibration The OIP The   OIP states, in part, that:
The testing The    testing and calibration calibration of the instrumenta instrumentationtion will will be consistent consistent with      vendor with vendor recommend recommendations   ations   or  other  documented basis. basis. Calibration Calibrationwill  will be be specific specific to the mounted instruments mounted       instruments and   and the the displays.
displays. Instrument Instrument performanc performance        will be e will  be trended trended as described in Exelon described                     procedural requirements.
Exelon procedural          requirements.

===RAI-11===
RAI-11 Please provide the following:
Please a)  Further information a) Further     informationdescribing describingthe   the maintenance maintenance and  and testing testing program program the thelicensee licenseewill will establish establish and and implement implement to ensureensure that thatregular regular testing testing andandcalibration calibration is is performed performed and  and verified verified by by inspection inspection and and audit audit to  to demonstrate demonstrate conformance conformance with   with design design and system readiness readiness requirement requirements. s. Include Includeaadescription descriptionof  of your your plans plans for for ensuring ensuring that necessary necessary channel     checks,     functional    tests,   periodic channel checks, functional tests, periodic calibration, and calibration,    andmaintenance maintenancewill   will be beconducted conducted for  the level for the            measurement system level measurement           system and   anditsitssupporting supporting equipment.
equipment.
b) A b)  A description description of   of how how thethe guidance in NEI    NEI 12-02 Section 4.3 regarding compensato   compensatory     ry actions actions forfor one one or or both both non-functio non-functioning ning channels channels willwill be addressed.
addressed.
c) A c)     description of A description       of what what compensatory compensatory actions are planned in                       event that in the event     that one one of of the the instrument      channels instrument channels cannot becannot     berestored restoredtotofunctional functional status statuswithin within 9090 days.
days.

===Response===
Response The The current current plan plan for for the SFPI design design of  of the the system system based basedon  onthethecurrent currentExelon ExelonNuclear Nuclear program    schedule      for  Quad    Cities   is program schedule for Quad Cities is to begin the to  begin     the design designphase phaseininOctober Octoberofof2013 2013with with the the design designcompletion completion and   and 100%
100%acceptance acceptanceofofthe     thedesign designininMarch Marchof   of2014.
2014.Following Followingthe  theissue issueofof the thedesign, deSign,procedures procedureswill   willstart startbeing beingdeveloped developedwith   withaaprojected projectedOctober October2014 2014completion completion date.
date.The Therequested requested    information informationwill willbebeprovided providedininthe theAugust August2014, 2014,6-month 6-monthintegrated integratedplan  plan update.
update.}}