RS-14-020, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No EA-12-051)

Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No EA-12-051)

ML14062A060
Person / Time
Site:	Dresden
Issue date:	02/28/2014
From:	Kaegi G T Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-020
Download: ML14062A060 (14)

Text

ti RS-14-020 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Order No. EA-12-051 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

Subject:

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)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012 2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012 4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012 5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051

), dated February 28, 2013 (RS-13-030)

6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051

), dated August 28, 2013 (RS-13-118)

7. NRC letter to Exelon Generation Company, LLC, Dresden Nuclear Power Station, Units 2 and 3-Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF1050 and MF1051), dated October 29,2013 U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page2 On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to install reliable spent fuel pool level instrumentation.

Specific requirements are outlined in Attachment 2 of Reference

1. Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI12-02, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference

2. Reference 4 provided the EGC initial status report regarding reliable spent fuel pool instrumentation.

Reference 5 provided the Dresden Nuclear Power Station, Units 2 and 3 overall integrated plan. Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Dresden Nuclear Power Station. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference

1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference

7. 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 28 1 h day of February 2014. Respectfully submitted, Glen T. Kaegi Director -Licensing

& Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation Enclosure Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (11 pages)

Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Dresden Nuclear Power Station, Units 2 and 3, developed an Overall Integrated Plan (Reference 1 ), documenting the requirements to install reliable spent fuel pool level instrumentation (SFP Ll), in response to Reference

2. This enclosure provides an update of milestone accomplishments since submittal of the first six month status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. 2 Milestone Accomplishments The following milestones have been completed since the development of the First six month status report (Reference 6), and are current as of February 28, 2014.

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

I Revised Milestone Target Completion Activity Target Date Status Completion I Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Response to RAis July 18, 2013 Complete Submit 6 Month Updates: I Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete with this submittal Update 3 August 28, 2014 Not Started Update 4 February 28, 2015 Not Started Provide Final Safety Evaluation April 30, 2015 Not Started Page 1 of ll Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 Milestone Target Completion Activity Date Status (SE) Info Update 5 August 28, 2015 Not Started Update 6 February 28, 2016 Not Started Update 7 August 28, 2016 Not Started

• Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 102015 Complete procure SFPI Equipment Begin Detailed Engineering 302014 Not Started Design for Unit 2 Complete and Issue SFPI 402014 Not Started Modification Package for Unit 2 Begin Detailed Engineering 302014 Not Started Design for Unit 3 Complete and Issue SFPI 402015 Not Started Modification Package for Unit 3 Begin SFPI Installation for Unit 2 302015 Not Started Complete S FPI Installation for 402015 Not Started Unit 2 and Put Into Service Begin SFPIInstallation for Unit 3 302016 Not Started Complete SFPI Installation for 402016 Not Started Unit 3 and Put Into Service 4 Changes to Compliance Method Revised Target Completion Date 402014 There are no changes to the compliance method as documented in the Overall Integrated Plan (Reference 1). 5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Dresden Nuclear Power Station, Units 2 and 3, expects to comply with the order implementation date and no relief/relaxation is required at this time. Page 2 of 11 Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Safety Evaluation (ISE) and the status of each item. Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete Continuous level indication will be (Addressed in Reference

6) provided by a guided wave radar system, submersible pressure transducer, or other appropriate level sensing technology that will be determined during the detailed engineering phase of the project. 2 RAI Question:

Complete (RAI-1, Please provide the following: (Addressed in Reference

4) Ref. 4) a) For Level 1 , specify how the identified location represents the higher of the two points described in the NEI 12-02 guidance for this level. b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of the instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets).

Indicate on this sketch the datum values representing Level 1, Level2, and Level 3 as well as the top of the fuel. Indicate on this sketch the I portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1 , Level 2, and Level 3 datum points. 3 RAI Question:

Not Started. (RAI-2, Please provide a clearly labeled sketch Note that the completion date for Unit 3 Ref.4) or marked-up plant drawing of the plan design has changed from December view of the SFP area, depicting the SFP 2015 to December 2014. The design inside dimensions, the planned information for Unit 2 and Unit 3 is locations/placement of the primary and intended to be provided in the February back-up SFP level sensor, and the 2015 6-month Integrated Plan update. proposed routing of the cables that will Page 3 of 11 I I 4 (RAI-3, Ref.4) 5 (RAI-4, Ref.4) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 extend from the sensors toward the location of the read-out/display device. RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) The design criteria that will be used design has changed from December to estimate the total loading on the 2015 to December 2014. The design information for Unit 2 and Unit 3 is mounting device(s), including static intended to be provided in the February weight loads and dynamic loads. Describe the methodology that will be 2015 6-month Integrated Plan update. used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces. b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.

Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

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

RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) A description of the specific method design has changed from December or combination of methods you intend to 2015 to December 2014. The design information for Unit 2 and Unit 3 is apply to demonstrate the reliability of intended to be provided in the February the permanently installed equipment under beyond-design-basis ambient 2015 6-month Integrated Plan update. temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this Page 4 of ll I I I I 6 (RAI-5, Ref.4) 7 (RAI-6, Ref. 4) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

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

RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) A description of how the two design has changed from December channels of the proposed level 2015 to December 2014. The design measurement system meet this information for Unit 2 and Unit 3 is intended to be provided in the February requirement so that the potential for a 2015 6-month Integrated Plan update. common cause event to adversely affect both channels is minimized to the extent practicable.

b) Further information describing the design and installation of each level measurement system, consisting of level sensor electronics, cabling, and readout devices. Please address how independence of these components of the primary and back-up channels is achieved through the application of independent power sources, physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) A description of the electrical ac design has changed from December power sources and capacities for the 2015 to December 2014. The design primary and backup channels.

information for Unit 2 and Unit 3 is intended to be provided in the February b) If the level measurement channels 2015 6-month Integrated Plan update. are to be powered through a battery system (either directly or through an Page 5 of 11 I I I 8 {RAI-7, Ref.4) 9 {RAI-8, Ref.4) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 Uninterruptible Power Supply), please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the beyond-design-basis event for the minimum duration needed, consistent with the plant mitigation strategies for beyond-design-basis external events (Order EA-12-049).

RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 c) An estimate of the expected design has changed from December instrument channel accuracy 2015 to December 2014. The design performance (e.g., in percent of span) information for Unit 2 and Unit 3 is under both a) normal SFP level intended to be provided in the February conditions (approximately Level 1 or 2015 6-month Integrated Plan update. higher) and b) at the beyond-design-basis conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at the Level 2 and Level 3 datum points. d) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) A description of the capability and design has changed from December provisions the proposed level sensing 2015 to December 2014. The requested equipment will have to enable periodic information for Unit 2 and Unit 3 is testing and calibration, including how intended to be provided in the February this capability enables the equipment to 2015 6-month Integrated Plan update. be tested in-situ. b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, Page 6 of 11 I I I 10 (RAI-9, Ref. 4) 11 (RAI-10, Ref.4) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 and against any other permanently-installed SFP level instrumentation.

c) A description of how calibration tests and functional checks will be performed, and the frequency at which they will be conducted.

Discuss how these surveillances will be incorporated into the plant surveillance program. d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed. RAI Question:

Replaced by Interim SE RAI #11 (ref. 5). Please provide the following:

Note that the completion date for Unit 3 a) The specific location for each of the design has changed from December primary and backup instrument channel 2015 to December 2014. The design information for Unit 2 and Unit 3 is displays.

intended to be provided in the February b) If the primary and backup display location is other than the main control 2015 6-month Integrated Plan update. room, provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain down scenarios and external events. c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible." Include consideration of various drain-down scenarios.

RAI Question:

Replaced by Interim SE RAI #12 (ref. 5). Please provide the following:

Note that the completion date for Unit 3 a) A list of the operating (both normal design has changed from December and abnormal response) procedures, 2015 to December 2014. The requested information for Unit 2 and Unit 3 is calibration/test procedures, intended to be provided in the February maintenance procedures, and inspection procedures that will be 2015 6-month Integrated Plan update. Page 7 of 11 I I 12 (RAI-11, Ref.4) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 developed for use of the SFP instrumentation in a manner that addresses the order requirements.

b) A brief description of the specific technical objectives to be achieved within each procedure.

If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable components when needed. RAI Question:

Not Started. Please provide the following:

Note that the completion date for Unit 3 a) Further information describing the design has changed from December 2015 to December 2014. The requested maintenance and testing program the information for Unit 2 and Unit 3 is licensee will establish and implement to intended to be provided in the February ensure that regular testing and 2015 6-month Integrated Plan update. calibration is performed and b)verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

Include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

c) A description of how the guidance in NEI12-02, Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

d) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days. Page 8 of ll I I I I I I I I I 01# 1 (RAI-3, Ref. 5) 2 (RAI-4, Ref. 5) 3 (RAI-6, Ref. 5) 4 (RAI-8, Ref. 5) 5 (RAI-11, Ref. 5) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 20i 4 Interim Safety Evaluation Open Items Description Status RAI Question:

Not Started. For RAI 2(a) above, please provide the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including design-basis maximum seismic loads and hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces. RAI Question:

Not Started. For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

RAI Question:

Not Started. For RAI #5 above, please provide the results for the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

RAI Question:

Not Started. Please provide the following:

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

b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured. RAI Question:

Not Started. Please provide the following:

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

b) If a display will be located somewhere Page 9 of ll ! I I 6 (RAI-12, Ref. 5) Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 other than the control room or alternate shutdown panel, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

RAI Question:

Not Started. Please provide a list of the procedures addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the spent SFP instrumentation.

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

Note: RAis not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAisin Reference 3 and are listed in the Overall Integrated Plan Open Item Table. 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time. 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Exelon Generation Company, LLC, letter to USNRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Page 10 of 11 I I Dresden Nuclear Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (RS-13-030) 2. NRC Order Number EA-12-051, "Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012. 3. USNRC letter to Exelon Generation Company, LLC, "Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation", dated June 26, 2013. 4. Exelon Generation Company, LLC, letter to USNRC, "Response to Request for Additional Information-Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)", dated July 18,2013 (RS-13-176).

5. USNRC letter to Exelon Generation Company, LLC, "Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", dated October 29, 2013. 6. First Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 28,2013 (RS-13-118).

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