ML15058A630

LaSalle, Units 1 and 2 - 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)

ML15058A630
Person / Time
Site:	LaSalle
Issue date:	02/27/2015
From:	Kaegi G T Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-029
Download: ML15058A630 (18)

Text

Exelon Generation Order No. EA-12-051 RS-15-029 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

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)

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-13-031) 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-13-120) 7. 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-14-021) 8. 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-14-199)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 27, 2015 Page 2 9. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2 - 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. MF1119 and MF1120), dated November 26, 2013 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 NEI 12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGO initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the LaSalle County Station, Units 1 and 2 overall integrated plan. Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6, 7, and 8 provided the first, second, and third six-month status reports, respectively, pursuant to Section IV, Condition 0.2, of Reference 1 for LaSalle County Station. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition 0.2, 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 9. 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 27th day of February 2015. Respectfully submitted, Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 27, 2015 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector - LaSalle County Station, Units 1 and 2 NRC Project Manager, NRR - LaSalle County Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Stephen R. Monarque, NRR/JLD/JPMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. John Boska, NRR/JLD/MSD, NRC Mr. Nicholas DiFrancesco, NRR/DORULPL3-2, NRC Illinois Emergency Management Agency - Division of Nuclear Safety Enclosure LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (14 pages)

LaSalle County Station, Units 1 and 2 Fourth 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 LaSalle County Station, Units 1 and 2, developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI), in response to NRC Order EA-12-051 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the Third 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 Third six month status report (Reference 8), and are current as of February 6, 2015.

• Installation is complete

• Testing is in progress 3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed. The revised milestone target completion dates do not impact the order implementation date. Milestone Target Completion Date Activity Status Revised Target Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls July 5, 2013 Complete Submit 6 Month Updates: Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete Update 4 February 27, 2015 Complete with Page 1 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Milestone Target Completion Date Activity Status Revised Target Completion Date submittal Provide Final Safety Evaluation (SE) Info September 30, 2014 Complete Modifications: Conceptual Design 302012 Complete Begin Detailed Design Engineering 202013 Complete Issue Exelon Fleet contract to procure SFPI Equipment 402013 Complete Complete and Issue SFPI Modification Package 202014 Complete Begin Installation 302014 Complete Complete SFPI Installation and Put Into Service 102015 Started 4 Changes to Compliance Method 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 LaSalle County Station, Units 1 and 2, expects to comply with the order implementation date and no relief/relaxation is required at this time. 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference 1) or the Draft Safety Evaluation (SE) and the status of each item. Page 2 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete. (Addressed in Reference 6) Continuous level indication will be 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-1, Ref. 4) RAI Question: Complete. (Addressed in Reference 4) Please provide following: 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 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, Level 2, and Level 3 as well as the top of the fuel. Indicate on this sketch the 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-2, Ref. 4) RAI Question: Complete. (Addressed in Reference 4) Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFP area, depicting the SFP inside dimensions, the planned locations/placement of the primary and back-up SFP level Page 3 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device. 4 RAI Question: Complete. (RAI-3, Ref. 4 / Please provide the following: a) The design criteria that will be (Addressed in Reference 8) RAI-4 used to estimate the total Ref 8 ) . loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be 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. 5 RAI Question: Complete. (RAI-4, Ref. 4 Please provide the following: a) A description of the specific (Addressed in Ref 8) RAI-5 method or combination of ) . Ref 8 methods you intend to apply to demonstrate the reliability of the permanently installed equipment Page 4 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 under BDB ambient 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 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. 6 RAI Question: Complete. (RAI-5, Ref. 4 / Please provide the following: a) A description of how the two (Addressed in Reference 8) RAI-6 channels of the proposed level measurement system meet Ref. 8) this requirement so that the potential for a common cause event to adversely affect both channels is minimized to the extent practicable. b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent Page 5 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays. 7 RAI Question: Complete. (RAI-6, Ref. 4 / Please provide the following: a) A description of the electrical (Addressed in Reference 8) RAI-7 ac power sources and capacities for the primary and Ref. 8) 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 water level indication function until offsite resource availability is reasonably assured. 8 RAI Question: Complete. (RAI-7, Ref. 4/ Please provide the following: a) An estimate of the expected (Addressed in Reference 8) RAI-8 instrument channel accuracy Ref. 8) performance (e.g., in percent of span) under both (a) normal SFP level conditions (approximately Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions} that would be present if the SFP water level were at the Level 2 and Level 3 datum points. b) 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 Page 6 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy. 9 RAI Question: Started. (RAI-8, Ref. 4 / Please provide the following: a) A description of the a) Addressed in Reference 8. RAI-9 capability and provisions the b) Addressed in Reference 8. Ref. 8) proposed water level sensing c) LaSalle Station procedures are in equipment will have to enable periodic testing and calibration, including how development and are listed on the Affected Document List of Engineering this capability enables the Change. Procedures that are required equipment to be tested in- to be issued prior to Operations situ. Acceptance are identified. The required b) A description of how such procedures are due to be completed testing and calibration will enable the conduct of regular 2/20/2015. channel checks of each independent channel against the other, and against any other permanently-installed d) Addressed in Reference 8. SFP level instrumentation. c) A description of how functional checks will be performed, and the frequency at which they will be conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to 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 Page 7 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 needed. 10 RAI Question: Complete. (RAI-9, Ref. 4 / Please provide the following: a) The specific location for each (Addressed in Reference 8) RAI-10 of the primary and backup Ref. 8) instrument channel displays. b) If the primary and backup display location is other than the main control 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" to various drain-down scenarios and external events. 11 RAI Question: Complete. (RAI-10, Ref. 4 / Please provide a description of the standards, guidelines and/or (Addressed in Reference 8) RAI-11 criteria that will be utilized to Ref. 8) develop procedures for inspection, maintenance, repair, operation, abnormal response, and administrative controls associated with the SFP level instrumentation, as well as storage and installation of portable instruments. Page 8 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 12 (RAI-11, Ref. 4 / RAI-12 Ref. 8) RAI Question: Completed. a: Addressed in Reference 8 b, c: and backup SFPI channels installation (with no post-event installation) of and robust augmented quality installation coupled of adequate spare parts the likelihood that a (and greatly diminishes the both channels) is (are) out-of-extended period of time. actions for unlikely -of-service events will be CC-LA-118-1001 Diverse and Strategies (Flex) and Spent Program and are summarized as Please provide the following: a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. 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. b) 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. c) 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. Response for Response for Both primary incorporate permanent reliance on portable, relatively simple equipment. Permanent with stocking reasonably diminishes single channel likelihood that service for an Planned compensatory extended outcontrolled by Flexible Coping Fuel Pool Instrumentation Implementation follows: # Channel(s) Out-of- Service Required Restoration Action Compensatory Action if Required Restoration Action not completed within Specified Time 1 Restore Channel to functional status within 90 days (or if channel Immediately initiate action in accordance with note below Page 9 of 14 restoration not expected within 90 days, then proceed to Cornpensatory Action Initiate action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one channel to functional status and restore one channel to functional status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Immediately initiate action in accordance with note below 2 Note: Initiate IA documenting the actions initiated to restore the channel(s) Out-of-Service to a functional status and the compensatory action implemented that meets the time required of 90 days for one channel Out-of Service or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for two channels Out-of-Service. LaSalle Station revised the compensatory action plan requirements applicable to conditions where the instrument channel(s) are not restored to functional status within the specified time, as specified in the Note. The condition will be entered into the corrective action program in lieu of a report to PORC. LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Draft Safety Evaluation Open Items 01# Description Status 1 (RAI-1, RAI Question: Complete. Please provide additional (Addressed in Reference 8) Page 10 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Ref. 5 / RAI-1 . ) Ref 8instrumentation information describing how the final arrangement of the SFP and routing of the cabling between the level instruments, the electronics and the displays, meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP. 2 (RAI-3, Ref. 5 / RAI-2 Ref 8) . RAI Question: Complete. 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. (Addressed in Reference 8) 3 (RAI-4, Ref. 5 / RAI-3 Ref. 8) RAI Question: Complete 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. (Addressed in Reference 8) 4 (RAI-6, Ref. 5 / RAI-4 Ref. 8) RAI Question: Complete 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. Westinghouse document EQ-QR-269 was revised to include aging tests that age the system components to 10 years. LaSalle Station has reviewed EQ-QR-269 Revision 2 and found it to be acceptable. Page 11 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 RAI Question: Please provide the following: a) The specific location for each of the primary and backup instrument channel displays. b) Please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BDB event. Include an estimate of the time available for personnel to access the display as well as the actual time 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 BDB event. Describe whether personnel would continuously monitor the display or access the display location on demand. c) If a display will be located somewhere 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 BDB 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 5 (RAI- 1 1 , Ref. 5 / RAI-5 Ref. 8) Complete (Addressed in Ref. 8) Page 12 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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 BDB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically. 6 RAI Question: Complete (RAI- Please provide a list of the (Addressed in Reference 8) procedures addressing operation 12,5 Ref. (both normal and abnormal response), calibration, test, / RAI-6 maintenance, and inspection Ref. 8) 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. 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, "Overall Integrated Plan 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 February 28, 2013 (RS-13-031). 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 7,2013. Page 13 of 14 LaSalle County Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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 3, 2013 (RS-13-158). 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 November 26, 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-13-120). 7. Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated February 28, 2014 (RS-14-021). 8. Third 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, 2014 (RS-14-199). Page 14 of 14