ML13059A265: Difference between revisions

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{{Adams
#REDIRECT [[RS-13-027, 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)]]
| number = ML13059A265
| issue date = 02/28/2013
| title = 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)
| author name = Kaegi G T
| author affiliation = Exelon Generation Co, LLC
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000456, 05000457
| license number = NPF-072, NPF-077
| contact person =
| case reference number = EA-12-051, RS-13-027
| document type = Letter
| page count = 12
| project =
| stage = Other
}}
 
=Text=
{{#Wiki_filter:U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2013 Page 2 Reference 4 provided the EGC initial status report regarding reliable spent fuel pool instrumentation, as required by Reference 1.
Reference 3, Appendix A-2 contains the specific reporting requirements for the Overall Integrated Plan. The information in the enclosure provides the Braidwood Station, Units 1 and 2 Overall Integrated Plan pursuant to Appendix A-2 of Reference 3. The enclosed Integrated Plan is based on conceptual design information. Final design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.
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 281' day of February 2013.Braidwood Station, Units 1 and 2 Reliable Spent Fuel Pool Instrumentation (SFPI) Overall Integrated Plan NRC Senior Resident Inspector - Braidwood Station, Units 1 and 2 NRC Project Manager, NRR - Braidwood Station, Units 1 and 2 Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safetyth 
 
Overall Integrated Plan (9 pages)
 
Applicability:
This integrated plan applies to Braidwood Station, Units 1 and 2 and is based on current conceptual design information and will be revised as detailed design engineering proceeds.Consistent with the requirements of Order EA-12-051 (Ref.1) and the guidance in NEI 12-02 (Ref.3), Exelon's six-month reports will delineate progress made, any proposed changes in compliance methods, updates to the schedule and, if needed, requests for relief and the basis.
General
 
== Description:==
 
Braidwood Station is a two unit Pressurized Water Reactor Station. The two units share a single Spent Fuel Pool (SFP) located in the Fuel Handling Building (FHB). Normal SFP water level is approximately El. 424'-6". Top of the spent fuel rack is El. 400'-13W and top of active fuel is approximately El. 400'-0".
Schedule: The installation of reliable level instrumentation for the SFP associated with Unit 1 and Unit 2 is scheduled for completion by the end of Al R18 (Spring 2015) based on the end of the second refueling outage for Unit 1 following submittal of this integrated plan. This is the earlier outage sequence of the units discharging to the pool.Submit Integrated PlanComplete with this submittalOrder SFP Instrumentation2Q2013Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan Appl icabi I ity:
General
 
== Description:==
400'-1 3 fit +/-
Schedule: 
 
Identification of Spent Fuel Pool Water Levels:
Key spent fuel pool water levels will be identified as follows:
Level adequate to support operation of the normal fuel pool cooling system (Level 2): Indicated level on either the primary or backup instrument channel of greater than 10 feet (elevation 410'-1314")
 
plus instrument channel accuracy(which will determined in the detailed design phase) above the top of the storage racks based on specification of this level as adequate in NRC JLD-ISG-2012-03 (Ref. 2) and NEI 12-02 (Ref. 3), the specified design accuracy of the instrument channel, and the relatively low sensitivity of dose rates to changes in water depth at this level. This monitoring level ensures there is an adequate water level to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck from direct gamma radiation from stored spent fuel.
Indicated level on either the primary or backup instrument channel of greater than 0 feet (elevation 400'-13/4") plus instrument channel accuracy above the top of the storage racks based upon the design accuracy (which will determined in the detailed design phase) of the instrument channel for both the primary and backup instrument channels. This monitoring level assures that water is covering the stored fuel seated in the rack.
Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Plan 402013 102015 202015
-1 3 A")
-1 3 A")
2 
 
Overall Integrated Plan Instruments:
The design of the instruments will be consistent with the guidelines of NRC JLD-ISG-2012-03 (Ref. 2) and NEI 12-02 (Ref. 3). Specifically, the channels will be designed as discussed below:
The primary instrument channel level sensing components will be located and permanently mounted in the Spent Fuel Pool. The primary instrument channel will provide continuous level indication over a minimum range of approximately 24 feet 8 inches from the high pool level elevation of 424'-91/8" to the top of the spent fuel racks at elevation 400'-1 3/4". This 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 design phase of the project.
The backup instrument channel level sensing components will also be located and permanently mounted in the Spent Fuel Pool.
The backup instrument channel will provide continuous level indication over a minimum range of approximately 24 feet 8 inches from the high pool level elevation of 424'- 9 '/" to the top of the spent fuel racks at elevation 400'- 1 3/a".
This continuous level indication will be provided by the same level sensing technology as the primary instrument channel.
of NRC JLD-ISG-2012-Both primary Instrument Channel Design:
Instruments:
Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Plan Primary (fixed) instrument channel:
Y2" 3A".
Backup instrument channel: 1;2" 3A".
Reliability:
Design Features Instrument Channel Design: 
 
The current plan is to install SFP level sensors in the southwest and northwest corners of the SFP separated by a distance in excess of 20 feet. The sensors themselves will be mounted, to the extent practical, near the pool walls and below the pool curb to minimize their exposure to damaging debris and not interfere with SFP activities. Instrument channel electronics and power supplies will be located in seismic and missile protected areas either at an elevation below the SFPoperating floor or in buildings other than the FHB. The areas to be selected will provide suitable radiation shielding and environmental conditions for the equipment consistent with instrument manufacturer's recommendations. Equipment and cabling for power supplies and indication for each channel will be separated equivalent to that provided for redundant safety related services.
Design of the mounting of the sensors in the SFP shall be consistent with the seismic Class I criteria. Installed equipment will be verified to be seismically adequate for the seismic motions associated with the maximum seismic ground motion considered in the design of the plant area in which it is installed.
Reliability of both instrument channels will be demonstrated via an appropriate combination of design, analyses, operating experience, and/or testing of channel components for the following sets of parameters:effects of shock and vibration on instrument channel components used during and following any applicable event, and seismic effects on instrument channel components used during and following a potential seismic event.
Temperature, humidity and radiation levels consistent with the conditions in the vicinity of the SFP and the area of use considering normal operation, event and postevent conditions for no fewer than seven days post-event or until off-site resources can be deployed by the mitigating strategies resulting from Order EA-12-049 (Ref.4), will be addressed in the detailed design engineering phase of the project. Examples of post-event (beyond-design-basis) conditions to be considered are:Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan Arrangement:
Mounting:
Qualification:
a concentrated borated water environment, andthe impact of FLEX mitigating strategies.
Components of the instrument channels will be qualified for shock and vibration using one or more of the following methods:components are supplied by manufacturers using commercial quality programs (such as 1509001, "Quality management systems-Requirements")
with shock and vibration requirements included in the purchase specification at levels commensurate with portable hand-held devices or transportation applications;components have substantial history of operational reliability in environments with significant shock and vibration loadings, such as portable hand-held devices or transportation applications; orcomponents are inherently resistant to shock and vibration loadings, such as
 
cables.For seismic effects on instrument channel components used after a potential seismic event for only installed components (with the exception of battery chargers and replaceable batteries), the following measures will be used to verify that the design and installation is adequate. Applicable components are rated by the manufacturer (or otherwise tested) for seismic effects at levels commensurate with those ofpostulated design basis event conditions in the area of instrument channel component use using one or more of the following methods:instrument channel components use known operating principles and are supplied by manufacturers with commercial quality programs (such as IS09001), The procurement specification and/or instrument channel designshall include the seismic requirements and specify the need for commercial
 
design and testing under seismic loadings consistent with design basis values at the installed locations;Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan 5 
 
substantial history of operational reliability in environments with significant vibration, such as for portable hand-held devices or transportation applications.
Such a vibration design envelope shall be inclusive of the effects of seismic motion imparted to the components proposed at the location of the proposed installation; adequacy of seismic design and installation is demonstrated based on the guidance in Sections 7, 8, 9, and 10 of IEEE Standard 344-2004, "IEEE Recommended Practice for Seismic Qualification of Class 1 E Equipment forNuclear Power Generating Stations", or a substantially similar industrial standard;demonstration that proposed devices are substantially similar in design to models that have been previously tested for seismic effects in excess of the plant design basis at the location where the instrument is to be installed (g-levels and frequency ranges); orseismic qualification using seismic motion consistent with that of existing design basis loading at the installation location.
The primary instrument channel will be independent of the backup instrument channel.
This independence will be achieved through physical and electrical separation of each channels' components commensurate with hazard and
 
electrical isolation needs.
Each channel will be normally powered from a different 120Vacbus.Upon loss of normal ac power, individual channel installed batteries will automatically maintain continuous channel operation. The batteries will be replaceable and be sized to maintain channel operation until off-site resources can
 
be deployed by the mitigating strategies resulting from Order EA-12-049(Ref.4).
Additionally, each channel will have provisions for connection to another suitable power source.
The instrument channels will be designed to maintain their design accuracy following a power interruption or change in power source without recalibration. Instrument channel accuracy, to be determined during detailed design, will consider Spent Fuel Pool conditions (e.g., saturated water, steam environment, concentrated borated water),other applicable radiological and environmental conditions and include display accuracy. Instrument channelBraidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan Independence:
Power Supplies:
Accuracy: 
 
Overall Integrated Plan level exceeds the specified lower level of each indicating range (levels 1, 2 or 3) without conflicting or ambiguous indications.
Testing:
The primary and backup instrument displays will be located at the control room, alternate shutdown panel, or other appropriate and accessible location. The specific location will be determined during detailed design.
An appropriate and accessible location will include the following characteristics:
occupied or promptly accessible to the appropriate plant staff giving appropriate consideration to various drain down scenarios, outside the area surrounding the SFP floor (e.g., an appropriate distance from the radiological sources resulting from an event impacting the Spent Fuel Pool),inside a structure providing protection against adverse weather, andoutside of very high radiation areas or LOCKED HIGH RAD AREA.
Personnel performing functions associated with these Spent Fuel Pool level instrumentation channels will be trained to perform the job specific functions necessary for their assigned tasks calibration, surveillance, etc.). This training will be consistent with equipment vendor guidelines, instructions and recommendations.
The Systematic Approach to Training (SAT) will be used to identify the population to be trained and to determine the initial and continuing elements of the required training.
Training will be completed prior to placing the instrumentation in service.
Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation and abnormal response issues associated
 
with the primary and backup channels of Spent Fuel Pool instrumentation.
Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan Testing:
Display:
Program Features Training:
Procedures: 
 
service, an instrument channel ceases to function, its function will be recovered within a period of time consistent with the emergency conditions that may exist at the time.If, at the time of an event or thereafter until the unit is returned to normal service, an instrument channel component must be replaced, it may be replaced with a commercially available component that may or may not meetall of the qualifications noted above to maintain instrument channel functionality.
The testing and calibration of the instrumentation will beconsistent with vendor recommendations or other documented basis. Calibration will be specific to the mounted instruments and the displays.
Calibration will be performed to an Instrument Maintenance Procedure (BIP/BISR series). A Passport PMID will be used to direct frequency for performance of the instrument calibration.
Both primary and backup instrumentation channels will be functional at all times when there is fuel in the SFP with allowance for testing, maintenance or repair per NEI 12-02(Ref.3),.
Exelon is not requesting relief from the requirements of Order EA-12-051 or the guidance in NRC IJD-ISG-2012-03 at this time.Consistent with the requirements of Order EA-12-051(Ref.1), and the guidance in NEI 12-02(Ref.3), Exelon's six-month reports will delineate progress made, any proposed changes in compliance methods, updates to the schedule, and if needed, requests for relief and their basis.
 
==References:==
 
1.NRC Order Number EA-12-051, Order Modifying 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 24, 2012Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Plan Testing and Calibration:
Need for Relief and Basis:
 
==References:==
 
8 
 
Overall 4.NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigating Strategies for Beyond-Design-Basis External Events, dated March 12, 2012Braidwood Station, Unit 1 and 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Plan}}

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