RS-14-203, 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)

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)

ML14248A217
Person / Time
Site:	Quad Cities
Issue date:	08/28/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-203
Download: ML14248A217 (28)

Text

sm-P-Exelon Generation Order No. EA-12-051 RS-14-203 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

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)

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-13-035)

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-13-128)

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 025)

8. NRC letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power 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. MF1052 and MF1053), dated October 9, 2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2014 Page 2 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 EGC initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Quad Cities Nuclear Power 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 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Quad Cities Nuclear Power Station. The purpose of this letter is to provide the third 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 8.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of August 2014.

Respectfully submitted,

// /

Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Quad Cities Nuclear Power Station, Units 1 and 2 Third 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 August 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region III NRC Senior Resident Inspector Quad Cities Nuclear Power Station, Units 1 and 2 NRC Project Manager, NRR Quad Cities Nuclear Power 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. Blake Purnell, NRR/DORL/LPL3-2, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (24 pages)

Quad Cities Nuclear Power Station, Units 1 and 2 Third 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 Quad Cities Nuclear Power 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 Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the Second 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 Second six month status report (Reference 8), and are current as of the issuance of this report.

Complete and Issue SFPI Modification Package for Quad Cities Nuclear Power Station Begin SFPLI Installation, July 2014 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 3, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete with this submittal Page 1 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Milestone Target Completion Date Activity Status Revised Target Completion Date Update 4 February 28, 2015 Not Started Provide Final Safety Evaluation (SE) Info September 30, 2014 Complete Modifications:

Conceptual Design 3Q2012 Complete Issue Exelon Fleet contract to procure SFPI Equipment 202013 Complete Begin (Site Specific) Detailed Engineering Design 402013 Complete Complete and Issue SFPI Modification Package 202014 Complete Begin Installation 402014 Complete Complete SFPI Installation and Put Into Service 102015 Not 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 Quad Cities Nuclear Power 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(Ref. 1) or the Draft Safety Evaluation (SE)(Ref. 5) and the status of each item. All incomplete RAI questions from the Draft Safety Evaluation are included as Open Items in the Tables below.

Page 2 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Overall Integrated Plan Open Items(01) 01#

Description Status 1

(Ref.1)

Open Item:

Complete.

(Addressed in Reference 7)

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-2, Ref.4)

RAI Question:

Complete.

See enclosed RAI-2 Sketch.

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 sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.

3 (RAI-3, Ref.4)

RAI Question:

Complete a) All SFPLI system equipment will be designed in accordance with the Quad Cities Station Safe Shutdown Earthquake (SSE) design requirements.

The vendor, Westinghouse, has evaluated the structural integrity of the mounting brackets in calculation ON-PEUS-14-5. The GTSTRUDL model, used by Westinghouse to calculate the stresses in the bracket assembly, considers load combinations for the dead load, live load and seismic load on the bracket. The reactionary forces calculated from these loads become the design inputs to design the mounting bracket anchorage to Please provide the following:

a) The design criteria that will be used to estimate the total 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 Page 3 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 the refuel floor to withstand a Safe Shutdown Earthquake (SSE).

Seismic The seismic loads are obtained from Quad Cities Station's response spectra curves (Reference Updated FSAR Chapter 3.7 Figures for Quad Cities Nuclear Generating Station). The following methodology was used in determining the stresses on the bracket assembly:

• Frequency analysis, taking into account the dead weight and the hydrodynamic mass of the structure, is performed to obtain the natural frequencies of the structure in all three directions.

• SSE (Safe Shutdown Earthquake) response spectra analysis is performed to obtain member stresses and support reactions.

• Modal responses are combined using the Ten Percent Method per U.S. NRC Regulatory Guide 1.92, Revision 1, "Combining Modal Responses and Spatial Components in Seismic Response Analysis.

The seismic loads for each of the three directions are combined by the Square Root of the Sum of Squares (SRSS) Method.

• Sloshing analysis is performed to obtain liquid pressure and its impact on bracket design.(see below for more details)

• The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum. These combined results are compared with the allowable stress values.

Sloshing Sloshing forces were obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach has been used to estimate the wave height and natural frequency. Horizontal and vertical impact force on the bracket components was calculated using the wave height and natural frequency obtained using TID-7024 approach.

Using this methodology, sloshing forces have been calculated and added to the total reactionary forces that would be applicable for bracket anchorage 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.

Page 4 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 design. The analysis also determined that the level probe can withstand a credible design basis seismic event. During the design basis event, the SFP water level is expected to rise and parts of the level sensor probe are assumed to become submerged in borated water. The load impact due to the rising water and submergence of the bracket components has also been considered for the overall sloshing impact. Reliable operation of the level measurement sensor with a submerged interconnecting cable has been demonstrated by analysis of previous Westinghouse testing of the cable, and the vendor's cable qualification. Boron build up on the probe has been analyzed to determine the potential effects on the sensor; this is however not applicable to Quad Cities pool.

The following Westinghouse documents provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a. CN-PEUS-14-5 Pool-side Bracket Seismic Analysis

b. LTR-SEE-II-13-47, WNA-TR-03149-GEN Sloshing Analysis

c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification of other components of SFPI Quad Cities Station specific calculations QDC-1900-S-2108 Evaluation of SFPI Sensor Mounting Detail Anchorage and QDC-1900-S-2109 were performed. The design criteria used in this calculation meets the requirements to withstand a SSE and will meet the Quad Cities Station safety related installation requirements. The methods used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, will be suspended from the launch plate via coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors. Enlosed Sketch RAI 3 shows a schematic of the level sensor with mechanical attachment points.

Page 5 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 c) The bracket assembly that supports the sensor probe and launch plate will be mechanically connected to the SFP structure. The mechanical connection consists of four concrete expansion anchors that will bolt the bracket assembly to the SFP structure via the base plate. The concrete expansion anchors will be designed to withstand SSE and will meet the Quad Cities Station safety related installation requirements. The qualification details of the bracket are provided in Westinghouse's Pool-side bracket Seismic Analysis CN-PEUS-14-5 and the qualification of the anchorage to the floor is provided in Quad Cities Station specific calculation QDC-1900-S-2108 Evaluation of SFPI Sensor Mounting Detail Anchorage.

4 RAI Question:

Complete (RAI-4, Please provide the a) Beyond Design Basis Environment Ref.4) following:

a) A description of the Westinghouse qualified the components (probe, connector, cable) of the SFPLI located in the SFP specific method or area to the beyond design basis environment.

combination of methods Components of the system were subjected to you intend to apply to beyond design basis conditions of heat and demonstrate the reliability humidity, thermal and radiation aging mechanisms.

of the permanently This testing confirmed functionality of these system installed equipment under components under these beyond design basis beyond-design-basis environmental conditions. Westinghouse performed ambient temperature, humidity, shock, vibration, and radiation conditions.

testing to ensure aging of the components in the SFP area will not have a significant effect on the ability of the equipment to perform following a plant design basis earthquake. Exelon has reviewed the b) A description of the documents and found acceptable. Reference testing and/or analyses Westinghouse documents EQ-TP-351, WNA-TR-that will be conducted to 03149-GEN, and EQ-TP-354 for description of provide assurance that the equipment will perform specific qualification methods.

reliably under the worst-case credible design basis loading at the location Mild Environment Westinghouse qualified the system components (display panel, sensor) that reside in the mild environment conditions to where the equipment will determine that the components can satisfactorily be mounted. Include a perform to those conditions. Westinghouse has discussion of this seismic determined that aging does not have a significant reliability demonstration effect on the ability of the equipment to perform as it applies to a) the level following a plant design basis earthquake. Exelon sensor mounted in the has reviewed the documents and found acceptable.

Page 6 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Reference Westinghouse documents EQ-QR-269, WNA-TR-03149-GEN for description of specific methods.

Shock and Vibration SFPIS pool side brackets were analyzed for Safe Shutdown Earthquake design requirements per NRC order EA-12-051 and NEI 12-02 guidance. As provided by the NRC Order EA-12-051, the NEI 12-02 guidance and as clarified by the NRC interim staff guidance, the probe, coaxial cable, and the mounting brackets are "inherently resistant to shock and vibration loadings." As a result, no additional shock and vibration testing is required for these components.

SFPIS pool side brackets for both the primary and backup Westinghouse SFP measurement channels will be permanently installed and fixed to rigid refuel floors, which are Seismic Category 1 structures.

The SFPI system components, such as level sensor and its bracket, display enclosure and its bracket, were subjected to seismic testing, including shock and vibration test requirements. The results for shock and vibration tests were consistent with the anticipated shock and vibration expected to be seen by mounted equipment. The level sensor electronics and the display electronics will be mounted to a seismically qualified wall.

Reference Westinghouse reports WNA-DS-02957, WNA-TR-03149-G EN for shock and vibration.

b)The seismic adequacy of the SFPLI (all components) is demonstrated by vendor testing and analysis in accordance with below listed standards:

• IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class lE Electrical Equipment for Nuclear Power Generating Stations

• IEEE-323-1974, Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations

• USNRC Regulatory Guide 1.100, Rev. 3

• USNRC Regulatory Guide 1.92, Rev. 1

• Calculation QDC-1900-S-2109, Seismic Qualification of Instrument Enclosure and Level Transmitter Boxes Seismic adequacy of the level sensor probe 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.

Page 7 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 supporting bracket within the SFP area was demonstrated by analysis as discussed in response to RAI-3.

c) Westinghouse has seismically qualified the SFPI instrument and its components. CN-PEUS-14-5 describes Pool-side Bracket Seismic Analysis, EQ-QR-269, WNA-TR-03149-G EN, EQ-TP-353 describe remaining seismic qualifications of the instrument components. With the instrument being seismically qualified and installed as described in RAI 4b response, the instrument is assured to maintain reliable and accurate indication when required. Westinghouse report WNA-CN-00301 -

GEN and Quad Cities Engineering Change 393703 provide the channel accuracy from measurement to display.

5 RAI Question:

Complete (RAI-5, Please provide the a) The level probes will be mounted on the east Ref.4) following:

side of the SFP and will be separated by a distance a) A description of how the greater than the span of the shortest side of the two channels of the pool. This meets the NEI 12-02 revision 1 guidance proposed level measurement system meet for channel separation. The two installed systems will function as completely independent channels to this requirement so that ensure that a single power source failure will not the potential for a common disable both primary and backup indications.

cause event to adversely b) To ensure adequate channel separation, the level affect both channels is sensor for the primary channel will be mounted in minimized to the extent the northeast corner of the Unit 1 SFP on an practicable.

existing abandoned jib crane plate. The level sensor b) Further information on for the backup channel will be mounted in the how each level measurement system, southeast corner of the Unit 2 SFP on an existing abandoned jib crane plate. The level transmitter and consisting of level sensor level indicating display for the primary and backup electronics, cabling, and channels will be installed in Unit 1 and Unit 2 readout devices will be Turbine Buildings, respectively. The 120 VAC power designed and installed to for the primary and backup level indicating displays address independence will be provided from Unit 1 and Unit 2 instrument through the application buses. The power and instrument cables will be and selection of routed on the Unit 1 side for primary channel and on independent power sources, the use of the Unit 2 side for the backup channel. The display locations are greater than 50 ft apart and the physical and spatial raceway systems are separated completely routing separation, independence in opposite directions. Therefore, adequate of. signals sent to the separation is maintained between the primary and Page 8 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 location(s) of the readout devices, and the independence of the displays.

backup channels.

6 RAI Question:

Complete (RAI-6, Please provide the a) The 120 VAC power for the primary and backup Ref.4) following:

a) A description of the electrical ac power sources and capabilities level indicating displays will be provided from Unit 1 and Unit 2 instrument buses. These buses are reliable sources of power fed from Diesel Generator backed MCC 18-2/28-2 busses respectively. Upon loss of normal AC power, individual batteries for the primary and backup channels.

installed in each channel's electronics/ UPS enclosure will automatically maintain continuous b) Please provide the channel operation for at least three (3) days. These results of the calculation ESF MCCs have also been identified as part of the depicting the battery FLEX strategy to ensure that the SFPLI will have ac backup duty cycle power restored if a Beyond Design Basis External requirements Event would occur. Additionally, a receptacle and a demonstrating that its selector switch are installed in each channel capacity is sufficient to electronics/ UPS enclosure to directly connect maintain the level indication function until emergency power to the SFPLI.

offsite resource availability b) The Westinghouse Report, WNA-CN-00300-is reasonably assured.

GEN, provides the results of the calculation depicting the battery backup duty cycle. This calculation demonstrates that battery capacity is 4.22 days to maintain the level indicating function to the display. Therefore, the Quad Cities Station readout display of level indication will be available for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation. The results of the calculation meet the NEI 12-02 requirements.

7 RAI Question:

Complete (RAI-7, Please provide the a) The Westinghouse documents WNA-CN-Ref.4) following:

a) An estimate of the expected instrument 00301and WNA-DS-02957-G EN describe the channel accuracy under both (a) normal SFP level conditions and (b) at the Beyond Design Basis channel accuracy performance under both (a) normal SFP level (BDB) conditions that would be present if SFP level were at Level 2 and Level 3 datum points. Each instrument channel will be accurate to within conditions (approximately

+/-3"during normal spent fuel pool level conditions.

Level 1 or higher) and (b) at the 16 beyond design-The instrument channels will retain this accuracy after BDB conditions, in accordance with the above basis conditions (i.e.,

Westinghouse documents.

Page 9 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 radiation, temperature, humidity, postseismic and b) The Westinghouse document WNA-TP-04709-GEN describes the methodology for routine post-shock conditions) testing/calibration verification and calibration that would be present if methodology. This document also specifies the the SFP level were at the required accuracy criteria under normal operating Level 2 and Level 3 datum conditions. Quad Cities Station calibration and

points, b) A description of the channel verification procedures will follow the guidance and criteria provided in this document.

methodology that will be Instrument channel calibration will be performed if used for determining the the level indication reflects a value that is outside maximum allowed the acceptance band established in the Quad Cities deviation from the Station calibration and channel verification instrument channel design accuracy that will be procedures.

Calibration will be performed once per refueling employed under normal cycle for Quad Cities Station. Per Westinghouse operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to document WNA-TP-04709-GEN calibration on a SFP level channel is to be completed within 60 days of a planned refueling outage considering normal testing scheduling allowances (e.g. 25%). An technicians that the channel requires adjustment to within the equivalent time period and periodicity may be used not tied to the refueling outage. This is in compliance with the NEI 12-02 guidance for Spent normal condition design accuracy.

Fuel Pool Instrumentation.

8 RAI Question:

Started (RAI-8, Please provide the a) Westinghouse calibration procedure WNA-TP-Ref.4) following:

04709-GEN and functional test procedure WNA-TP-a) A description of the capability and provisions the proposed level sensing 04613-G EN describe the capabilities and provisions of SFPI periodic testing and calibration, including in-situ testing.

equipment will have to b) The level displayed by the channels will be enable periodic testing verified per the Quad Cities Station administrative and calibration, including and operating procedures, as recommended by how this capability Westinghouse vendor technical manual WNA-GO-enables the equipment to 00127-GEN.

If the level is not within the required be tested in-situ, b) A description of how such testing and accuracy per Westinghouse recommended tolerance in WNA-TP-04709-GEN, channel calibration will be performed.

calibration will enable the c) Functional checks will be performed per conduct of regular channel Westinghouse functionality test procedure WNA-TP-checks of each 04613-GEN at the Westinghouse recommended independent channel frequency. Calibration tests will be performed per Page 10 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 against the other, and Westinghouse calibration procedure WNA-TP-against any other 04709-GEN at the Westinghouse recommended permanently-installed SFP frequency. In accordance with Quad Cities Station level instrumentation, c) A description of how functional checks will be modification process, maintenance and operating surveillances will be developed for calibration, functional test, channel verification procedures per performed, and the frequency at which they Westinghouse recommendations to ensure reliable, accurate and continuous SFPI functionality by will be conducted.

March 1, 2015.

Describe how calibration d) Quad Cities Station will develop preventive tests will be performed, and the frequency at which maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual they will be conducted.

WNA-G0-00127-GEN to assure that the channels Provide a discussion as to are fully conditioned to accurately and reliably 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.

perform their functions when needed by March 1, 2015.

9 RAI Question:

Replaced by Interim SE RAI #12 (Ref. 5).

(RAI-9, Ref.4)

Please provide the following:

a) The specific location for each of the primary and backup 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 Page 11 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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.

10 RAI Question:

Replaced by Interim SE RAI #13 (Ref. 5).

(RAI-10, Ref.4)

Please provide a description of the standards, guidelines and/or criteria that will be utilized to 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.

11 RAP Question:

Complete (RAI-11, Please provide the Response for a):

Ref.4) following:

Performance tests (functional checks) and Operator a) Further information performance checks will be described in detail in the describing the vendor operator's manual, and the applicable maintenance and testing information is planned to be contained in plant program the licensee will establish and implement to operating procedures.

Operator performance tests are planned to be Page 12 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 performed periodically as recommended by the equipment vendor.

Channel functional tests per operations procedures with limits established in consideration of vendor equipment specifications are planned to be performed at appropriate frequencies established equivalent to or more frequently than existing SFPI.

Manual calibration and operator performance checks are planned to be performed in a periodic scheduled fashion with additional maintenance on an as-needed basis when flagged by the system's automated diagnostic testing features.

Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment specifications are planned to be performed at frequencies established in consideration of vendor recommendations.

SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness are planned to be established in accordance with Exelon's processes and procedures and in consideration of vendor recommendations to ensure that appropriate regular testing, channel checks, functional tests, periodic calibration, and maintenance is performed (and available for inspection and audit). Subject maintenance and testing program requirements are planned to be developed during the SFPI modification design process.

Response for b, c:

Both primary and backup SFPI channels incorporate permanent installation (with no reliance on portable, post-event installation) of relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (and greatly diminishes the likelihood that both channels) is (are) out-of-service for an extended period of time. Planned compensatory actions for unlikely extended out-of-service events are summarized as follows:

ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

Please 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 NEI 12-02 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.

Page 13 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014

1. 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 restoration not expected within 90 days, then proceed to Compensatory Action)

Immediately initiate action in accordance with Note below 2

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 Note: Present a report to the on-sle Plant Operations Review Committee (PORC) within the following 14 days. The report shall outline the planned alternate method of monitoring, the cause of the non-functionality, and the plans and schedule or restoring the instrumentation channel(s) to functional status.

12 (RAI-1, Ref. 4)

RAI Question:

Complete (Addressed in Reference 4)

Please provide the following:

a) For level Li, specify how the identified location represents the higher of Page 14 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 L1, L2, and L3 as well as the top of the fuel. Indicate on this sketch the portion of the level sensormeasurement range that is sensitive to measurement of the fuel pool level, with respect to the L1, L2, and L3 datum points.

Draft Safety Evaluation Open Items (Ref. 5 & 6) 01#

Description Status 1

RAI Question:

Complete (RAI-1, Ref. 5, Please provide the following:

(Adressed in Reference 8)

6) a) Describe the impact of the installation of the gates between the SFPs and transfer canal on the reliability of the SFP level instrumentation for each SFP. Describe the compensatory measures that would be taken to ensure reliable indication in each SFP when the gates are installed.

b) Describe the Page 15 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 elevation for the bottom of the gate opening or highest elevation of the bottom of the transfer canal to demonstrate that both the primary and backup SFP level instrument channels can measure the same Level 3 elevation in both SFPs.

2 (RAI-4, Ref. 5)

RAI Question:

Started The following Westinghouse documents provide the analyses used to verify the design criteria and describe the methodology for seismic testing of the SFP instrumentation and electronics units, inclusive of design basis maximum seismic loads and hydrodynamic loads that could result from pool sloshing and other effects that could accompany such seismic forces:

a. CN-PEUS-14-5 Pool-side Bracket Seismic Analysis

b. LTR-SEE-I1-13-47, WNA-TR-03149-G EN Sloshing Analysis

c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 Seismic Qualification of other components of SFPI No equipment failures were noted as a result of seismic test runs. Seismic test data has been documented in the seismic test reports, referenced above.

Quad Cities Station specific calculation QDC-1900-S-2109 Seismic Qualification of SFPI Transmitter and Display boxes will address the seismic qualification of the display panel indicators. This analysis will be finalized by December 2014.

For RAI3(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 the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

3 (RAI-5, Ref.5)

RAI Question:

Started Quad Cities Station specific calculations QDC-1900-S-2108 Evaluation of SFPI Sensor Mounting Detail Anchorage and QDC-1900-S-2109 were performed. The design criteria used in this calculation meets the requirements to withstand a SSE and will meet the Quad Cities Station safety related installation requirements. The methods used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument. This analysis will be finalized by December 2014.

For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs and methodology used to qualify the structural integrity of the affected structures and equipment.

4 (RAI-7, RAI Question:

Started Below is a summary of the test conditions used by For RAI #6 above, Page 16 of 24

Temperature 212°F 50-140°F Pressure Atmospheric Atmospheric 100% (saturated steam)

Humidity 0-95% RH 1E07 Rads 1E03 Rads Radiation TID y (above pool)

Normal Parameter for Exelon Plants BDB Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Westinghouse to qualify the SFPIS. Environmental Conditions for SFPIS Components installed in the Spent Fuel Pool Area at Quad Cities Station are bounded by below test conditions, except for radiation Total Integrated Dose (TID) 12" above top of fuel rack for beyond design basis conditions (BDB). The BDB radiation TID, 12" above top of fuel rack for Quad Cities is 4.E07 R y, per calculation BYR13-051 NEI 12-02 Spent Fuel Pool Doses. The BDB radiation value to which the Westinghouse equipment is qualified to is 1.E07 R y, per Section 5.1.1 of WNA-TR-03149-GEN. The radiation value of 4.E07 R y is higher than 1.E07 R y to which Westinghouse qualified the instrument. However, this value of 4.E07 R y is applicable only when the water is at Level 3. At Level 2 the TID reduces to 2.E07 R y and it further reduces to 8.E06 at Level 1 and above. With SFP water level at Level 3 the only components of SFPI that are exposed to high radiation are the stainless steel probe and the stainless steel anchor.

The materials with which the probe and the anchor are manufactured are resistant to radiation effects. The stainless steel anchor and stainless steel probe can withstand 40 year dose. Westinghouse updated the design specification (WNA-DS-02957-GEN) and LTR-SFPIS 35, Revision 1 documentation to include the above technical justification.

Environmental Conditions for SFPIS Components in the Spent Fuel Pool Area Level sensor probe, coax coupler and connector assembly, launch plate and pool side bracket assembly, coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Ref. 5) please provide the results for the selected methods, tests and analyses utilized to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

Page 17 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Radiation TID y (12" above top of fuel rack) 1E09 Rads (probe and weight only) 1E07 Rads Environmental Conditions Outside of the Spent Fuel Pool Area The level sensor transmitter and bracket, electronics display enclosure and bracket are designed and qualified to operate reliably in the below specified environmental conditions.

Parameter Normal BDB BDB (Level Sensor Electronics Only)

Temperature 50-120°F 140°F 140°F Pressure Atmos-pheric Atmos-pheric Atmospheric Humidity 0-95% RH 0-95%

(non-condensing) 0-95%

(non-condensing)

Duration 3 days 3 days 3 days Radiation TID V

5 1E03 R V

5 1E03 R y 5 1E03 R y Thermal and Radiation Aging organic components in SFP area Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-03149-GEN provide thermal and radiation aging program details for the SFPI components. Westinghouse completed their thermal and radiation aging testing programs to qualify the SFPI components to 1.25 years.

Exelon has reviewed the documents and found acceptable.

Additionally, Westinghouse is continuing their aging tests to age the system components to 10 years. These tests are Page 1 8 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 projected to be completed towards the end of Summer 2014. Final test reports are scheduled to be provided to Exelon by September 4, 2014. Exelon will complete the test report reviews by September 30, 2014.

5 RAI Question:

Complete (RAI-Please provide the a) Quad Cities' primary and backup instrument channel 12, following:

displays are located in the Main Turbine Building on the Ref. 5) a) The specific location Main Turbine floor along the Reactor Building wall. The for each of the primary primary channel is in the Unit 1 portion of the building and and backup instrument channel displays.

the backup is in the Unit 2 portion.

b) If a display will be located somewhere b) Quad Cities' primary and backup instrument channel other than the control room or alternate shutdown panel, displays are located outside of the control room. As described above, they are located on the Main Turbine floor. This location was selected due to the milder please describe the environment and display location proximity to the main evaluation used to validate that the control room.

display location can be Radiological habitability at the display location has been accessed without evaluated against estimated dose rates from SFP drain unreasonable delay down to Level 3 conditions (EC #393703). For primary following a BDB event, Include the time channel electronics enclosure and transmitter enclosure(worst case) on the Unit 1 side of the plant, the available for personnel straight line distance from the pool to the electronics panel to access the display mounted in the Turbine Building at EL. 639'-0" is 80'. For as credited in the conservatism, using a distance of 70', and treating all walls evaluation, as we as and floors as a combined 3' in straight thickness, an overall the actual time (e.g.,

based on walk-dose rate for the area can be obtained. Based on Design Analysis BYR13-187 calculated dose rates as a function of throughs) that it will distance and wall thickness scaling factors, the dose rate is take for personnel to 8.30E+01 rem/hr x 2.151E-10 = 1.8E-08 rem/hr at the access the display.

primary channel enclosures during a BDBEE when the Additionally, please include a description of the radiological and environmental conditions on the water in the SFP is the top of the fuel assemblies.

Radiation exposure to personnel monitoring SFP levels would remain considerably less than exposure limits paths personnel might allowable for emergency responders, per Plant Emergency take. Describe whether Plan procedure EP-AA-113. Heat and humidity from a SFP the display location boil down conditions have been determined to be of remains habitable for minimal concern as the display locations are outside the radiological, heat and secondary containment such that heat and humidity from a humidity, and other boiling SFP would not compromise habitability concerns for environmental accessing these displays. The expected Turbine Building conditions following a temperatures with loss of ventilation max for all conditions BOB event. Describe is 120 F and humidity can reach 90%NC (non-condensing) whether personnel are continuously stationed and at 100% NC for LOCA at the display or Both primary and backup instrument channel displays are monitor the display located to reduce likelihood of missile damage. The display Page 19 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 periodically. locations are mounted on seismic category I structure wall adjacent to safety related 4 kV switchgear. Per section 3.2 and 3.8 the Turbine Building location selected "assures a degree of safety against structural failure afforded as to Class I equipment located within the Class I reactor building."

Spent fuel pool level control and level display monitoring will be the responsibility of an Equipment Operator position, who will normally be observing pool level at the location of the primary display once dispatched from the Control Room. Travel time from the Control Room to the primary display is approximately 2 to 5 minutes based on traveling trials on various paths available. Travel time from the Control Room to the secondary display location is approximately 3 to 6 minute based on trial runs along various travel paths. Radiological habitability for the transit routes to both displays has been evaluated for estimated dose rates from SFP drain down to Level 3 conditions (EC #393703). Exposure to personnel monitoring SFP levels would remain considerably less than exposure limits allowable for emergency responders to perform this action, per the Plant Emergency Plan procedure EP-AA-113. Heat and humidity from a SFP boil down conditions have been determined to be of minimal concern as the travel paths are outside the secondary containment such that heat and humidity from a boiling SFP would not compromise habitability concerns for accessing these displays.

Diverse communications are accessible at both display locations. The operators would first employ radio communications or the telephone communication. If the radio communications or telephone systems are non-functional, the sound powered phone system is assumed available because no power is required.. Sound powered phone jacks units are located near both display locations and can be setup as needed.

For severe accidents scenarios involving core damage and increased radiological exposure levels, access to these SFP level displays for short term can be achieved (see UFSAR chapter 12, Reference 12.3.6-1). Exposure duration to personnel monitoring SFP levels would be limited to remain within exposure allowable for emergency responders to perform this action, per the Plant Emergency Plan procedure EP-AA-113. The SFP electronics and displays are not expected to take radiation dose higher than the qualified TID 1.0E03 rads. This is because the location is outside secondary containment and not near any piping systems that could contain fission products. (see UFSAR chapter 12, Reference 12.3.6-1). Heat and humidity from Page 20 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Post Accident conditions have been determined to be of minimal concern as some travel paths are outside the secondary containment and heat and humidity conditions are the same as for BDE scenarios.

The diverse travel paths provide alternate access to the displays addressing concerns of potential missiles impacts.

6 RAI Question:

Complete (RAI-Please provide a list of The modification review process will be used to ensure all 13, the procedures necessary procedures are developed for maintaining and Ref. 5) addressing operation operating the spent fuel level instruments upon installation.

(both normal and These procedures will be developed in accordance with the abnormal response),

calibration, test, maintenance, and Exelon's procedural control process.

The objectives of each procedural area are described below:

inspection procedures that will be developed for use of the spent

• System Inspection SFP instrumentation.

Please provide a brief description of the To verify that system components are in place, complete, and in the correct configuration, and that the sensor probe is clean.

specific technical objectives to be

• Calibration and Test achieved within each To verify that the system is within the specified accuracy, is procedure.

functioning as designed, and is appropriately indicating SFP water level.

• Maintenance To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.

• Operation To provide sufficient instructions for operation and use of the system by plant operation staff. To specify troubleshooting/diagnostics information to help identify component repair and replacement activities in the event of system malfunction, as appropriate.

• Responses To define the actions to be taken upon observation of system level indications, including actions to be taken at the levels defined in NEI 12-02.

7

Potential Draft Safety Evaluation Impacts(Ref. 5)

There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 21 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (RS 035)

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.

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-13-159).

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 9, 2013.

6. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated November 26, 2013.

7. 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-13-128).

8. 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-14-025).

9. Attachments

• RAI 2 Sketch

• RAI 3 Sketch Page 22 of 24

EM BEDDED CONDLJIT-EMBEDDED coriDIJIT LEVEL PROBE ---

(P R

--LED PROBE (KLJ P)

U-2 mu_ Pool.

X.4.1'(r)

U-i FlJEL POOL (33 -IZI"

)

L NE W FUEL

1:3 VAULT

• "-.)

kI DECON PADt:i

\\ 0 /

Quad Cities Nuclear Power Station. Units I and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28. 2014 TO TRANSM ITTER (TURBIPI E BLDG)

'TO TR*ISMITTEF' (T1JRBINE BLDG)

SENSOR CABLE QUAD CITIES SPENT FUEL LEVEL INSTRUMENTATION LAYOUT (PORTION OF THE REFUEL FLOOR ELEV. BgVB")

RAI 2 SKETCH Page 23 of 24

SS Embedded plate (Refuel Floor)

SS Liner (from concrete)

Quad Cities Nuclear Power Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 25.25" 4

4-5/8" SS bolts Cable bracket Sensor Bracket Assembly (SS)

Sensor bracket, Launch plate Welded tube steel(SS curb Sensor probe location trough Pool RAI 3 Sketch, Level Sensor Assembly w/Mechanical Attachment Points Page 24 of 24