RS-15-081, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML15117A635
Person / Time
Site: LaSalle  
Issue date: 04/27/2015
From: Gaston R
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-081
Download: ML15117A635 (6)
v • d • e


Text

l RS-15-081 April 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 Order No. EA-12-051

Subject:

Report of Full Compliance with 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, 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. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7, 2013
7. Exelon Generation Company, LLC letter to NRC, Response to Request For Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051),

dated July 3, 2013 (RS-13-158)

8. 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)

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 April 27, 2015 Page2

9. 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 021)
10. 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)
11. Exelon Generation Company, LLC 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}, dated February 27, 2015 (RS 029)
12. 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

13. NRC letter to Exelon Generation Company, LLC, LaSalle County Station, Units 1 and 2

- Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF1119, MF1120, MF1121, and MF1122}, dated March 23, 2015 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directed 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 (01 P) pursuant to Section IV, Condition C. Reference 2 endorsed 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 LaSalle County Station, Units 1 and 2 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the OIP. References 8, 9, 10, and 11 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for LaSalle County Station.

The purpose of this letter is to provide the report of full compliance with the March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (Reference 1} pursuant to Section IV, Condition C.3 of the Order for LaSalle County Station, Units 1 and 2.

LaSalle County Station has installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. LaSalle County Station OIP Open Items have been addressed and closed as documented in References 8, 9, 10, and 11, and are considered complete pending NRC Closure. The information provided herein documents full compliance for LaSalle County Station, Units 1 and 2 with Reference 1.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 April 27, 2015 Page3 EGC's response to the NRG OIP Requests for Additional Information (OIP RAls), and the NRG Interim Staff Evaluation (ISE) Open Items (ISE RAls) identified in References 6 and 12 have been addressed and closed as documented in References 7, 8, 9, 10, and 11, and below, and are considered complete pending NRG Closure. The following table provides completion references for each NRG OIP RAI and ISE RAI.

OIP Open Item No. 1 Reference 8 OIP RAI Nos. 1, 2 Reference 7 OIP RAI Nos. 3, 4, 5, 6, 7, Ba, 8b, Reference 1 O 8d, 9, 10, 11a OIP RAI No. 8c Reference 1 O and updated with this submittal as provided below 01 P RAI Nos. 11 b, 11 c References 10 and 11 ISE RAI Nos. 1, 3, 4, 11, 12 References 1 o ISE RAI No. 6 References 1 O and 11 Note: ISE RAls are not duplicated in the table above if previously issued as OIP RAls in Reference 6.

EGC's response to the NRC audit questions and any additional audit open items have been addressed and closed as documented in the NRG Site Audit Report (Reference 13).

Reference 13 contains no remaining audit open items regarding LaSalle County Station's compliance with NRG Order EA-12-051.

The table below documents the completion of the final remaining open action as identified in Reference 11. As stated above, EGG provides the response for the following item and considers it to be complete for LaSalle County Station.

Item Description Reference OIP Item 9 (RAl-8, Ref.

c) The LaSalle function al test and calibration Com12lete

6) are combined in the same procedure(s) (LIP-c) A description of how FC-501 for U1 and LIP-FC-601 for U2). Each functional checks will be performed, and the Spent Fuel Pool Level Indicating System frequency at which they (Primary/Backup) has its own procedure. The will be conducted.

LaSalle procedures are associated with a Describe how calibration preventive maintenance task that establishes tests will be performed, the required performance of both procedures 60 days prior to a scheduled refueling outage and the frequency at on either unit. These procedures are based on which they will be the Westinghouse Two Point Verification conducted.

Provide a discussion as Method and WNA-TP-04709-GEN Spent Fuel to how these Pool Instrument System Calibration surveillances will be Procedure. LaSalle procedures establish the current water level by measuring the distance

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 April 27, 2015 Page4 incorporated into the to the water referenced from the bottom of the plant surveillance launch plate. This distance is compared to the program.

level indication to obtain the As-Found indication value. The probe is then lifted out of the water to a predetermined mark on the probe. The water level at the predetermined mark is then recorded. The probe is lowered back into the water freely suspended from the launch plate. The level indication is recorded.

If all three As-Found Level indications are within the tolerance specified, the procedures are exited. If the As-Found values are not within tolerance, the calibration is performed to bring the indication within the calibration requirements. The calibration steps of the LaSalle procedures were taken from Westinghouse document WNA-TP-04709-GEN Spent Fuel Pool Instrument System Calibration Procedure.

MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Day Status Report October 25, 2012 Submit Overall Integrated Plan February 28, 2013 Submit Responses to RAls July 3, 2013 Submit 6 Month Updates:

Update 1 August 28, 2013 Update 2 February 28, 2014 Provide Final Safety Evaluation (SE) Information March 31, 2014 Update 3 Auoust 28, 2014 Update 4 February 27, 2015 Modifications:

Conceptual Desiqn 302012 Begin Detailed Design Engineering 202013 Issue Exelon Fleet contract to procure SFPI 402013 Equipment Complete and Issue SFPI Modification Package 202014 Begin Installation 302014 Complete SFPI Installation and Put Into Service February 26, 2015

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 April 27, 2015 Page 5 ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for LaSalle County Station, as well as the site overall integrated plan response submittal (Reference 5), the 6-Month Status Reports (References 8, 9, 10, and 11 ), and any additional docketed correspondence, demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING *COMPLETE LaSalle County Station has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. These levels have been integrated into the site processes for monitoring level during events and responding to loss of SFP inventory.

INSTRUMENT DESIGN FEATURES.. COMPLETE The design of the instruments installed at LaSalle County Station complies with the requirements specified in the Order and described in NEI 12-02 "Industry Guidance for Compliance with NRC Order EA-12-051". The instruments have been installed in accordance with the station design control process.

The instruments have been arranged to provide reasonable protection against missiles.

The instruments have been mounted to retain design configuration during and following the maximum expected ground motion. The instruments will be reliable during expected environmental and radiological conditions when the SFP is at saturation for extended periods. The instruments are independent of each other and have separate and diverse power supplies. The instruments will maintain their design accuracy following a power interruption and are designed to allow for routine testing and calibration.

The instrument display is readily accessible during postulated events and allows for SFP level information to be promptly available to decision makers.

PROGRAM FEATURES.. COMPLETE Training for LaSalle County Station, Units 1 and 2 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures for LaSalle County Station have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 April 27, 2015 Page 6 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 April 2015.

Respectfully submitted,

~~

Ronald W. Gaston Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc:

Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region 111 NRG Senior Resident Inspector-LaSalle County Station, Units 1 and 2 NRG Project Manager, NRA - LaSalle County Station, Units 1 and 2 Mr. Jeremy S. Bowen, NRR/JLD/JOMB, NRG Ms. Jessica A. Kratchman, NRR/JLD/JPSB, NRG Mr. John P. Boska, NRR/JLD/JOMB, NRG Illinois Emergency Management Agency - Division of Nuclear Safety

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