RS-14-199, 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)

ML14248A214
Person / Time
Site:	LaSalle
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-14-199
Download: ML14248A214 (36)

Text

.1111111111,

/MP

Exelon Generation Order No. EA-12-051 RS-14-199 August 28, 2014 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:

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-13-031)

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 021)

8. 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

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 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 and 7 provided the first and second 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 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 28`"

day of August 2014.

Respectfully submitted, 71 1e,(7-,

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

Enclosure:

1. LaSalle County 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 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/DORL/LPL3-2, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure LaSalle County 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 (32 pages)

LaSalle County 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 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 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 7), and are current as of August 28, 2014.

• Provided responses to all RAls via E-Portal on June 20, 2014

• Completed and Issued SFPI Modification Package

• Began Installation of SFPI 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 Page 1 of 32

LaSalle County 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 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete with this submittal Provide Final Safety Evaluation (SE) Info September 30, 2014 Complete Modifications:

Conceptual Design 3Q2012 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 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 Page 3 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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.

4 RAI Question:

Complete.

(RAI-3, Please provide the following:

a)

All SFPIS equipment will be designed Ref.4) a) The design criteria that will be in accordance with the LaSalle Station used to estimate the total Safe Shutdown Earthquake (SSE) loading on the mounting device(s), including static weight loads and dynamic loads.

design requirements.

Describe the methodology that The vendor, Westinghouse, has will be used to estimate the total evaluated the structural integrity of the loading, inclusive of design mounting bracket in calculation CN-basis maximum seismic loads and the hydrodynamic loads that PEUS-14-5. The GTSTRUDL model, used by Westinghouse to calculate the could result from pool sloshing or other effects that could stresses in the bracket assembly, considers load combinations for the accompany such seismic forces, b) A description of the manner in which the level sensor (and stilling well, if appropriate) will dead load, live load and seismic load on the bracket. The reactionary forces calculated from these loads become be attached to the refueling floor the design inputs to design the and/or other support structures mounting bracket anchorage to the for each planned point of refuel floor to withstand a Safe attachment of the probe assembly. Indicate in a Shutdown Earthquake (SSE).

schematic the portions of the level sensor that will serve as points of attachment Seismic for mechanical/mounting or The seismic loads are obtained from electrical connections.

LaSalle Station's response spectra c) A description of the manner curves (Reference DC-SE-02-LS by which the mechanical Seismic Response Spectra Design connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

Criteria). 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 Page 4 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 three directions.

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

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

This method is endorsed per Appendix B of the Updated FSAR Revision 20 for LaSalle County Power Station.

• 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.

• 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 Page 5 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 and added to the total reactionary forces that would be applicable for bracket anchorage 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.

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 Seismic Analysis of the SFP Mounting Bracket at LaSalle and Quad Cities Nuclear Generating Stations

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 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 Page 6 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors. Attachment 1 shows a schematic of the level sensor bracket with mechanical attachment points including locations for the coupler and probe.

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 LaSalle 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 LaSalle Station specific calculation L-003911 Evaluation of SFPI Sensor Mounting Bracket Anchor Plate Detail for components 1/2LE-FC165.

5 RAI Question:

Complete.

(RAI-4, Please provide the following:

a)

Beyond Design Basis Environment Ref.4) a) A description of the specific Westinghouse qualified the method or combination of components (probe, connector, cable) methods you intend to apply to demonstrate the reliability of the permanently installed equipment of the SFPIS located in the SFP area to the beyond design basis environment.

under BDB ambient temperature, humidity, shock, vibration, and Components of the system were subjected to beyond design basis radiation conditions.

conditions of heat and humidity, thermal and radiation aging b) A description of the testing mechanisms. This testing confirmed and/or analyses that will be functionality of these system conducted to provide assurance components under these beyond that the equipment will perform reliably under the worst-case credible design basis loading at design basis environmental conditions.

Westinghouse performed testing to the location where the ensure aging of the components in the equipment will be mounted.

SFP area will not have a significant Page 7 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 effect on the ability of the equipment to perform following a plant design basis earthquake. Exelon has reviewed the documents and found them acceptable.

Reference Westinghouse documents EQ-TP-351, WNA-TR-03149-GEN, and EQ-TP-354 for description of specific qualification methods.

Mild Environment Westinghouse qualified the system components (display panel, transmitter) that reside in the mild environment conditions to determine that the components can satisfactorily perform to those conditions. Westinghouse has determined that aging does not have a significant effect on the ability of the equipment to perform following a plant design basis earthquake. Exelon has reviewed the documents and found them acceptable. 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 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 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.

Page 8 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 are enclosed in a NEMA-4X housing.

The display electronics panel utilizes a NEMA-4X rated stainless steel housing as well. These housings will be mounted to a seismically qualified wall and will contain the active electronics, and aid in protecting the internal components from vibration induced damage.

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

b) The seismic adequacy of the SFPIS (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 lE Equipment for Nuclear Power Generating Stations USNRC Regulatory Guide Page 9 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 1.100, Rev. 3

• USNRC Regulatory Guide 1.92, Rev. 1

• Calculation L-003913 Evaluation of Mounting Details for components 1/2LT-FC165 &

1/2PLH13J, A Grouted Conduit Support & a 3" Diameter Core Hole for a 11/2 "Conduit

• L-003911 Evaluation of SFPIS Sensor Mounting Bracket Anchor Plate Detail for Components 1/2LE-FC165 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-GEN, EQ-TP-353 describe remaining seismic qualifications of the instrument components. With the instrument being seismically qualified and installed as described in RAI 5b response, the instrument is assured to maintain reliable and accurate indication when required. Westinghouse report WNA-CN-00301-GEN provides the channel accuracy from measurement to display.

6 RAI Question:

Complete.

(RAI-5, Please provide the following:

The two channels of the proposed level Ref.4) a) A description of how the two measurement system will be installed such channels of the proposed level measurement system meet that:

this requirement so that the a) The level probes will be mounted on the potential for a common cause west side of the SFP and will be event to adversely affect both channels is minimized to the separated by a distance greater than the extent practicable.

span of the shortest side of the pool. This b)

Further information on how meets the NEI 12-02 Revision 1 guidance each level measurement system, consisting of level for channel separation.

sensor electronics, cabling, and readout devices will be b) The level transmitter and the electronics /

UPS enclosure for the primary instrument designed and installed to channel will be installed in the Auxiliary Page 10 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 address independence Building in Unit 1 elevation 731. The level through the application and selection of independent power sources, the use of transmitter and the electronics / UPS enclosure for the backup instrument physical and spatial channel will be installed in the Unit 2 separation, independence of Auxiliary Building elevation 731. Physical signals sent to the location(s) and spatial separation of the level sensors of the readout devices, and the and electronics / UPS enclosures for independence of the displays.

primary and backup instrument channels is maintained by routing the associated instrument channel cables through Unit 1 and Unit 2 respectively. The 120 VAC power to the primary instrument will be provided from safety related Division 1, 120 volt distribution panel at 480 volt MCC 135X-3. The 120 VAC power to the backup level instrument will be provided from safety related Division 2, 120 volt distribution panel at 480 volt MCC 236X-3.

The 120VAC distribution panels for the primary and backup instruments are powered by different 480V safety buses.

Therefore, the loss of any one bus will not result in the loss of AC power to both instrument channels.

7 RAI Question:

Complete.

(RAI-6, Please provide the following:

a)

The primary SFPLI instrument channel Ref.4) a) A description of the electrical ac power sources and capacities for the primary and will be normally powered from Unit 1 Division 1 120 VAC distribution panel at backup channels.

480 volt MCC 135X-3. The backup b) Please provide the results of SFPLI instrument channel will be the calculation depicting the normally powered from Unit 2 Division battery backup duty cycle 2 120 VAC distribution panel at 480 volt requirements demonstrating MCC 236X-3. These are on different that its capacity is sufficient to maintain the water level safety buses, which maintain power indication function until offsite source independence. Upon loss of resource availability is normal AC power, individual batteries reasonably installed in each channel's electronics /

assured.

UPS enclosure will automatically maintain continuous channel operation for at least (3) days. The power cables will be routed on the Unit 1 side for the primary channel and on the Unit 2 side for the backup channel so that spatial and physical separation is maintained between the primary and backup Page 11 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 channels. These MCCs have also been identified as part of the FLEX strategy to ensure that the SFPLI will have AC power restored if a Beyond Design Basis External Event would occur.

Additionally, a receptacle and a selector switch are installed in each channel electronics / UPS enclosure to directly connect emergency power to the SFPLI.

b) The Westinghouse Report, WNA-CN-00300-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 location, located in the Unit 1 and Unit 2 Auxiliary Building 731 elevation at LaSalle Station.

The results of the calculation meet the NEI 12-02 requirements.

8 RAI Question:

Complete.

(RAI-7, Please provide the following:

a) The Westinghouse documents WNA-Ref.4) a) An estimate of the expected CN-00301 and WNA-DS-02957-GEN instrument channel accuracy describe the channel accuracy under performance (e.g., in percent of span) under both (a) both (a) normal SFP level conditions normal SFP level conditions and (b) at the Beyond Design Basis (approximately (BDB) conditions that would be present Levell or higher) and (b) at if SFP level were at Level 2 and Level 3 the BDB conditions (i.e.,

radiation, temperature, humidity, post-seismic and datum points. Each instrument channel will be accurate to within +/-3"cluring normal spent fuel pool level conditions.

post-shock conditions} that The instrument channels will retain this would be present if the SFP accuracy after BDB conditions, in water level were at the Level 2 and Level 3 datum points.

b) A description of the accordance with the above Westinghouse documents. This value methodology that will be is within the channel accuracy used for determining the requirements of the Order (+/-1 foot).

maximum allowed deviation b) The Westinghouse document WNA-TP-from the instrument channel design accuracy that will be employed under normal 04709-GEN describes the methodology for routine testing/calibration verification and calibration methodology. This Page 12 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 operating conditions as an document also specifies the required acceptance criterion for a accuracy criteria under normal calibration procedure to flag operating conditions. LaSalle Station to operators and to technicians that the channel calibration and channel verification requires adjustment to within procedures will follow the guidance and the normal condition design criteria provided in this document.

accuracy.

Instrument channel calibration will be performed if the level indication reflects a value that is outside the acceptance band established in the LaSalle Station calibration and channel verification procedures.

Calibration will be performed once per refueling cycle for LaSalle Station.

Per Westinghouse 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%). This is in compliance with the NEI 12-02 guidance for Spent Fuel Pool Instrumentation. This is not required to be performed more than once per 12 months.

9 RAI Question:

Started.

(RAI-8, Please provide the following:

a)

Westinghouse calibration procedure Ref.4) a) A description of the WNA-TP-04709-GEN and functional capability and provisions the test procedure WNA-TP-04613-GEN proposed water level sensing equipment will have to enable periodic testing and describe the capabilities and provisions of SFPI periodic testing and calibration, calibration, including how including in-situ testing. LaSalle must this capability enables the use a different in-situ test methodology equipment to be tested in-to accommodate LaSalle's low profile situ.

bracket installation. Westinghouse b) A description of how such delivered an addendum to above test testing and calibration will procedures describing the new in-situ enable the conduct of regular test methodology for LaSalle. LaSalle channel checks of each independent channel against has reviewed the methodology and Page 13 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 the other, and against any other permanently-installed found it acceptable.

SFP level instrumentation.

b)

The level displayed by the channels will c) A description of how be verified per the LaSalle Station functional checks will be administrative and operating performed, and the procedures, as recommended by frequency at which they will Westinghouse vendor technical manual be conducted. Describe how WNA-G0-00127-GEN. If the level is calibration tests will be not within the required accuracy per performed, and the frequency at which they will be conducted.

Westinghouse recommended tolerance in WNA-TP-04709-GEN then channel Provide a discussion as to calibration will be performed.

how these surveillances will c)

Functional checks will be performed per be incorporated into the plant surveillance program.

Westinghouse functionality test d) A description of what preventive maintenance procedure WNA-TP-04613-GEN at the Westinghouse recommended tasks are required to be frequency.

Calibration tests will be performed during normal performed per Westinghouse operation, and the planned calibration procedure WNA-TP-04709-maximum surveillance GEN at the Westinghouse interval that is necessary to ensure that the channels are recommended frequency.

fully conditioned to In accordance with LaSalle Station accurately and reliably perform their functions when needed.

maintenance and operating programs, LaSalle Station will develop calibration, functional test, and channel verification procedures per Westinghouse recommendations to ensure reliable, accurate and continuous SFPI functionality by December 31, 2014.

d)

LaSalle Station will develop preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-G0-00127-GEN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed by December 31, 2014.

10 RAI Question:

Complete.

(RAI-9, Please provide the following:

a)

LaSalle's primary and backup Ref.4) a) The specific location for each instrument channels are located in of the primary and backup the Unit 1 and Unit 2 Division 2 instrument channel displays.

b) If the primary and backup display location is other than Switchgear Room respectively.

Page 14 of 32

Response for b) and c):

LaSalle's primary and backup instrument channel display are located outside of the control room and alternate shutdown panel. As described above, they are located in the Unit 1 and Unit 2 Division 2 Switchgear Room respectively. This location was selected due to the display location proximity to the main control room, and alternate shutdown panel.

Radiological habitability at this location has been evaluated against LaSalle UFSAR Table 3.11-26 Controlled Environment Zone C2 Conditions Inside the Essential Switchgear Rooms for core melt scenario estimated radiological conditions as well as estimated dose rates from SFP draindown conditions to level 3, (calculation BYR13-187) and exposure to personnel monitoring SFP levels would remain less than emergency exposure limits allowable for emergency responders to perform this action. Heat and humidity from SFP boildown conditions have been evaluated for this location. The location is at an elevation below the SFP operating floor and located in a different building physically separated by concrete walls, closed air lock/fire doors from the SFP such that heat and humidity from a boiling SFP would not compromise habitability at this location.

Spent Fuel Pool Level monitoring will be the responsibility of Operations personnel who will monitor the display periodically once dispatched from the Control Room. Travel time from the Control Room to the primary and secondary displays is approximately 6 minutes based on walkdowns.

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.

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Page 15 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Radiological habitability for the transit routes to both displays has been evaluated against LaSalle Station UFSAR Table 3.11-21 Normal Environment Zone Ni Service Conditions in the Auxiliary Building for core melt scenario conditions as well as estimated dose rates from SFP draindown conditions to Level 3, (calculation BYR13-187) and exposure to personnel monitoring SFP levels would remain less than emergency exposure limits allowable for emergency responders to perform this action. Heat and humidity from SFP boildown conditions have been evaluated for access to this location, and the access routes are below the SFP operating floor and located in a different building physically separated by closed air lock/fire doors from the SFP such that heat and humidity from a boiling SFP would not compromise habitability concerns with 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.

The display will be accessed on demand. It takes up to 6 minutes to reach the display location, for both the primary and backup channels, when an operator is dispatched from the control room. The actual time for accessing the display locations is based on walkthroughs in the plant by the Page 16 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Operations, Engineering, and Maintenance personnel. The walkthrough to access the display locations is within the robust seismic category I structures, from the control room to the display locations, located in the Unit 1 and Unit 2 Division 2 Switchg ear Rooms. Upon obtaining the indicated SFP level from the display location, the operators will use the sound powered phone system to provide the information to the control room immediately. Being able to provide the indicated SFP level within approximately 10 minutes is not considered an unreasonable delay.

11 (RAI-10, Ref.4)

RAI Question:

Complete.

process will be used procedures are and operating the upon installation.

be developed in procedural control of each procedural 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.

The modification review to ensure all necessary developed for maintaining spent fuel level instruments These procedures will accordance with Exelon's process. The objectives area are described below:

Procedure Objectives to be achieved

1.

System Inspection To verify that system components are in place, complete, and in the correct configuration, and that the sensor probe is free of significant deposits of crystallized boric acid.

2.

Calibration and Test To verify that the system is within the specified accuracy, is functioning as designed, and is appropriately indicating Page 17 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 SFP water level.

3.

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

4.

Repair To specify troubleshooting steps and component repair and replacement activities in the event of system malfunction.

5.

Operation To provide sufficient instructions for operation and use of the system by plant Operations staff.

6.

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.

12 (RAI-11, Ref.4)

RAI Question:

Completed.

checks) and checks will be the vendor operator's information is in plant operating tests are planned to be as recommended by the 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 Response for a:

Performance tests (functional Operator performance described in detail in manual, and the applicable planned to be contained procedures.

Operator performance performed periodically Page 1 8 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 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.

Page 19 of 32

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 will be controlled by CC-LA-118-1001 Diverse and Flexible Coping Strategies (Flex) and Spent Fuel Pool Instrumentation Program Implementation and are summarized as follows:

Compensatory Action if Required Restoration Action not completed within Specified Time Channel(s)

Out-of-Service Required Restoration Action 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 Initiate action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Immediately initiate action in accordance LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Page 20 of 32

restore one

with note channel to

below 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 />.

Note: Present a report to the on-site 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 for restoring the instrumentation channel(s) to functional status.

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Draft Safety Evaluation Open Items 01#

Description Status 1

(RAI-1, Ref.

5)

RAI Question:

Cornelete.

Please provide additional information describing how the final arrangement of the SFP instrumentation 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.

The two sensors will be mounted in different locations of the SFP and separated by a distance comparable to the shortest side of the pool. The coaxial cables that extend from the two sensors toward the location of the transmitters (sensors electronics) will be installed using separate routes and separate conduits. The existing embedded conduits in the floor concrete will provide a physical barrier to protect the coax cable from potential missile hazards. The conduits and tray system (in which the coax cables are installed) will be separated in accordance with current plant licensing bases criteria for electrical separation as defined in LaSalle Station UFSAR Section 8.3.1.4.2 Physical Separation Criteria. The 4-20mA cables that extend from the transmitter to the electronics enclosure (display) location will also be installed in separate conduits and will be routed separately in accordance with current plant licensing bases criteria for electrical separation as defined in LaSalle Station UFSAR Section 8.3.1.4.2 Physical Separation Criteria.

Page 21 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 2

(RAI-3, Ref.

5)

RAI Question:

Corn

• lete.

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.

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 Seismic Analysis of the SFP Mounting Bracket at LaSalle and Quad Cities Nuclear Generating Stations

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 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.

LaSalle Station specific calculations L-003911 Evaluation of SFPIS Sensor Bracket Mounting Bracket Anchor Plate Detail for Components 1/2LE-FC165 and L-003913 Evaluation of Mounting details for Components 1/2LT-FC165 & 1/2PLH13J, A Grouted Conduit support & a 3" diameter Core Hole for a 11/2" Conduit, will address the seismic qualifications. The design criteria used in these calculations satisfies the requirements to withstand a SSE and will meet the LaSalle Station's safety related installation requirements for mounting.

3 RAI Question:

Complete (RAI-For each of the The structural integrity and mounting of SFP level equipment is 4,

Ref.

mounting attachments required to attach SFP level based on formal calculations, plant drawings, and approved work plans per Exelon procedures and processes.

5) equipment to plant Design inputs include the following:

structures, please describe the design

1. Component weights and dimensions, core hole inputs, and the methodology that was used to qualify locations and support details.

2. The capability of concrete expansion anchors.

the structural

3. The loads (dynamic and static) for the probe mounting integrity of the affected bracket.

structures/equipment

4. Concrete properties.

5. Seismic acceleration requirements for electrical Page 22 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 equipment.

6. Allowable stresses for structural bolts Methodology to qualify the structural integrity includes, but not limited to the following:

1. Structural Weldments Qualifying the weld design entails the selection of a weld's physical attributes, such as type, configuration and size, which will make it suitable for transferring the prescribed loads within the appropriate limits. This process involves determining the maximum unit forces on the weld and comparing them with the weld capacity. The methodology determines weld design forces by assuming nominal linear stress/strain distribution of stiffness within the joint is consistent with this assumption. In some cases more refined techniques may be required to predict appropriate distribution of weld forces.

2. Concrete Expansions The design methodology of concrete expansion anchor assemblies involves 1) application of component attachment loads to the plate,

2) analysis of the assembly to determine the resultant tension and shear forces on individual anchors, 3) evaluation of the anchor forces relative to anchor allowable and 4) computation and evaluation of bending stresses in the CEA plate. Reactions for the attached component (applied to the plate at the centroid of the attachment weld) shall be resolved into moments, shears and triaxial loads (about the major axes of the expansion anchor plate).

3. Local Stress Effects The member local stresses for open sections are computed according to specific procedures for flange attachments, web attachments, attachments to flanges of beams supporting concrete, and attachment of webs of beams supporting concrete.

4. Existing Embedment Plate Evaluation Embedment plates for mechanical/electrical component supports attachments (i.e., pipe supports, conduit supports, HVAC supports, etc.) are evaluated as follows:

• Determine embedment plate detail based on the component support design drawing and appropriate structural drawings.

• Determine an allowable load for the embedment plate per design tables.

Page 23 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014

• Ensure that the attachment location satisfies the location tolerances used in determining the embedment plate allowances.

• Calculate reactions at face of embedment plate.

• Determine if the embedment plate can be qualified per criteria.

5. Conduit and Conduit Supports Structural adequacy of rigid conduit is evaluated by determining the critical span condition, loads, checking conduit stresses and verifying structural adequacy of conduit clamps.

Structural adequacy of conduit, junction boxes and junction box supports is evaluated by determining loads, calculating member forces and joint reactions, checking member stresses, checking expansion anchor assemblies, checking attachments to structure and resolving overstresses.

6. Cable Tray Loading Violations (CTLVs) The structural evaluation of cable tray supports for potential increase in design basis loading will be performed by identifying the hangers affected by the routing point. For each affected hanger controlling routing point will be determined. Then actual load associated with the routing point will be computed. Then the actual load will be compared to the load used in the hanger design. An evaluation of cable tray hanger for any increased load will be performed.

7. Category 1 Partition Walls When qualifying a wall for a new/revised attachment, the following method is utilized:

• If the loads on the existing critical design strip are larger in magnitude than the loads on the design strip containing the new attachment, then the wall can be qualified by comparison.

• If the wall cannot be qualified by comparison of loading, moment and shear due to the attachment shall be calculated and their effects added to the critical design strip. New stresses or moment and shear will be compared to the allowable stresses/capacities.

• If this results in an unacceptable over stress condition, detailed evaluation of the design strip Page 24 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 containing the attachment is required. All existing attachments and core holes in the strip will be accounted for in this evaluation.

4 (RAI-6, Ref.

5)

RAI Question:

Started of the test conditions used by the SFPIS.

Environmental Conditions installed in the Spent Fuel Pool Area bounded by below test conditions, except above top of fuel rack for beyond design The BDB radiation TID, 12" above is 4.E07 R y, per calculation BYR13-051 Fuel Pool Doses. The BDB radiation value equipment is qualified to is 1.E07 of WNA-TR-03149-GEN. The radiation is higher than 1.E07 R y to which the instrument to. However, this value only when the water is at Level to 2.E07 R y and it further reduces above. With SFP water level at Level of SFPI that are exposed to high radiation probe and the stainless steel anchor.

which the probe and the anchor are resistant to radiation effects. The stainless steel probe can withstand 40 year updated the design specification (WNA-LTR-SFPIS-13-35, Revision 1 the above technical justification.

for SFPIS Components in the Spent coax coupler and connector assembly, side bracket assembly, coax cable are to operate reliably in the below specified to qualify qualified and to include Conditions conditions.

at top R

3. At to 3

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.

Below for for basis of fuel NEI to y, per value of Level 8.E06 the are The steel dose.

Fuel Level Westinghouse LaSalle Westinghouse manufactured DS-02957-GEN) documentation Environmental launch designed environmental is a summary SFPIS Components Station are radiation TID 12" conditions (BDB).

rack for LaSalle 12-02 Spent which the Westinghouse Section 5.1.1 of 4.E07 R y 4.E07 R y is applicable 2 the TID reduces at Level 1 and only components the stainless steel materials with are anchor and stainless Westinghouse Pool Area sensor probe, plate and pool and qualified Parameter Normal BDB Temperature 50-140°F 212°F Page 25 of 32

Atmospheric Atmospheric Pressure Humidity 100% (saturated steam) 0-95% RH Radiation TID y (above pool) 1E03 Rads 1E07 Rads 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 Atmospheric Atmospheric Atmospheric Humidity 0-95% RH 0-95%

(non-condensing) 0-95%

(non-condensing)

Duration 3 days 3 days 3 days Radiation TID Y

5 1E03 R y 5 1E03 R 5 1E03 R LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Page 26 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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 them acceptable.

Additionally, Westinghouse is continuing their aging tests to age the system components to 10 years. These tests are projected to be completed towards 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.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirms that the SFPIS meets the seismic requirements of the vendor's design specification. Westinghouse's design specification satisfies the LaSalle Station installation requirements to withstand a SSE.

Vibration Justification Components of the system (i.e., bracket, transmitter, display enclosure) will be permanently installed to meet the requirements to withstand a SSE and will meet the LaSalle Station safety related installation requirements. Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification Page 27 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 The sloshing calculation performed by Westinghouse was reviewed for a design basis seismic event and found acceptable. Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

5 RAI Question:

Complete (RAI_

Please provide the a)

LaSalle's primary and backup instrument channels 11, Ref.

following:

a) The specific location for each are located in the Unit 1 and Unit 2 Division 2 Switchgear Room respectively.

5) of the primary and backup instrument Response for b) and c):

channel displays.

LaSalle's primary and backup instrument channel b) Please describe display are located outside of the control room and the evaluation alternate shutdown panel. As described above, they are used to validate located in the Unit 1 and Unit 2 Division 2 Switchgear that the display Room respectively. This location was selected due to location can be accessed without unreasonable the display location proximity to the main control room, and alternate shutdown panel.

delay following a Radiological habitability at this location has been BDB event, Include an evaluated against LaSalle UFSAR Table 3.11-26 Controlled Environment Zone C2 Conditions Inside estimate of the the Essential Switchgear Rooms for core melt scenario time available for estimated radiological conditions as well as estimated personnel to access the dose rates from SFP draindown conditions to level 3, (calculation BYR13-187) and exposure to personnel display as well as the actual monitoring SFP levels would remain less than time it will take emergency exposure limits allowable for emergency for personnel to responders to perform this action. Heat and humidity access the from SFP boildown conditions have been evaluated for display.

this location. The location is at an elevation below the Additionally, please include a SFP operating floor and located in a different building physically separated by concrete walls, closed air description of lock/fire doors from the SFP such that heat and humidity the radiological from a boiling SFP would not compromise habitability at and environmental this location.

conditions on the Spent Fuel Pool Level monitoring will be the paths personnel responsibility of Operations personnel who will monitor might take.

the display periodically once dispatched from the Describe whether Control Room. Travel time from the Control Room to the the display location remains habitable for primary and secondary displays is approximately 6 minutes based on walkdowns. Radiological habitability radiological, heat for the transit routes to both displays has been evaluated against LaSalle Station UFSAR Table 3.11-Page 28 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 21 Normal Environment Zone Ni Service Conditions in the Auxiliary Building for core melt scenario conditions as well as estimated dose rates from SFP draindown conditions to Level 3, (calculation BYR13-187) and exposure to personnel monitoring SFP levels would remain less than emergency exposure limits allowable for emergency responders to perform this action. Heat and humidity from SFP boildown conditions have been evaluated for access to this location, and the access routes are below the SFP operating floor and located in a different building physically separated by closed air lock/fire doors from the SFP such that heat and humidity from a boiling SFP would not compromise habitability concerns with 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.

The display will be accessed on demand. It takes up to 6 minutes to reach the display location, for both the primary and backup channels, when an operator is dispatched from the control room. The actual time for accessing the display locations is based on walkthroughs in the plant by the Operations, Engineering, and Maintenance personnel. The walkthrough to access the display locations is within the robust seismic category I structures, from the control room to the display locations, located in the Unit 1 and Unit 2 Division 2 Switchgear Rooms. Upon obtaining the indicated SFP level from the display location, the operators will use the sound powered phone system to provide the information to the control room immediately.

Being able to provide the indicated SFP level within approximately 10 minutes is not considered an unreasonable delay.

Page 29 of 32 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 environmental conditions on the

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 paths personnel might take.

Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

6 RAIQuestion:

Complete (RAI-Please provide a list Appropriate quality measures will be selected for the SFPIS 12, of the procedures.

required by Order EA-12-051, consistent with Appendix A of Ref.

addressing operation (both normal and NEI 12-02. Site procedures will be developed for system

5) abnormal response),

calibration, test, maintenance, and inspection, calibration and test, maintenance, repair, operation and normal and abnormal responses, in accordance with Exelon's procedure control process. Technical objectives to be inspection achieved in each of the respective procedures are described procedures that will below:

be developed for use of the spent SFP instrumentation.

Procedure Objectives to be achieved Please provide a brief

1. System Inspection: To verify that system description components are in place, complete, and in the of the specific correct configuration, and that the sensor probe is technical objectives free of significant deposits.

to be achieved within

2. Calibration and Test: To verify that the system is each procedure.

within the specified accuracy, is functioning as designed, and is appropriately indicating SFP water level.

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

4. Repair: To specify troubleshooting steps and component repair and replacement activities in the Page 30 of 32

LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 event of system malfunction.

5. Operation: to provide sufficient instructions for operation and use of the system by plant operation staff.

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 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 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.

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 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).

Page 31 of 32

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ell OF 111Palae.Aal LaSalle County Station, Units 1 and 2 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 LaSalle Station Schematic of the Level Sensor Bracket