RS-15-280, 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)

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)

ML15352A135
Person / Time
Site:	Peach Bottom
Issue date:	12/15/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-280, TAC MF0845, TAC MF0846, TAC MF0849, TAC MF0850
Download: ML15352A135 (8)

Text

Exelon Generation RS-15-280 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Order No. EA-12-051 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

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-13-034)

6. NRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 24, 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 19, 2013 (RS-13-178)

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-13-126)

~ -

• .,.~- -

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 2

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-14-024)

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-14-202)

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-15-032)

12. Exelon Generation Company, LLC Fifth 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, 2015 (RS-15-204)

13. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - 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. MF0849 and MF0850), dated October 30, 2013

14. NRC letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0845, MF0846, MF0849 and MF0850), dated September 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 (OIP) 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 Peach Bottom Atomic Power Station, Units 2 and 3 OIP.

Reference 1 required submission of a status report at six-month intervals following submittal of the 01 P. References 8, 9, 10, 11, and 12 provided the first, second, third, fourth, and fifth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Peach Bottom Atomic Power Station, Units 2 and 3.

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 Peach Bottom Atomic Power Station, Units 2 and 3.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 3 Peach Bottom Atomic Power Station, Units 2 and 3 have installed two independent full scale level monitors for the Spent Fuel Pool (SFP) in response to Order EA-12-051. Peach Bottom Atomic Power Station, Units 2 and 3 OIP Open Items have been addressed and closed as documented in References 8, 9, 10, 11, and 12, and are considered complete pending NRC closure. The information provided herein documents full compliance for Peach Bottom Atomic Power Station, Units 2 and 3 with Reference 1.

EGC's response to the NRC OIP Requests for Additional Information (OIP RAls), and the NRC Interim Staff Evaluation (ISE) Open Items (ISE RAls) identified in References 6 and 13 have been addressed and closed as documented in References 7, 8, 9, 1 O, 11, 12, and below, and are considered complete pending NRC closure. The following table provides completion references for each NRC OIP RAI and ISE RAI.

OIP Open Item No. 1 Reference 8 OIP RAI No. 1 Reference 7 OIP RAI Nos. 2, 3, 4, 5 Reference 12 OIP RAI No. 7 Reference 1 O OIP RAI No. 8 Reference 12 and updated with this submittal as provided below OIP RAI No. 11 Reference 11 ISE RAI No. 1 Reference 9 ISE RAI Nos. 4, 5, 7 Reference 12 ISE RAI No. 9 (replaces OIP RAI 6)

Reference 11 ISE RAI No. 12 (replaces OIP RAI 9)

Reference 1 O ISE RAI No. 13 (replaces OIP RAI 10)

Reference 12 and updated with this submittal as provided below Table Notes:

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 additional audit open items have been addressed as documented in the NRC Site Audit Report (Reference 14). Reference 14 contains no remaining audit open items regarding Peach Bottom Atomic Power Station, Units 2 and 3 compliance with NRC Order EA-12-051.

The table below documents the completion of the final remaining open actions as identified in Reference 12. As stated above, EGC provides the response for the following items and considers them to be complete for Peach Bottom Atomic Power Station, Units 2 and 3.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 4 Item Description OIP Item 9 (RAl-8, Ref. 7) a) Westinghouse provided test equipment that provides the RAI Question:

capability to enable periodic Please provide the testing and calibration of the following:

proposed level sensing equipment. Westinghouse a) A description of the calibration procedure WNA-TP-04709-GEN and functional test capability and provisions procedure WNA-TP-04613-GEN the proposed level sensing provide instructions to use the equipment will have to test equipment to perform enable periodic testing and periodic testing and calibration, calibration, including how including in-situ testing. Peach this capability enables the Bottom Atomic Power Station in-equipment to be tested in-situ test methodology is based on situ.

the Westinghouse Two Point Verification Method, LTR-SFPIS-b) A description of how 14-55.

such testing and calibration b) The level displayed by the will enable the conduct of channels will be verified per the regular channel checks of Peach Bottom Atomic Power each independent channel Station operating procedures, as against the other, and recommended by Westinghouse against any other vendor technical manual WNA-permanently-installed SFP G0-00127-GEN. If the level is level instrumentation.

not within the required accuracy per Westinghouse recommended c) A description of how tolerance in WNA-TP-04709-functional checks will be GEN, channel calibration will be performed, and the performed.

frequency at which they will be conducted. Describe how c) The functional test and calibration tests will be calibration are combined in the performed, and the same procedure, IC-11-00660.

The Peach Bottom procedure is frequency at which they will associated with a PM that be conducted. Provide a establishes the required discussion as to how these performance of the procedure 60 surveillances will be days prior to a scheduled incorporated into the plant refueling outage of either unit.

surveillance program.

These procedures are based off of the Westinghouse Two Point d) A description of what Verification Method and WNA-TP-preventive maintenance 04709-GEN Spent Fuel Pool tasks are required to be Instrument Svstem Calibration Reference Complete With this Compliance submittal.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 5 performed during normal Procedure. The procedure operation, and the planned establishes the current water maximum surveillance level by measuring the distance interval that is necessary to to the water referenced from the ensure that the channels are bottom of the launch plate. This fully conditioned to measured distance is then accurately and reliably compared to the level indication perform their functions obtaining the As-Found indication when needed.

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 procedure is 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 Peach Bottom procedures were taken from Westinghouse document WNA-TP-04709-GEN Spent Fuel Pool Instrument System Calibration Procedure.

d) Peach Bottom Atomic Power Station has developed preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-GO-00127-GEN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed.

ISE Item 7 (RAl-13, Ref. 13)

Site procedures have been developed for RAI Question:

system inspection, calibration and test, Please provide a list of the maintenance, operation and normal and procedures addressing abnormal responses, in accordance with operation (both normal and Exelon's procedure control process.

abnormal response),

Technical objectives to be achieved in calibration, test, each of the respective procedures are Complete With this Compliance submittal.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 6 maintenance, and described below:

inspection procedures that will be developed for use of Procedure Objectives to be achieved:

the SFP instrumentation.

1. System Inspection: To verify The licensee is requested to that visible portions of system include a brief description of components are in place, the specific technical complete, and in the correct objectives to be achieved configuration.

within each procedure.

2. Calibration and Test: To verify that the system is 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. Operation: To provide sufficient instructions for operation and use of the system by plant operation staff.

5. 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.

The list of procedures was provided to the NRC's Khoi Nguyen on June 25, 2015 while he was on site at Peach Bottom to perform the audit. The associated SE tracker item was closed out at that time.

MILESTONE SCHEDULE - ITEMS COMPLETE Milestone Completion Date Submit 60 Dav Status Report October 25, 2012 Submit Overall lnteqrated Plan February 28, 2013 Submit Responses to RAls July 19, 2013 Submit 6 Month Updates:

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 7 Milestone Update 1 Update 2 Update 3 Update 4 Update 5 Modifications:

Conceptual Design Issue Exelon Fleet contract to procure SFPI Equipment BeQin Detailed DesiQn EnQineerinQ Complete and Issue SFPI Modification Package Begin Installation Complete SFPI Installation and Put Into Service Completion Date August28,2013 February 28, 2014 AuQust28,2014 February 27, 2015 AuQust28,2015 302012 202013 402013 102015 202015 October 09, 2015 ORDER EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

The elements identified below for Peach Bottom Atomic Power Station, Units 2 and 3, as well as the site overall integrated plan response submittal (Reference 5), and the 6-Month Status Reports (References 8, 9, 10, 11, and 12), demonstrate compliance with Order EA-12-051.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING - COMPLETE Peach Bottom Atomic Power Station, Units 2 and 3 have 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 Peach Bottom Atomic Power Station, Units 2 and 3 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 Jevel info~mation to be promptly available to decision makers.

-.~-*-.:-.

U.S. Nuclear Regulatory Commission Report of Full Compliance with Order EA-12-051 December 15, 2015 Page 8 PROGRAM FEATURES - COMPLETE Training for Peach Bottom Atomic Power Station, Units 2 and 3 has been completed in accordance with an accepted training process as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures for Peach Bottom Atomic Power Station, Units 2

• and 3 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.

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 151h day of December 2015.

Re~c=ube&:-

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc:

Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station Mr. Peter J. Bamford, NRR/JLD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection