L-14-032, August 2014 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)

August 2014 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)

ML14241A015
Person / Time
Site:	Ginna
Issue date:	08/26/2014
From:	Korsnick M Constellation Energy Nuclear Group, Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, FLL-14-032
Download: ML14241A015 (17)

Text

AMaria SExe!on to 0 t jSenior Generation Korsnick Vice President. Northeast Operations Chief Nuclear Officer, CENG 100 Constellation Way Suite 500P Constellation Energy Nuclear Group, LLC Baltimore, MD 21202 410-470-5133 Office 443-213-6739 Fax www.exeloncorp.com mara.korsnick@exeloncorp.com NRC Order No. EA-12-051 FLL-14-032 August 26, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket No. 50-244

Subject:

August 2014 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)

Reference:

(1) NRC Order Number EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ML12054A679)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051 (Reference 1) to Constellation Energy Nuclear Group, LLC (CENG) for R.E. Ginna Nuclear Power Plant, LLC (Ginna). Reference (1) requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Attachment (1) provides the third Six-Month Status Report for Ginna pursuant to Section IV, Condition C.2, of Reference (1). This report updates the milestone accomplishments since the submittal of the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

There are no regulatory commitments contained in this letter.

If there are any questions regarding this letter, please contact Bruce Montgomery, Acting Manager - Licensing, at 443-532-6533.

U. S. Nuclear Regulatory Commission August 26, 2014 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 6 th day of August, 2014.

Respectfully, Mary G. Korsnick MGK/STD Attachment (1) Six-Month Status Report (August 2014) for Reliable Spent Fuel Pool Instrumentation cc: Regional Administrator, Region I, USNRC NRC Project Manager, NRR - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - R. E. Ginna Nuclear Power Plant Director, Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Commission August 26, 2014 Page 3 bcc: M. G. Korsnick B. S. Montgomery B. J. Dough C. L. Behrend V. K. Aggarwal D. J. Distel S. Mokkapati J. E. Pacher W. B. Carsky T. L. Harding S. L. Miller C. R. Dedrickson P. M. Amway C. R. Merritt K. A. Picciott G. J. Wrobel J. M. Traynor S. T. Day, Jr.

COMMITMENTS IDENTIFIED IN THIS CORRESPONDENCE:

None Responsible Person/Organization: NA Due Date: NA SAR/TSB Revision Required? No No NIL No.: NA Posting Requirements for Responses -- NOV/Order No

ATTACHMENT (1)

SIX-MONTH STATUS REPORT (AUGUST 2014)

FOR RELIABLE SPENT FUEL POOL INSTRUMENTATION R. E. GINNA NUCLEAR POWER PLANT, LLC August 26, 2014

R. E. Ginna Nuclear Power Plant 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 R. E. Ginna Nuclear Power Plant, LLC (Ginna) 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 3), and are current as of August 1, 2014.

Completed Site Acceptance Testing 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.

Revised Milestone Target Completion Activity Target Date Status Completion Date Submit 60 Day Status Report October 26, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAIs September 23, 2013 Complete Submit 6 Month Updates:

Update 1 August 27, 2013 Complete Update 2 February 24, 2014 Complete Update 3 August 28, 2014 Complete with this submittal

,Provide Final Safety Evaluation September 30, 2014 Started (SE) Information Page 1 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 I

Milestone Modifications:

Commence Engineering and Design

-*1*

Complete Engineering and Design Receipt of SFP Instruments Commence Installation of SFP fI Instruments Close out Project/Plant Turnover I 4 Changes to Compliance Method No changes to the compliance methodology have occurred since the February 2014 status report (Reference 3).

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Ginna 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 As noted in the memorandum from C. A. Hunt (NRC) to M. A. Mitchell (NRC), Summary of the November 26, 2013 Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation (Reference 4), the ISE questions supersede any previous requests for information issued by the staff concerning the spent fuel pool instrumentation. The following table provides a summary of the open items documented in the Draft Safety Evaluation (SE) and the status of each item.

Draft Safety Evaluation Open Items O# Description Status 1 RAI Question: Complete.

(RAI-1, Ref. 5) Please provide (Addressed in Reference 3) additional information describing how the proposed arrangement Page 2 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 of the waveguides and routing of the cabling between the radar horns and the electronics in the Intermediate Floor (Elevation 253 ft. 0 in.)

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.

2 RAI Question: Started.

(RAI-2, Ref. 5) Please provide the analyses verifying the seismic testing of the horn and waveguide assembly and the electronics units, and the analysis of the combined maximum seismic and hydrodynamic forces on the cantilevered portion of the assembly exposed to the potential sloshing effects. Show the SFP instrument design configuration will be maintained during and following the maximum seismic ground motion considered in the design of the SFP structure.

3 RAI Question: Complete.

(RAI-3, Ref. 5) For each of the (Addressed in Reference 3) mounting attachments required to attach SFP Level equipment to Page 3 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 plant structures, please describe the design inputs, and the methodology that will be used to qualify the structural integrity of the affected structures/

equipment.

4 RAI Question: Complete.

(RAI-4, Ref. 5) Please provide analysis (Addressed in Reference 3) of the maximum expected radiological conditions (dose rate and total integrated dose) to which the equipment will be exposed. Also, please provide documentation indicating how it was determined that the electronics for this equipment are capable of withstanding a total integrated dose of lx103 Rads. Please discuss the time period over which the analyzed total integrated dose was applied.

-- I.

5 RAI Question: Started.

(RAI-5, Ref. 5) Please provide information indicating (a) whether the 800 C rating for the sensor electronics is a continuous duty rating; and, (b) the maximum expected ambient temperature in the room in which the sensor electronics will be located under Beyond Design Basis (BDB) conditions with no ac power available to run Heating Ventilation and Air Page 4 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014

-t Conditioning (HVAC) systems.

= -I.

6 RAI Question: Started.

(RAI-6, Ref. 5) Please provide information indicating the maximum expected relative humidity in the room in which the sensor electronics will be located under BDB conditions, with no ac power available to run HVAC systems, and whether the sensor electronics are capable of continuously performing their required functions under this expected humidity condition.

7 RAI Question: Complete.

(RAI-7, Ref. 5) Please provide (Addressed in Reference 3) information describing the evaluation of the comparative sensor design, the shock test method, test results, and forces applied to the sensor applicable to its successful tests, demonstrating the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of severe shock.

8 RAI Question: Complete.

(RAI-8, Ref. 5) Please provide (Addressed in Reference 3) information describing the evaluation of the comparative sensor design, the vibration test method, test results, and the forces and their frequency Page 5 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 ranges and directions applied to the sensor applicable to its successful tests, demonstrating the referenced previous testing provides an appropriate means to demonstrate reliability of the sensor under the effects of high vibration.

9 RAI Question: Complete.

(RAI-9, Ref. 5) Please provide (Addressed in Reference 3) information describing the evaluation of the comparative display panel ratings against postulated plant conditions. Also provide results of the manufacturer's shock and vibration test methods, test results, and the forces and their frequency ranges and directions applied to the display panel associated with its successful tests.

10 RAI Question: Complete.

(RAI-10, Ref. 5) Please provide the (Addressed in Reference 3) results of seismic testing for shock and vibration effects to demonstrate the reliability of the components within the power and control panel under shock and vibration conditions.

11 RAI Question: Complete.

(RAI-11, Ref. 5) Please provide analysis (Addressed in Reference 3) of the seismic testing results and show that the instrument performance reliability, Page 6 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 following exposure to simulated seismic conditions representative of the environment anticipated for the SFP structures at Ginna, has been adequately demonstrated.

12 RAI Question: Complete.

(RAI-12, Ref. 5) Please provide the NRC (Addressed in Reference 3) staff with the final configuration of the power supply source for each channel so the staff may conclude the two channels are independent from a power supply assignment perspective.

+ -

.13 RAI Question: Complete.

(RAI-13, Ref. 5) Please provide the (Addressed in Reference 3) results of the calculation depicting the battery backup duty cycle requirements, demonstrating battery capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.

14 RAI Question: Complete.

(RAI-14, Ref. 5) Please provide the The instrument accuracy at normal and BDB conditions analysis verifying was verified by testing of the actual waveguide proposed instrument configuration during the vendor factory acceptance performance is testing. The vendor factory acceptance test consistent with these demonstrated reliable operation of the SFP level estimated accuracy instrumentation under normal conditions and under normal and BDB various simulated BDB test conditions (e.g. steam values. Please exposure). Normal conditions testing included multi-demonstrate the point checks of accuracy at room temperature and channels will retain humidity using a metal target. BDB conditions were these accuracy simulated by injecting steam and water into the performance values waveguide pipe and checking the indicated values. All Page 7 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 following a loss of results were within the estimated accuracy normal and power and subsequent BDB values. The testing demonstrated the restoration of power. instrumentation met design accuracy and repeatability specifications (Reference 6).

The accuracy performance values were also verified after a loss of power and subsequent restoration of power. FAT and Site Acceptance Testing (SAT)

(Reference 7) verified that on a loss of the normal AC power supply that is expected to occur during an ELAP, power is automatically transferred to a battery backup within each of the primary and backup SFP LI power control panels and accuracy remains satisfactory.

I -

15 RAI Question: Complete.

(RAI-15, Ref. 5) Please describe the NRC Order EA-12-051 (Reference 2), JLD-ISG-2012-03 evaluation used to (Reference 8), and NEI 12-02 guidance (Reference 9) do validate that the not explicitly require a formal evaluation to determine the display locations can required time for personnel to access the SFP level be accessed without display. NEI 12-02 Section 3.1 allows reliance on unreasonable delay portable SFP level instrumentation for the back-up following a BDB event. channel, provided two trained personnel can deploy the Include the time instrument within 30 minutes. Personnel access to the available for personnel Ginna primary and back-up SFP level channels can to access the display readily be achieved within this timeframe during a location as credited in postulated BDB/ELAP event. Depending on the specific the evaluation, as well BDB event, personnel will be dispatched to the SFP level as the actual time (e.g., display location in the Standby Auxiliary Feedwater based on walk-through) Building (SAFWB) to establish Standby Auxiliary that it will take for Feedwater Flow to the Steam Generators within 25 personnel to access minutes of the initiating event. Once the priority of the display locations. establishing core cooling is achieved, personnel can Additionally, please then monitor SFP level on an intermittent basis to include a description of provide SFP level indication information to the Control the radiological and Room Operators.

environmental conditions on the paths As discussed in the Maintain SFP Cooling strategy in the personnel might take. Ginna Overall Integrated Plan for Mitigation Strategies Describe whether the for Beyond-Design-Basis External Events (Reference display locations 10), in the most limiting circumstances, SFP boiling does remain habitable for not occur for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. There is significant margin to radiological, heat and determine SFP level before it is be necessary to take humidity, and other mitigating actions.

environmental conditions following a An access pathway to the SAFWB (among multiple BDB event. Describe available pathways) is expected to remain available whether personnel are following a seismic or tornado missile event. In slowly continuously stationed developing BDB events, personnel can be pre-staged at at the display locations the SFP level display location. SFP level display access or monitor the displavs times are based on enaineerina/oDerations iudament.

Page 8 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 periodically. The timeline will be validated for compliance with Order EA-12-049 (Reference 11) after the Standby Auxiliary Feedwater Building modification is completed.

During a postulated BDB event, only periodic personnel monitoring of SFP level is required. The SAFWB environment is not affected by the environmental conditions associated with any SFP drain down scenario.

Radio communications between personnel at the SFP level display and the Control Room will used to keep Operations informed of SFP level.

SFP level indication is considered to be readily accessible during an ELAP as defined by NEI 12-02 based on the following considerations:

a) The travel path to the SFP level displays from the Control Room is via the Turbine Building Operating or Intermediate floors, through the Turbine Building or Technical Support Center, and then outside to the SAFWB. The travel path is not exposed to potentially adverse SFP area conditions. Radiological or environmental conditions through the travel path will be consistent with operating conditions for maximum temperature and humidity, or be subject to expected low temperature conditions. Travel path and SFP level display area dose-rates are not anticipated to increase during the event. In the case of BDB floods, pre-staging personnel in the SAFWB will negate any travel path issues.

b) Design criteria for the new SAFWB will ensure that the area remains habitable for heat and humidity conditions followina a BDB event.

16 RAI Question: Complete.

(RAI-16, Ref. 5) Please provide a list of A complete list of the procedures addressing operation the procedures (both normal and abnormal response), calibration, test, addressing operation maintenance, and inspection that will be developed for (both normal and use of the spent SFP instrumentation has not been abnormal response), finalized yet. The following procedures have been calibration, test, revised, developed, or will be developed in support of the maintenance, and SFP LI system:

inspection that will be a) 0-6.1, Auxiliary Operator Rounds and Log developed for use of Sheets (Reference 12) the SFP Provides on-shift operators and, in particular, instrumentation. The Auxiliary Operators, the controls necessary to licensee is requested perform rounds and report abnormal/unusual to include a brief conditions to ensure that the plant operates description of the safely and efficiently for all modes.

sDecific technical b) ER-SFP.2. Diverse SFP MakeuD and SDrav Page 9 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 objectives to be (Reference 13) achieved within each > Provides the internal and external strategy for procedure. establishing a diverse means of SFP makeup for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without offsite supplies and provides a list of materials available for leak mitigation.

c) FSG-1 1, Alternate SFP Makeup and Cooling (TBD)

> Provides actions to restore SFP level using an alternate makeup source.

d) CPI-LVL-310, Calibration of SFP Level Northeast Channel Loop LT-310 (Reference 14)

>. Provides instructions for Calibration check of Spent Fuel Pool Level Channel LT-310 Instrumentation.

e) CPI-LVL-31 1, Calibration of SFP Level Northeast Channel Loop LT-311 (Reference 15)

• Provides instructions for Calibration check of Spent Fuel Pool Level Channel LT-311 Instrumentation.

f) TBD

> Describes compensatorv actions when both channels are out of service and expedited and compensatory actions when one of the instrument channels cannot be restored to functional status within 90 days.

17 RAI Question: Complete.

(RAI-17, Ref. 5) Please provide the a. Programmatic controls will be established to ensure following: the performance of periodic performance checks of

a. Further information the SFP level transmitters and indications, calibration describing the of loop power supplies and current maintenance and repeaters/isolators, and verification of computer testing program the response. Procedures CPI-LVL-31 0 and CPI-LVL-licensee will 311 provide the instructions for calibration checks of establish and SFP Level Instrumentation Channels LT-310 and LT-implement to 311 respectively. Procedure 0-6.1 directs the ensure that regular Outside Operator to log LI-310 and LI-31 1 SFP Wide testing and Range Levels once per twelve hour shift. Minimum calibration is and Maximum SFP Level values are identified for performed and operator action in 0-6.1. The Plant Process verified by Computer System has alarms to notify Control Room inspection and audit Operators when levels indicate off-normal values.

to demonstrate conformance with The maintenance, testing and calibration program design and system has been established, or will be established, that readiness contains the elements listed below:

requirements. > Calibration procedures that are based on the Please include a vendor provided instruction manuals and description of the calibration procedures for the equipment.

Page 10 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 plans for ensuring >, Verification that instrument readings are within that necessary the allowable tolerance band or that actions are channel checks, taken to address the out of tolerance condition.

functional tests, > Calibration to validate the functionality of the periodic calibration, installed instrument channels within 60 days of a and maintenance planned refueling outage considering normal will be conducted testing and scheduling allowances (e.g. 25%).

for the level > Existing work control processes will be utilized to measurement perform testing and maintenance on the system and its instrument channels.

supporting > Allowable channel out of service times and equipment. associated actions will be consistent with the

b. Information guidance provided in NEI 12-02.

describing compensatory It should be noted that based on the negligible drift actions when both rate of VEGA electronics experienced over a large channels are out-of- user base, periodic calibration is not needed.

order, and the Functional verification can be achieved using cross implementation channel checks and functional checks per vendor procedures. manual.

c. Additional information b. NEI 12-02, Section 4.3 states "The primary or back-describing up instrumentchannel can be out of service for expedited and testing, maintenance and/or calibrationfor up to 90 compensatory days provided the other channel is functional actions in the Additionally, compensatoryactions must be taken if maintenance the instrumentation channel is not expected to be procedure to restoredor is not restored within 90 days. If both address a condition channels become nonfunctioning then initiate actions when one of the within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the channels of instrument instrumentation and implement compensatory actions channels cannot be (e.g., use of alternatesuitable equipment or restored to supplementalpersonnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />."

functional status within 90 days. SFP level instrument may be taken out of service for testing, maintenance and/or calibration for short durations, consistent with current maintenance practices. Upon discovery of a non-functioning SFP level instrument, the issue will be place in the Corrective Action program. Attempts will be made to restore the non-functioning SFP level instrument to service as soon as possible and within 90 days. No compensatory actions will be taken while the one channel is non-functioning as long as the remaining instrument channel is available. Ifthe non-functional channel cannot be restored within 90 days, compensatory actions will include enhanced monitoring of the existing SFP level instrumentation and increased direct visual monitoring of SFP level.

The determination of time frames for enhanced Page 11 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014 monitoring will be defined as the procedure development is finalized.

If both instrument channels are determined to be out-of-order, actions will be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one of the instrument channels to full functionality within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or compensatory actions will be implemented with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Compensatory actions will consider alternate means of monitoring SFP level, such as video cameras or supplemental shift staffing; and may consider decay heat loads in the SFP.

'1~

c. See response to b.

18 RAI Question: Complete.

(RAI-18, Ref. 5) Please provide a The in-situ calibration process at the SFP description of the in- location utilizes the capability to rotate the situ calibration process waveguide horn assembly from its normal at the SFP location that downward-pointing position so that it can be will result in the pointed at a target that is moved along the channel calibration radar beam path. By placing the moveable being maintained at its target at known distances from the horn, the design accuracy. instrument output can be checked at each target location. In the event that the as-found values are not within acceptance criteria, the measurement range can be shifted up or down to calibrate the instrument to within the required tolerance. (Reference 16)

It should be noted that based on negligible drift rate of VEGA electronics experienced over large user base, periodic calibration is not needed. Functional verification can be achieved using cross channel checks and functional checks per vendor manual.

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. Constellation Energy Nuclear Generation, LLC, letter to USNRC, "Supplement to Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation," dated March 8, 2013 (FLL-13-14)

Page 12 of 13

R. E. Ginna Nuclear Power Plant Third Six-Month Status Report for the Implementation of SFP LI August 28, 2014

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. Constellation Energy Nuclear Generation, LLC, letter to USNRC, "February 2014 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 051)," dated February 24, 2014 (FLL-14-003)

4. Memorandum from C. A. Hunt (USNRC) to M. A. Mitchell (USNRC), "Summary of the November 26, 2013 Public Meeting to Discuss Industry Responses to Staff Interim Evaluations for Spent Fuel Pool Instrumentation," dated December 26, 2013

5. USNRC letter to Constellation Energy Nuclear Generation, LLC, "Constellation Energy Nuclear Group, R.E. Ginna Nuclear Power Plant, 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. MF1 147)," dated December 5, 2013

6. AREVA Document No. 66-9218244, "Through Air Radar Spent Fuel Pool Level Indication (SFPLI) Instrument Factory Acceptance Test (FAT) Report for R.E. Ginna," Revision 000

7. AREVA Document No. 66-9221608, "Through Air Radar Spent Fuel Pool Level Instrument (SFPLI) Site Acceptance Test (SAT) Report for R.E. Ginna," Revision 001

8. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-1 2-051, Reliable Spent Fuel Pool Instrumentation," Revision 0

9. Nuclear Energy Institute 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

10. Constellation Energy Nuclear Generation, LLC, letter to USNRC, "Supplement to Overall Integrated Plan for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 8, 2013 (FLL-12-15)

11. NRC Order Number EA-1 2-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

12. 0-6.1, "Auxiliary Operator Rounds and Log Sheets," Revision 05300

13. ER-SFP.2, "Diverse SFP Makeup and Spray," Revision 00300

14. CPI-LVL-310, "Calibration of SFP Level Northeast Channel Loop LT-310," Revision 00000

15. CPI-LVL-31 1, "Calibration of SFP Level Northeast Channel Loop LT-31 1," Revision 00000

16. AREVA Document No. 01-9213759, "Through Air Radar Spent Fuel Pool Level Instrument (SFPLI) Instruction Manual for R.E. Ginna," Revision 002 Page 13 of 13