RS-14-026, 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)
| ML14059A228 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/28/2014 |
| From: | David Helker Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-051, RS-14-026, TAC MF0866, TMI-14-007 | |
| Download: ML14059A228 (19) | |
Text
Order No. EA-12-051 RS-14-026 TMI-14-007 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
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)
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-13-036)
- 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-13-130)
- 7. NRC letter to Exelon Generation Company, LLC, Three Mile Island Nuclear Station, Unit 1 - 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. MF0866), dated November 13, 2013
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page 2 On March 1 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGG). Reference 1 was immediately effective and directs 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 Three Mile Island Nuclear Station, Unit 1 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. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Three Mile Island Nuclear Station, Unit 1. The purpose of this letter is to provide the second 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 7.
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 th day of February 2014.
Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Enclosure:
- 1. Three Mile Island Nuclear Station, Unit 1 Second 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 February 28, 2014 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR Three Mile Island Nuclear Station, Unit 1 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. Greg A. Casto, NRR/DSS/SBPB, NRC Mr. John D. Hughey, NRR/DORULPL3-2, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection
Enclosure Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (15 pages)
Three Mile Island Nuclear Station, Unit 1 Second Six*Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction Three Mile Island Nuclear Station, Unit 1, developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPU), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the First 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 First six month status report (Reference 6), and are current as of February 8,2014.
- Begin detailed design engineering of the SFPU for Three Mile Island Nuclear Station 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.
Revised Target Activity Target Milestone Completion Date Status Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Responses to RAls July 24, 2013 Complete Submit 6 Month Updates:
Update 1 August 28,2013 Complete Complete with Update 2 February 28, 2014 this submittal Update 3 August28,2014 Not Started Update 4 February 28, 2015 Not Started Page 1 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 Revised Target Activity Target Milestone Completion Date Status Completion Date Provide Final Safety Evaluation (SE)
March 31,2015 Not Started Info Update 5 August 28,2015 Not Started Modifications:
Conceptual Design 3Q2012 Complete Issue Exelon Fleet contract to 2Q2013 Complete procure SFPI Equipment Begin Detailed Design 2Q2014 Complete 4Q2013 Engineering Complete and Issue SFPI 2Q2014 Not Started 4Q2014 Modification Package Begin Installation 3Q2015 Not Started 2Q2015 Complete SFPI Installation and 4Q2015 Not Started 2Q2015 Put Into Service 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 Three Mile Island Nuclear Station, Unit 1 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 or the Interim Safety Evaluation (ISE) and the status of each item.
Overall Integrated Plan Open Items 01# Description Status 1 RAI Question: Started.
(RAI-1 a, For Level 1, specify how the identified Note that the start date for detailed Page 2 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 RetA) location represents the HIGHER of the design has changed from October to two points described in the NE112-02 November 2013 and completion date for guidance for this level.
design has changed from May 2014 to November 2014. As a result, the date to
RESPONSE
provide the requested information has The detailed design will include a changed from August 2014 to February calculation to determine adequate water 201 level to maintain normal fuel pool cooling system operation. This information will be available following acceptance of the 100% design, scheduled for November, 2014. The result will be provided in the February 2015, 6-month Integrated Plan update report to the NRC.
2 Open Item: Complete Continuous level indication will be (Addressed in Reference 6) 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.
3 RAI Question: Complete (RAI-1 b, A clearly labeled sketch depicting the (Addressed in Reference 4) elevation view of the proposed typical I Ref. 4) 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 racks. 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, Level2, and Level3 datum pOints.
4 RAI Question: Started.
(RAI-2, Please provide a clearly labeled sketch Note that the start date for detailed Ref A) or marked-up plant drawing of the plan design has changed from October to view of the SFP area, depicting the November 2013 and completion date for SFP inside dimensions, the planned locations/placement of the primary and design has changed from May 2014 to backup SFP level sensor, and the November 2014. As a result, the date to proposed routing of the cables that provide the requested information has will extend from the sensors toward changed from August 2014 to February Page 3 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 the location of the readout/display 2015.
device.
RESPONSE
final locations and cable routings are not available at this time. A detailed design will include sensor locations and cable routing drawings from the Spent Fuel Pool to each channel indicator.
The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100% acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
5 RAI Question: Started.
(RAI-3, Please provide the following: Note that the start date for detailed Ref A) a) The design criteria that will be design has changed from October to used to estimate the total loading on November 2013 and completion date for the mounting device(s), including design has changed from May 2014 to static weight loads and dynamic November 2014. As a result, the date to loads. Describe the methodology that will be used to estimate the total provide the requested information has loading, inclusive of design-basis changed from August 2014 to February maximum seismic loads and the 2015.
hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly. Indicate in a schematic, the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.
c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to Page 4 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 support the level sensor assembly.
RESPONSE
Device total loading and mounting will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100%
acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
6 RAI Question: Started.
(RAI-4, Please provide the following: Note that the start date for detailed Ref A) a) A description of the specific design has changed from October to method or combination of methods November 2013 and completion date for that will be applied to demonstrate design has changed from May 2014 to the reliability of the permanently November 2014. As a result, the date to installed equipment under BOB ambient temperature, humidity, provide the requested information has shock, vibration, and radiation changed from August 2014 to February conditions. 2015.
b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted.
Include a discussion of this seismic reliability demonstration as it applies to (i) the level sensor mounted in the SFP area, and (ii) any control boxes, electronics, or readout and retransmitting 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 Page 5 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 instrument will maintain its required accuracy.
RESPQNSE:
Device qualification and reliability will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100%
acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
7 RAI Question: Started.
(RAI-5, Please provide the following: Note that the start date for detailed RetA) a) A description of how the two design has changed from October to channels of the proposed level November 2013 and completion date for measurement system meet this design has changed from May 2014 to requirement so that the potential for November 2014. As a result, the date to a common cause event to adversely affect both channels is provide the requested information has minimized to the extent practicable. changed from August 2014 to February b) Further information on how each 2015.
level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.
RESPONSE
Device channel independence evaluation will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and Page 6 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 100% acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
8 RAI Question: Replaced by Interim SE RAI #10 (RAI-6, Please provide the following: Note that the start date for detailed Ref.4) a} A description of the electrical ac design has changed from October to power sources and capabilities for the November 2013 and completion date for primary and backup channels.
design has changed from May 2014 to b) If the level measurement channels November 2014. As a result, the date to are to be powered through a battery provide the requested information has system (either directly or through an changed from August 2014 to February Uninterruptible Power Supply (UPS>>,
2015.
please provide the design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BOB event for the minimum duration needed, consistent with the plant mitigation strategies for BOB external events (Order EA*12*
049).
RESPONSE
Device total power supply configuration will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100%
acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
9 RAI Question: Started.
(RAI-7, Please provide the following: Note that the start date for detailed Ref.4) a) An estimate of the expected design has changed from October to instrument channel accuracy November 2013 and completion date for performance under both (i) normal SFP level conditions design has changed from May 2014 to (approximately Levell or higher) and November 2014. As a result, the date to (ii) at the BOB conditions (i.e., provide the requested information has Page 7 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation ot SFP LI February 28,2014 radiation, temperature, humidity, post- changed from August 2014 to February seismic and postshock conditions) 2015.
that would be present if the SFP level were at the Level 2 and Level 3 datum pOints.
b) A description of the methodology that will be used for determining the maximum allowed deviation from the instrument channel design accuracy that will be employed under normal operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RESPONSE
Device channel accuracy analysis will be performed as part of the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100%
acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
10 RAI Question: Started.
(RAI-8, Please provide the following: Note that the start date for detailed RetA) a) A description of the capability and design has changed from October to provisions the proposed level November 2013 and completion date for sensing equipment will have to design has changed from May 2014 to enable periodic testing and November 2014. However, the requested calibration, including how this capability enables the equipment to information for this RAI will be provided be tested in-situ. in February 2015 per the original date.
b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.
c) A description of how functional checks will be performed, and the frequency at which they will be Page 8 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 conducted. Describe how calibration tests will be performed, and the frequency at which they will be conducted. Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program.
d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed.
RESPONSE
Device testing requirement analysis will be performed as part of the process and procedure development following the design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November 2013 with design completion and 100%
acceptance of the design in November 2014. Following the issue of the design, procedures will start being developed. The requested information will be developed early in the process and will be provided in the February 2015, 6-month Integrated Plan update.
11 RAI Question: Started.
(RAI-9, Please provide the following: Note that the start date for detailed Ref.4) a) The specific location for each of design has changed from October to the primary and backup instrument November 2013 and completion date for channel displays. design has changed from May 2014 to b) If the primary and backup display November 2014. As a result, the date to location is other than the main provide the requested information has control room, provide justification for changed from August 2014 to February prompt accessibility to displays 2015.
including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible Page 9 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 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." Include consideration of various drain-down scenarios.
RESPONSE
Device channel display location will be finalized during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November of 2013 with design completion and 100%
acceptance of the design in November 2014. The requested information will be provided in the February 2015, 6-month Integrated Plan update.
12 RAI Question: Started.
(RAI-10, Please provide the following: Note that the start date for detailed Ref A) design has changed from October to a) A list of the operating (both normal November 2013 and completion date for and abnormal response) procedures, design has changed from May 2014 to calibration/test procedures, November 2014. However, the requested maintenance procedures, and information for this RAI will be provided inspection procedures that will be in February 2015 per the original date.
developed for use of the SFP instrumentation in a manner that addresses the order requirements.
b) A brief description of the specific technical objectives to be achieved within each procedure. If your plan incorporates the use of portable spent fuel level monitoring components, please include a description of the objectives to be achieved with regard to the storage location and provisions for installation of the portable Page 10 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28. 2014 components when needed.
RESPONSE
Device program features analysis will be performed as part of the detailed design process following the design I phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November 2013 with design completion and 100%
acceptance of the design in November 2014. Following the issue of the design, procedures will start being developed. The requested information will be developed early in the process and will be provided in the February 2015, 6-month Integrated Plan update.
13 RAI Question: Started.
(RAI-11, Please provide the following: Note that the start date for detailed Ref.4) a) Further information describing the design has changed from October to maintenance and testing program November 2013 and completion date for the licensee will establish and design has changed from May 2014 to implement to ensure that regular November 2014. However, the requested testing and calibration is performed and verified by inspection information for this RAI will be provided and audit to demonstrate in February 2015 per the original date.
conformance with design and system readiness requirements.
Please include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.
b) A description of how the guidance in 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.
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Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 RESPQNSE:
Device testing and calibration requirements analysis will be performed as part of the detailed design process following the design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for TMI-1 is to begin the design phase in November 2013 with design completion and 100%
acceptance of the design in November 2014. Following the issue of the design, procedures will start being developed. The requested information will be developed early in the process and will be provided in the February 2015, 6-month Integrated Plan update.
Interim Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete.
(RAI-2, Please describe the impact of the installation of Complete redundant monitoring Ref. 5) the gate on the reliability of the SFP level of the pools will not be available instrumentation for each SFP, and what when the gate is installed. The compensatory measures would be taken to gate is normally not installed ensure reliable level indication in each SFP when during any expected plant the gate is installed.
modes of operation. There is an existing procedure 1507-2 to remove and install the gate. To address the concern related to the unexpected plant modes of operation when the gate may be installed, the procedure 1507-2 will be revised to:
- Note that installation of the gate affects the redundancy of the Reliable Spent Fuel Pool Instrumentation .
- If the gate has to be installed, the procedure will establish administrative Page 12 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 guidance/controls to follow to support the gO-day out of service rule of NEI 12-02 Revision 1, Section 4.3.
2 RAI Question: Not Started (RAI-5, For RAI 4{a) above, please provide the results Ref. 5) of the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including, design-basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
3 RAI Question: Not Started (RAI-6, For each of the mounting attachments required Ref. 5) to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equ ipment.
4 RAI Question: Not Started (RAI-8, For RAJ 7 above, please provide the results from Ref. 5) the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
5 RAI Question: Not Started (RAI-10, Please provide the following:
Ref. 5) a} A description of the electrical ac power sources and capabilities for the primary and backup channels.
b) Please provide the results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.
6 RAI Question: Not Started (RAI-13, Please provide the following:
Ref. 5) a) The specific location for each of the primary and backup instrument channel displays.
b) For any SFP level instrumentation displays located outside the main control room, please describe the evaluation used to validate that the display location can be accessed Page 13 of 15
Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 without unreasonable delay following a BOB event. Include the time available for personnel to I!
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 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.
7 RAI Question: Not Started (RAI-14, Please provide a list of the procedures Ref. 5) addressing operation (both normal and abnormal response), calibration, test, maintenance, and inspection procedures that will be developed for use of the SFP instrumentation.
The licensee is requested to include a brief description of the specific technical objectives to be achieved within each procedure.
Note: RAls not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAls in Reference 3 and are listed in the Overall Integrated Plan Open Item Table.
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, letter to USNRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February 28, 2013 (RS 036)
- 2. NRC Order Number EA-12-051, "Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012.
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Three Mile Island Nuclear Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014
- 3. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 26, 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 24,2013 (RS-13-182, TMI-13-095).
- 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 13, 2013.
- 6. First Six-Month Status Report for Implementation of the Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 28,2013 (RS-13-130).
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