RA-15-066, 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)

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)

ML15243A094
Person / Time
Site:	Oyster Creek
Issue date:	08/28/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RA-15-066, RS-15-203
Download: ML15243A094 (22)

Text

Exelon Generation Order No. EA-12-051 RS-15-203 RA-15-066 August28,2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

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)

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 August2012

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-13-033)

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-13-124)

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 023)

8. 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-14-201)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August28,2015 Page 2

9. 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-15-031)

10. NRC letter to Exelon Generation Company, LLC, Oyster Creek Nuclear Generating Station - 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 No. MF0823), dated November 8, 2013 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 Oyster Creek Nuclear Generating Station 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, 7, 8, and 9 provided the first, second, third, and fourth six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Oyster Creek Nuclear Generating Station. The purpose of this letter is to provide the fifth 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 10.

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 1h day of August 2015.

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

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2015 Page 3

Enclosure:

1. Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation cc: Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region I NRG Senior Resident Inspector- Oyster Creek Nuclear Generating Station NRG Project Manager, NRR - Oyster Creek Nuclear Generating Station Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRG Mr. Stephen R. Monarque, NRR/JLD/JPMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRG Mr. John G. Lamb, NRR/DORULPL3-2, NRG Mr. John D. Hughey, NRR/JLD/JOMB, NRC Manager, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Enclosure Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (18 pages)

Oyster Creek Nuclear Generating Station Fifth 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 Oyster Creek Nuclear Generating Station 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 Fourth 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 milestone has been completed since the development of the Fourth six month status report (Reference 9), and is current as of August 28, 2015.

• Begin Detailed Design Engineering 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 Completion Activity Target Milestone Date Status Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit 6 Month Updates:

Update 1 August28, 2013 Complete Update 2 February 28, 2014 Complete Update 3 August28,2014 Complete Update 4 February 27, 2015 Complete Complete with Update 5 August 28, 2015 this submittal Update 6 February 28, 2016 Not Started Page 1 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 Revised Target Completion Activity Target Milestone Date Status Completion Date Update 7 August 28, 2016 Not Started Provide Final Safety Evaluation April 30, 2016 Not Started (SE) Info Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Design 102015 Started Engineering Complete and Issue SFPI 302015 Not Started Modification Package Begin Installation 202016 Not Started Complete SFPI Installation and 302016 Not Started 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 Oyster Creek Nuclear Generating Station 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 Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete Continuous level indication will (Addressed in Reference 6)

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Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 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 Question: Started (RAl-1, Please provide a clearly labeled The required sketch is not available at this Ref. 4) sketch depicting the elevation time. This information will be developed during view of the proposed typical the detailed design process. The SFPI system mounting arrangement for the design completion and 100% acceptance of the design is scheduled for September 2015. The portions of instrument channel requested information will be provided in the consisting of permanent February 2016, 6-month Integrated Plan update.

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 Level1,Level2,andLevel3 datum points.

3 RAI Question: Started (RAl-2, Please provide a clearly labeled The required sketch is not available at this Ref.4) sketch or marked-up plant time. This information will be developed during drawing of the plan view of the detailed design process. The SFPI system the SFP area, depicting the SFP design completion and 100% acceptance of the inside dimensions, the planned design is scheduled for September 2015. The locations/placement of requested detail will be provided in the February the primary and backup SFP level 2016, 6-month Integrated Plan update.

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: Started (RAl-3, Please provide the following: a) Calculation CN-PEUS-15-08 prepared by a) The design criteria that will be Westinghouse provides the design criteria for Page 3 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 Ref.4) used to estimate the total loading the loading on the mounting device(s), including on the mounting static weight loads and dynamic loads.

device(s), including static weight loads and dynamic loads. The design basis maximum seismic loads were Describe the methodology that based on the Bounding Curve and Bounding will be used to estimate the total Tables provided in "Spent Fuel Pool Level loading, inclusive of design basis Instrumentation Procurement Specification",

maximum seismic loads and the 2013-BYR001.

hydrodynamic loads that could The hydrodynamic loads that could result from result from pool sloshing or other pool sloshing that could accompany such effects that could accompany seismic forces were calculated using "United such seismic forces.

States Atomic Energy Commission, "Nuclear b) A description of the manner in which the level sensor (and Reactors and Earthquakes", TID-7024, August stilling well, if appropriate) will be 1963, Chapter 6, "Dynamic Pressure on Fluid attached to the refueling floor Containers". This is an acceptable method per and/or other support structures CC-AA-320-1001, Design Guide for the for each planned point of Dynamic Qualification of Equipment.

attachment of the probe Response for b, c:

assembly. Indicate in a schematic the portions of the level sensor The level sensors will be attached to steel that will serve as points of brackets mounted on the refueling floor via attachment for concrete anchors. Drawing 10067E58 prepared mechanical/mounting or by Westinghouse shows the electrical connections. connection/mounting details.

c) A description of the manner NOTE: The Calculation CN-PEUS-15-08 and by which the mechanical Drawing 10067E58 preparation is in progress.

connections will attach the level These documents will be finalized at design instrument to permanent SFP completion and 100% acceptance of the design structures so as to support the in September 2015. The requested detail will be level sensor assembly.

provided in the February 2016, 6-month Integrated Plan update.

5 RAI Question: Started (RAl-4, Please provide the following: This information will be developed during the Ref.4) a) A description of the specific detailed design process. The SFPI system method or combination of design completion and 100% acceptance of the methods that will be applied to design is scheduled for September 2015. The demonstrate the reliability of requested detail will be provided in the February the permanently installed 2016, 6-month Integrated Plan update.

equipment under beyond-design-basis (BOB) ambient temperature, humidity, shock, vibration, and radiation conditions.

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 Page 4 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 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 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.

6 RAI Question: Complete (RAl-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 that:

channels of the proposed level measurement system meet this requirement so that the potential a) The level probes will be mounted on the south for a common cause event to side of the SFP and will be separated by a adversely affect both channels is distance greater than the span of the shortest minimized to the extent side of the pool. This meets the NEI 12-02, practicable. Revision 1 guidance for channel separation.

b) Further information on how each level measurement system, b) One level transmitter for the primary and one consisting of level sensor for the backup instrument channels will be electronics, cabling, and readout installed in each Cable Tray Bridge on elevation devices will be designed and 80'. The electronics I UPS enclosure for the installed to address primary and backup instrument channels will be independence through the installed in the Upper Cable Spreading Room application and selection of elevation 68' -6" with a physical separation of 8'.

independent power sources, the Physical and spatial separation of the primary use of physical and spatial and backup instrument channels is maintained separation, independence of by routing the associated instrument channel signals sent to the location(s) of cables in separate raceways with a minimum the readout devices, and the separation of 1 feet. This meets the separation independence of the displays.

requirements for the installed location per OCGS Specification SP-9000-41-005, Cables &

Raceways. The 120 VAC power to the primary instrument will be provided from safetv related Page 5 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28 2015 Post Accident Instrument Power Panel PDP-733-057. The 120VAC power to the backup level instrument will be provided from safety related Post Accident Instrument Power Panel PDP-733-058. 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: Replaced by Interim SE RAI -9.

(RAl-6, Please provide the following:

Ref.4) a) A description of the normal electrical AC power sources and capacities for the primary and backup channels. Describe how these AC sources are independent, and how they may be restored following an extended loss of AC event. b) If the level measurement channels are to be powered through a battery system (either directly or through an Uninterruptible Power Supply (UPS)), 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 049).

8 RAI Question: Complete (RAl-7, Please provide the following:

a) The Westinghouse documents WNA-CN-Ref.4) a) An estimate of the expected 00301 and WNA-DS-02957-GEN describe the instrument channel accuracy channel accuracy under both (a) normal SFP performance under both (i) level condition and (b) at the Beyond Design normal SFP level conditions Basis (BOB) condition that would be present if (approximately Level 1 or SFP level were at Level 2 and Level 3 datum higher) and (ii) at the BOB points. Each instrument channel will be accurate conditions (i.e., radiation, to within +/-3" during normal spent fuel pool level temperature, humidity, post-conditions. The instrument channels will retain seismic and post-shock this accuracy after BOB conditions, in conditions) that would be accordance with the above Westinghouse Page 6 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August 28, 2015 present if the SFP level were at documents. This value is within the channel the Level 2 and Level 3 datum accuracy requirements of the Order (+/-1 foot).

points.

b) A description of the b) The Westinghouse document WNA-TP-methodology that will be used 04709-GEN describes the methodology for for determining the maximum routine testing/calibration verification and allowed deviation from the calibration methodology. This document also instrument channel design specifies the required accuracy criteria under accuracy that will be employed normal operating conditions. Oyster Creek under normal operating Station calibration and channel verification conditions as an acceptance procedures will follow the guidance and criteria criterion for a calibration provided in this document. Instrument channel procedure to flag to operators calibration will be performed if the level and to technicians that the indication reflects a value that is outside the channel requires adjustment to acceptance band established in the Oyster within the normal condition Creek Station calibration and channel design accuracy. verification procedures. Calibration will be performed once per refueling cycle for Oyster Creek 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.

9 RAI Question: Started (RAl-8, Please provide the following: a) During the detailed design phase, Ref.4) a) A description of the Westinghouse will provide the calibration capability and provisions the procedure and functional test procedure proposed level sensing describing the capabilities and provisions of equipment will have to enable SFPI periodic testing and calibration, including periodic testing and calibration, in-situ testing. Oyster Creek Station will including how this capability review the procedures to ensure that the enables the equipment to be instrument can be calibrated, functionally tested in-situ. tested, and in-situ tested per the Order b) A description of how such requirements.

testing and calibration will enable the conduct of b) The level displayed by the channels will be regular channel checks of each verified per the Oyster Creek Station independent channel against administrative and operating procedures. If the other, and against any other the level is not within the required accuracy permanently-installed SFP level per Westinghouse recommended tolerances, instrumentation. channel calibration will be performed.

c) A description of how functional checks will be c) Functional checks will be performed per a performed, and the frequency at future Westinghouse functionality test which they will be conducted. procedure at the Westinghouse Describe how calibration tests recommended frequency. Calibration tests will be performed, and the will be performed per a future Westinqhouse Page 7of18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28 2015 frequency at which they will be calibration procedure at the Westinghouse conducted. Provide a recommended frequency. In accordance with discussion as to how these Oyster Creek Station maintenance and_ .

surveillances will be operating programs, Oyster Creek Station will incorporated into the plant develop calibration, functional test, and surveillance program. channel verification procedures per d) A description of what Westinghouse recommendations to ensure preventive maintenance tasks reliable accurate and continuous SFPI are required to be performed functio~ality. Periodic surveillance te_sting of the new components installed per this ECR during normal operation, and will be determined by the cognizant system the planned maximum manager per CC-AA-102, Attachment 1OB.

surveillance interval that is necessary to ensure that the channels are fully conditioned d) Oyster Creek Station will develop preventive to accurately and reliably maintenance tasks for the SFPI per future perform their functions when Westinghouse recommendations to assure needed. that the channels are fully conditioned to accurately and reliably perform their functions when needed.

The planned completion for this item is November 2016.

10 RAI Question: Complete (RAl-9, Please provide the following:

a) The Oyster Creek Station primary and b~ckup Ref.4) a) The specific location for the instrument channel displays are located in the primary and backup instrument Upper Cable Spreading Room.

channel displays.

b) If the primary and backup Response for b) and c):

displays are not located in the main control room, please The Oyster Creek Station primary and backup provide a description of the instrument channel displays are located on a selected location(s) for the floor above the control room accessible through primary and backup displays, a nearby stairwell. This location was selected including prompt accessibility due to the proximity to the main control room.

to displays, primary and Radiological habitability, humidity, and alternate route evaluation, temperature at this location are considered habitability at display habitable in Oyster Creek Station's Engineering location(s), continual resource Standard ES-027, "Environmental Parameters availability for personnel Oyster Creek NGS" and Calculation C-1302-responsible to promptly read 822-5360-008, Rev 2, "Reactor Bldg Loss of displays, and provisions for Ventilation"; therefore, these locations are not communications with decision considered a harsh environment. Estimated makers for the various SFP radiological conditions inside the Upper.Cable drain down scenarios and Spreading Room for a core melt scenario, as external events.

well as estimated dose rates from SFP c) The reasons justifying why draindown conditions to Level 3 (Calculation the locations selected will BYR13-187), and exposure to personnel enable the information from monitoring SFP levels, will remain less than these instruments to be emeroency exposure limits allowable for Page 8of18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 considered "promptly emergency responders to perform this action.

accessible". Include Heat and humidity from SFP boildown conditions consideration of various drain- have been evaluated for this location. The down scenarios location is several elevations below the SFP operating floor and located in a different building physically separated by concrete walls 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 2 minutes based on walkdowns. Radiological habitability, humidity, and temperature for the transit routes were considered habitable in Oyster Creek Station's Engineering Standard ES-027, "Environmental Parameters Oyster Creek NGS" and Calculation C-1302-822-5360-008, Rev 2, "Reactor Bldg Loss of Ventilation"; therefore, these locations are not considered a harsh environment to personnel monitoring the indications. The SFP levels will 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 concrete walls 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 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. A sound powered phone jack is located in the Control Room; however, a sound powered phone jack is not located in the Upper Cable Spreading Room. The sound powered phone will be available to dispatch personnel for the monitoring of the indicators.

The display will be accessed on demand. It takes up to 2 minutes to reach the disolav Page 9 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 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 Upper Cable Spreading Room.

11 RAI Question: Replaced by Interim SE RAI -13.

(RAI- Please provide the following:

10, a) A list of the operating (both Ref.4) normal and abnormal response) procedures, calibration/test procedures, maintenance procedures, and inspection procedures that will be 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 components when needed.

c) Describe how the replacement of an instrument channel component with a commercially available one that may not meet all of the qualifications noted in the OIP submittal would still be considered to be in compliance with the Order requirements.

Which qualification provisions described in the OIP would not be followed?

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Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28 2015 12 RAI Question: Complete (RAI- Please provide the following: Response for a:

11, a) Further information Performance tests (functional checks) and Ref.4) describing the maintenance and Operator performance checks will be testing program the licensee described in detail in the vendor operator's will establish and implement to manual, and the applicable information is ensure that regular testing and planned to be contained in plant operating calibration is performed and procedures. Operator performance tests are verified by inspection and audit planned to be performed periodically as to demonstrate conformance recommended by the equipment vendor.

with design and system Channel functional tests per Operations readiness requirements. Please Procedures, with limits established in include a description of your consideration of vendor equipment plans for ensuring that specifications, are planned to be performed at necessary channel checks, appropriate frequencies established equivalent functional tests, periodic to or more frequently than existing SFPI. Manual calibration, and maintenance calibration and operator performance checks are will be conducted for the level planned to be performed on a perio~ic measurement system and its scheduled basis, with additional maintenance on supporting equipment. an as-needed basis when flagged by the b) A description of how the system's automated diagnostic t~sting features.

guidance in NEl12-02, Section Channel calibration tests per maintenance 4.3 regarding compensatory procedures, with limits established in actions for one or both non- consideration of vendor equipment functioning channels will be specifications, are planned to be performed at addressed. frequencies established in consideration of c) A description of what vendor recommendations.

compensatory actions are SFPI channel/equipment maintenance, planned in the event that one of preventative maintenance, and .

the instrument channels cannot testing program requirements to ensure design be restored to functional status and system readiness are planned to be within 90 days. 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) ?f relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel Page 11 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August 28, 2015 (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 Procedure CC-OC-118-1001, Diverse and Flexible Coping Strategies (Flex) and Spent Fuel Pool Instrumentation Program Implementation, and are summarized as follows:

1. Required Compensatory Channel(s) Restoration Action if Out-of- Action Required Service Restoration Action not completed within Specified Time 1 Restore Immediately Channel to initiate action functional in accordance status within with note 90 days (or if below channel restoration not expected within 90 days, then proceed to Compensatory Action) 2 Initiate action Immediately within 24 initiate action hours to in accordance 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 />.

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Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 Note: Initiate an Issue Report to enter the condition into the Corrective Action Program.

Identify the equipment out of service time is greater than the specified allowed out of service time, develop and implement an alternate method of monitoring, determine the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.

Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete (RAI Please provide additional The two sensors will be mounted in different locations of

-2, information describing how the SFP and separated by a distance comparable to the Ref. the final arrangement of the shortest side of the pool. The coaxial cables that extend

5) SFP instrumentation and from the two sensors toward the location of the routing of the cabling transmitters (sensors electronics) will be installed using between the level separate routes. The primary coaxial cable will be instruments, the electronics installed in conduit and the backup coaxial cable will be and the displays, meets the installed in cable tray. The Reactor Building and Cable Order requirement to Tray Bridges are seismic I structures and will remain arrange the SFP level operable during and after a beyond design basis event.

instrument channels in a The conduits and tray system (in which the coax cables manner that provides are installed) will be separated in accordance with reasonable protection of the current plant licensing bases criteria for electrical level indication function separation as defined in OCGS Specification SP-9000-against missiles that may 41-005, Cables & Raceways. The minimum separation result from damage to the between the coax cables from spent fuel pool to the structure over the SFP. transmitters is 8 feet. The 4-20mA cables that extend from the transmitters located in the Cable Tray Bridges to the electronics enclosure (display) located in the Upper Cable Spreading Room will be installed in seismic I structures, installed in separate conduits and will be routed separately with a minimum distance of 8 feet. The 120VAC power cables will be installed in a Page 13 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 seismic I building, installed in separate conduits and routed separately with a minimum distance of 1 feet.

This meets the separation requirements for the installed location per Oyster Creek Station Specification SP-9000-41-005, Cables & Raceways. All the equipment and supports will be seismically mounted.

2 RAI Question: Started (RAI For RAI 3(a) above, please Calculation CN-PEUS-15-08 prepared by Westinghouse

-4, provide the analyses used provides the design criteria for the loading on the Ref. to verify the design criteria mounting device(s), including static weight loads and and methodology for dynamic loads.

5) seismic testing of the SFP instrumentation and the The design basis maximum seismic loads were based electronics units, on the Bounding Curve and Bounding Tables provided including, design basis in Spent Fuel Pool Level Instrumentation Procurement maximum seismic loads Specification, 2013-BYR001.

and the hydrodynamic loads that could result from The hydrodynamic loads that could result from pool pool sloshing or other sloshing that could accompany such seismic forces effects that could were calculated using United States Atomic Energy accompany such seismic Commission, Nuclear Reactors and Earthquakes, TID-7024, August 1963, Chapter 6, "Dynamic Pressure on forces.

Fluid Containers." This is an acceptable method per CC-AA-320-1001, Design Guide for the Dynamic Qualification of Equipment.

NOTE: Calculation CN-PEUS-15-08 preparation is in progress. This document will be finalized at design completion and 100% acceptance of the design in September 2015. The requested detail will be provided in the February 2016, 6-month Integrated Plan update.

3 RAI Question: Started (RAI For each of the mounting The design inputs to qualify the structural integrity of the

-5, attachments required to affected structures/equipment are based on AR Ref. attach SFP level equipment Evaluations A2307026-02, A2307026-03, and

5) to plant structures, please equipment cut sheets from Westinghouse.

describe the design inputs, The methodology to qualify the structural integrity of the and the methodology that affected structures/equipment is qualification by was used to qualify the Analysis in accordance with CC-AA-320-1001, Design structural integrity of the Guide for the Dynamic Qualification of Equipment.

affected This information will be developed during the detailed structures/equipment.

design process. The SFPI system design completion and 100% acceptance of the design is scheduled for September 2015. The requested detail will be provided in the February 2016, 6-month Integrated Plan update.

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Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August 28, 2015 4 RAI Question: Started (RAI For RAI 6 above, please This information will be developed during the detailed

-7, provide the results for the design process. The SFPI system design completion Ref. selected methods, tests and and 100% acceptance of the design is scheduled for analyses used to September 2015. The requested detail will be provided 5) in the February 2016, 6-month Integrated Plan update.

demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

5 RAI Question: Complete Please provide the following:

(RAI a) A description of the a) The primary SFPLI instrument channel

-9, electrical ac power sources will be normally powered from safety related 120VAC, Ref. and capacities for the Post Accident Instrument Panel PDP-733-57. The

5) primary and backup backup SFPLI instrument channel will be normally channels. powered from the safety related 120VAC, Post b) Please provide the results Accident Instrument Panel PDP-733-58. These are on of the calculation depicting different safety buses, which maintains power source the battery backup duty independence. Upon loss of normal AC power, cycle requirements individual batteries installed in each channel's demonstrating that its electronics I UPS enclosure will automatically maintain capacity is sufficient to maintain the level indication continuous channel operation for at least 3 days.

function until offsite resource Before reaching the 3-day battery life, the Post Accident availability is reasonably Instrument Panels will be restored using the FLEX assured. diesel generator. Spatial and physical separation of the power cables will be maintained and complies with Oyster Creek Station Specification SP-9000-41-005, Cables & Raceways. The power cables will be routed in conduit approximately 1 foot apart and routed from the Control Room to the Upper Cable Spreading Room.

b) 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 Upper Cable Spreading Room elevation 63' -6". The results of the calculation meet the NEI 12-02 requirements.

6 RAI Question: Complete (RAI Please provide the a) The Oyster Creek Station primary and backup

-12, following: instrument channel displays are located in the Upper Ref. a) The specific location for Cable Spreading Room.

5) the primary and backup Page 15 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 instrument channel display. Response for b):

b) For any SFP level The Oyster Creek Station primary and backup instrumentation displays instrument channel displays are located on elevation located outside the main 63'-6", the floor above the control room. The Upper control room, please Cable Spreading Room is accessible through two doors describe the evaluation and a staircase. This location was selected due to used to validate that the proximity to the main control room. The Upper Cable display location can be Spreading Room is not applicable in Engineering accessed without Standard ES-027, "Environmental Parameters Oyster unreasonable delay Creek NGS"; therefore, the radiological habitability at following a BOB event. this location will remain less than emergency exposure Include the time limits allowable for emergency responders to perform available for personnel to this action. Heat and humidity from SFP boildown access the display as conditions have been evaluated for this location. The credited in the evaluation, location is at an elevation several floors below the SFP as well as the actual time operating floor and located in a different building (e.g., based on walk- physically separated by concrete walls, such that heat throughs) that it will take for and humidity from a boiling SFP would not compromise personnel to access the habitability at this location.

display. Additionally, please Spent Fuel Pool Level monitoring will be the include a description of the responsibility of Operations personnel who will monitor radiological and the display periodically once dispatched from the environmental conditions Control Room. Travel time from the Control Room to the on the paths personnel primary and secondary displays is approximately 2 might take. Describe minutes based on walkdowns. Radiological habitability whether the display location for the transit routes to both displays is not available in remains habitable for Engineering Standard ES-027, "Environmental radiological, heat and Parameters Oyster Creek NGS"; therefore, the humidity, and other radiological habitability at this location will remain less environmental conditions than emergency exposure limits allowable for following a BOB event. emergency responders to perform this action. Heat and Describe whether personnel humidity from SFP boildown conditions have been are continuously stationed evaluated for access to this location, and the access at the display or monitor the routes are below the SFP operating floor and located in display periodically. a different building 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 employ radio communications or the telephone communication. If the radio communications or telephone systems are nonfunctional, the sound powered phone system is assumed available because no power is required. A sound powered phone jack is located in the Control Room; however, a sound powered phone jack is not located in the Upper Cable Spreading Room. The sound powered phone will be available to dispatch personnel for the monitoring of the indicators.

The display will be accessed on demand. It takes up to 2 minutes to reach the display location, for both the primary and backup channels, when an operator is Page 16 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August 28, 2015 dispatched from the control room. The actual time for accessing the display locations is based on a walkthrough from the Control Room to the Upper Cable Spreading Room. 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 Upper Cable Spreading Room.

Upon obtaining the indicated SFP level from the display location, the operators will use the radio communication system to provide the information to the control room immediately.

7 RAI Question: Complete (RAI Please provide a list of the Appropriate quality measures will be selected for the

-13, procedures addressing SFPIS required by Order EA-12-051, consistent with Ref. operation (both normal and Appendix A of NEI 12-02. Site procedures will be

5) abnormal response), developed for system inspection, calibration and test, calibration, test, maintenance, repair, operation and normal and maintenance, and inspection abnormal responses, in accordance with procedures that will be Exelon's procedure control process. Technical developed for use of the SFP objectives to be achieved in each of the respective instrumentation. The licensee procedures are described below:

is requested to include a brief description of the Procedure Objectives to be achieved:

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

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. 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 operation 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.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

Page 17 of 18

Oyster Creek Nuclear Generating Station Fifth Six-Month Status Report for the Implementation of SFPLI August28,2015 8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Oyster Creek Nuclear Generating Station, "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 033)

2. NRC Order Number EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

3. USN RC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated August28,2013

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 September 18, 2013 (RS-13-212)

5. USN RC 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 8, 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-13-124)

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 Feburary 28, 2014 (RS-14-023)

8. Third 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, 2014 (RS-14-201)

9. Fourth Six Month Status Report for the Implementation of Order EA-12-051 , Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated Feburary 27, 2015 (RS-15-031)

10. C-1302-822-5360-008, Rev 2, "Reactor Bldg Loss of Ventilation"

11. ES-027, Rev 004, "Environmental Parameters Oyster Creek NGS" Page 18 of 18