RS-14-022, 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)
| ML14059A223 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| 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-14-022 | |
| Download: ML14059A223 (19) | |
Text
Order No. EA-12-051 RS-14-022 February 28,2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
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. NEI12-02, 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-13-032)
- 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-13-122)
- 7. NRC letter to Exelon Generation Company, LLC, Limerick Generating Station, Units 1 and 2 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0854 and MF0855), dated October 23,2013
U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page 2 On March 12, 201 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 Limerick Generating Station, Units 1 and 2 overall integrated plan.
Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. Reference 6 provides the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1 for Limerick Generating Station. 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 28th day of February 2014.
Respectfully submitted, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC
Enclosure:
- 1. Limerick Generating Station, Units 1 and 2 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 Limerick Generating Station, Units 1 and 2 NRC Project Manager, NRR - Limerick Generating Station, Units 1 and 2 Ms. Jessica A Kratchman, NRR/JLD/PMB, NRC Mr. Stephen R. Monarque, NRR/JLD/JPMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Greg A Casto, NRR/DSS/SBPB, NRC Mr. Richard B. Ennis, NRR/DORULPL3-2, NRC Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection
Enclosure Limerick Generating Station, Units 1 and 2 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)
Limerick Generating Station, Units 1 and 2 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 Limerick Generating Station, Units 1 and 2, developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install Reliable Spent Fuel Pool Level Instrumentation (SFPLI), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the First six month status report including any changes to the compliance method, schedule, or need for relieflrelaxation and the basis, if any.
2 Milestone Accomplishments The following milestones have been completed since the submittal of the First Six Month Status Report, (Ref. 6) and are current as of January 24, 2014.
- Detailed design of the SFPLI for Limerick Generating Station has commenced.
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 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 Responses to RAls July 18, 2013 Complete Submit 6 Month Updates:
Update 1 August 28, 2013 Complete Complete with Update 2 February 28, 2014 this submittal Update 3 August 28, 2014 Not Started Page 1 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 Revised Target Completion Activity Target Milestone Date Status Completion Date Provide Final Safety Evaluation September 30, 2014 Not Started (SE) Info Update 4 February 28,2015 Not Started Modifications:
Conceptual Design 302012 Complete Issue Exelon Fleet contract to 102015 Complete procure SFPI Equipment Begin Detailed Engineering 302013 Complete Design Complete and Issue SFPI 202014 Started 302014 Modification Package Begin Installation 302014 Not Started 102015 Complete SFPI Installation and 202015 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 Limerick Generating Station, Units 1 and 2, expects to comply with the order implementation date and no relief/relaxation is required at this time.
6 Open Items from Overall Integrated Plan and Interim Staff Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Staff Evaluation (ISE) and the status of each item.
Overall Integrated Plan Open Items 01# Description Status 1 Open Item: Complete.
Continuous level indication will be (Addressed in Reference 6)
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Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 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: Complete.
(RAI-1, Please provide the following: (Addressed in Reference 4)
Ref. 3) a) For levell, specify how the identified location represents the HIGHER of the two points described in the NEI 12-02 guidance for this level.
b) A clearly labeled sketch depicting the elevation view of the proposed typical mounting arrangement for the portions of instrument channel consisting of permanent measurement channel equipment (e.g., fixed level sensors and/or stilling wells, and mounting brackets). Indicate on this sketch the datum values representing Levell, 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 Levell, Level 2, and Level 3 datum points.
Indicate on this sketch the elevation of the bottom opening of the gates that connect the two pools.
3 RAI Question: Not Started.
(RAI-2, Please provide a clearly labeled sketch Note that the completion date for design Ref.3) or marked-up plant drawing of the plan has changed from 202014 to 302014.
view of the SFP area, depicting the The requested information will be SFP inside dimensions, the planned locations/placement of the primary and provided by September 30, 2014 in backup SFP level sensor, and the accordance with the ISE (Reference 5).
proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device.
RESPONSE
Final sensor locations and cable Page 3 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February ~~, 2014 routings are not available at this time.
This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
4 RAIOuestion: Not Started.
(RAI-3, Please provide the following: Note that the completion date for design Ref.3) a) The design criteria that will be has changed from 202014 to 302014.
used to estimate the total loading on The requested information will be the mounting device(s), including provided by September 30, 2014 in static weight loads and dynamic accordance with the ISE (Reference 5).
loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the 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 support the level sensor assembly.
RESPONSE
Mounting device total loading and attachments are not available at this time. This information will be developed Page 4 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 during the detailed design process. The current plan for the design of the SFPI I system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
5 RAIOuestion: Not Started.
(RAI-4, Please provide the following: Note that the completion date for design Ref.3) a) A description of the specific method has changed from 202014 to 302014.
or combination of methods that will be The requested information will be applied to demonstrate the reliability of the permanently installed equipment provided by September 30, 2014 in under BOB ambient temperature, accordance with the ISE (Reference 5).
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 basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to a) the level sensor mounted in the SFP area, and b) any control boxes, electronics, or read-out and re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.
c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.
RESPONSE
Equipment reliability qualification information is not available at this time.
This information will be developed durinq the detailed design process. The Page 5 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
6 RAI Question: Not Started.
(RAI-5, Please provide the following: Note that the completion date for design Ref.3) a) A description of how the two has changed from 202014 to 302014.
channels of the proposed level The requested information will be measurement system meet this requirement so that the potential for a provided by September 30, 2014 in common cause event to adversely accordance with the ISE (Reference 5).
affect both channels is minimized to the extent practicable.
b) Further information on how each 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
Channel independence information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
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Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28. 2014 7 RAIOuestion: Not Started.
(RAI-6, Please provide the following: Note that the completion date for design Ref.3) a) A description of the electrical ac has changed from 202014 to 302014.
power sources and capacities for the The requested information will be primary and backup channels.
b) Please provide the results of the provided by September 30, 2014 in calculation depicting the battery accordance with the ISE (Reference 5).
backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured.
RESPONSE
Equipment total power supply configuration and characteristics are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100% acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
8 RAIOuestion: Not Started.
(RAI-7, Please provide the following: Note that the completion date for design Ref.3) a) An esti mate of the expected has changed from 202014 to 302014.
instrument channel accuracy The requested information will be performance under both (a) normal provided by September 30, 2014 in SFP level conditions (approximately accordance with the ISE (Reference 5).
Level 1 or higher) and (b) at the BDB conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) 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 Page 7 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 operating conditions as an acceptance criterion for a calibration I procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.
RESPONSE
Channel accuracy information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100% acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
9 RAI Question: Not Started.
(RAI-8, Please provide the following: Note that the completion date for design Ref.3) a) A description of the capability and has changed from 202014 to 302014.
provisions the proposed level The requested information will be sensing equipment will have to provided by September 30, 2014 in enable periodic testing and accordance with the ISE (Reference 5).
calibration, including how this capability enables the equipment to be tested in-situ.
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 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 Page 8 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 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
Equipment testing, calibration, functional checks and maintenance requirements are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. Following the issue of the design procedures will be developed.
The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
10 RAJ Question: Not Started.
(RAI-9, Please provide the following: Note that the completion date for design Ref.3) a) The specific location for the primary has changed from 2Q2014 to 3Q2014.
and backup instrument channel The requested information will be display.
b) If the primary or backup display provided by September 30, 2014 in location is other than the main control accordance with the ISE (Reference 5).
room, then provide justification for prompt accessibility to displays including primary and alternate route evaluation, habitability at display location(s), continual resource availability for personnel responsible to promptly read displays, and provisions for communications with decision makers for the various SFP drain-down scenarios and external events.
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Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 c) The reasons justifying why the locations selected enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.
RESPONSE
Channel display location information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
11 RAI Question: Replaced by Interim SE RAI #15 (RAI-10, Please provide the following: Note that the completion date for design Ref.3) a) A list of the operating (both normal has changed from 2Q2014 to 3Q2014.
and abnormal response) procedures, The requested information will be calibration/test procedures, maintenance procedures, and provided by September 30, 2014 in inspection procedures that will be accordance with the ISE (Reference 5).
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.
RESPONSE
Procedural details are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current Page 10 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. Following the issue of the design procedures will be developed.
The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
12 RAI Question: Not Started.
(RAI-11, Please provide the following: Note that the completion date for design Ref.3) a) Further information describing the has changed from 202014 to 302014.
maintenance and testing program The requested information will be the licensee will establish and provided by September 30, 2014 in implement to ensure that regular accordance with the ISE (Reference 5).
testing and calibration is performed and verified by inspection and audit to demonstrate 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 NE112-02 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.
RESPONSE
Testing and calibration program requirements and compensatory actions are not available at this time. This information will be established during process and procedure development following the detailed design phase.
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Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Limerick Generating Station is to begin the design phase in September of 2013 with design completion and 100%
acceptance of the design in September of 2014. Following the issue of the design procedures will be developed.
The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5).
Interim Staff Evaluation Open Items 01# Description Status 1 RAI Question: Complete with this submittal.
(RAI-1, Please provide the following: a) Complete redundant monitoring Ref. 5) a) A description of the operational of the pools will not be available circumstances under which the gates are when the gates are installed. The expected to be installed, and describe how continuous back-up monitoring (e.g., direct gates are not normally installed.
visual observation) is available when the There is an existing procedure M-gates are installed. 097-009 (Cask Pit Gate b) The elevation for the bottom of the gate Removal, Installation, opening to demonstrate that both the Maintenance and Movement of primary and backup SFP instrument Fuel Pool Gates Between channels can simultaneously measure the same Level 3 elevation. Storage/ Repair Locations) to remove and install the gates. To address the concern when the gates may be installed, the procedure M-097 -009 will be revised to establish administrative guidance/controls to follow the N EI 12-02 rev. 1 guidance for the 90-day out of service criterion.
b) The elevation for the bottom of the gate opening for Limerick Generating Station (LGS) is 328.2ft. Level 3 for LGS is revised to elevation 328.5ft, which is slightly above the bottom of the gate opening, rather than the top of the Fuel rack elevation 327.5ft. This will provide Page 12 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28,2014 assurance that both the primary and backup SFP level instrument channels can measure the same Level 3 elevation in both SFPs.
2 RAI Question: Complete with this submittal.
(RAI-2, Please describe the impact of the Refer to response to the RAI-1a of Ref. 5) installation of the gate on the reliability of the Interim Staff Evaluation Open the SFP level instrumentation for each SFP, Items above.
and what compensatory measures would be taken to ensure reliable level indication in each SFP when the gate is installed.
3 RAI Question: Not Started.
(RAI-4, Please provide additional information Ref. 5) describing how the final arrangement of the SFP instrumentation and routing of the cabling between the level instruments, the electronics and the displays, meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.
4 RAI Question: Not Started.
(RAI-6, For RAI 5(a) above (please refer to RAI-Ref. 5) 3(a) in the Overall Integrated Plan Open Items Table), please provide the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.
5 RAI Question: Not Started.
(RAI-7, For each of the mounting attachments Ref. 5) required 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 lequipment.
6 RAI Question: Not Started.
(RAI-9, For RAJ #8 above, (please refer to RAI-4 in the Overall Integrated Plan Open Items Page 13 of 15
Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 28, 2014 Ref. 5) Table), please provide the results for the selected methods, tests and analyses utilized to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.
7 RAI Question: Not Started.
(RAI-14, Please provide the following:
Ref. 5) a) The specific location for the primary and backup instrument channel display.
b) For any display located outside the main control room, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the 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.
8 RAI Question: Not Started.
(RAI-15, 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 3, 5, 8, 10,11,12,13 and 16 are not included in the Interim Staff Evaluation Open Items Table as they are duplicate to the RAls in Reference 3 and listed in the Overall Integrated Plan Open Item Table as RAls 2, 3, 4, 5, 6, 7, 8, and 11 respectively.
7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
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Limerick Generating Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFP LI February 2014 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 032).
- 2. NRC Order Number EA-12-051, "Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012.
- 3. USNRC letter to Exelon Generation Company, LLC, Limerick Generating Station, Units 1 and 2- Request For Additional Information RE: Overall Integrated Plan In Response to Order EA-12-051, "Reliable Spent Fuel Pool Instrumentation" (TAC NOS. MF0854 and MF0855), dated June 24 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 18,2013, (RS-13-177).
- 5. USNRC letter to Exelon Generation Company, LLC, "Limerick Generating Station, Units 1 and 2 -Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (T AC NOS. MF0854 and MF0855)", dated October 23, 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-13-122)
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