RS-14-025, Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)

ML14062A063
Person / Time
Site:	Quad Cities
Issue date:	02/28/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-025
Download: ML14062A063 (18)

Text

Exelon Generation Order No. EA-12-051 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

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-13-035)

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-13-128)

7. NRC letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power 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. MF1052 and MF1053), dated October 9, 2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page 2 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 Quad Cities Nuclear Power 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 Quad Cities Nuclear Power 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,

~[,~

Glen T. Kaegi Director- Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Quad Cities Nuclear Power 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

Enclosure Quad Cities Nuclear Power 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)

Quad Cities Nuclear Power 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 1 Introduction Quad Cities Nuclear Power 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 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 the issuance of this report.

• Begin detailed design engineering of the SFPLI for Quad Cities Nuclear Power 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.

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 RAis July 3, 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 Provide Final Safety Evaluation September 30, 2014 Not Started Page 1 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Revised Target Completion Activity Target Milestone Date Status Completion Date (SE) Info I Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin (Site Specific) Detailed 402013 Complete Engineering Design Complete and Issue SFPI 202014 Started Modification Package Begin Installation 402014 Not Started Complete SFPI Installation and 102015 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 Quad Cities Nuclear Power 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 Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Ref. 1) or the Interim Safety Evaluation (ISE)(Ref. 5) and the status of each item. All incomplete RAI questions from the Interim Safety Evaluation are included as Open Items in the Tables below.

Overalllntegrated Plan Open ltems(OI) 01# Description Status 1 Open Item: Complete.

(Ref.1) Continuous level indication will be (Addressed in Reference 7) provided by a guided wave radar Page 2 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 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: Not Started.

(RAI-2, Please provide a clearly labeled Note that the completion date for design Ref.4) sketch or marked-up plant drawing of has changed from March 2014 to May the plan view of the SFP area, 2014; however, submittal of results in depicting the SFP inside dimensions, August 2014, 6-month Integrated Plan the planned locations/placement of update has not changed.

the primary and back-up SFP level sensor, and the 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 I routings are not available at this time. I This information will be developed during the detailed design process. The current plan for the design of the SF PI system based on the current Exelon Nuclear program schedule for Quad Cities is to begin the design phase in October 2013 with design completion and 100% acceptance of the design in May 2014. The requested information II will be provided in the August 2014, 6-month Integrated Plan update.

3 RAI Question: Not Started.

(RAI-3, Please provide the following: Note that the completion date for design Ref.4) has changed from March 2014 to May a) The design criteria that will be 2014; however, submittal of results in used to estimate the total loading on August 2014, 6-month Integrated Plan the mounting device(s), including update has not changed.

static weight loads and dynamic 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 Page 3 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six~Month Status Report for the Implementation of SFPLI February 28, 2014 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 during the detailed design process. The current plan for the design of the SF PI system based on the current Exelon Nuclear program schedule for Quad Cities is to begin the design phase in I October 2013 with design completion and 100% acceptance of the design in May 2014. The requested information I

will be provided in the August 2014, 6~

month Integrated Plan update.

4 RAI Question: Not Started.

(RAI-4, Please provide the following: Note that the completion date for design Ref.4) has changed from March 2014 to May a) A description of the specific 2014; however, submittal of results in method or combination of methods August 2014, 6-month Integrated Plan you intend to apply to demonstrate update has not changed.

the reliability of the permanently installed equipment under beyond-design-basis ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or Page 4 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 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 I 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 during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Quad Cities is to begin the design phase in October 2013 with design completion and 100% acceptance of the design in May 2014. The requested information will be provided in the August 2014, 6-month Integrated Plan update.

5 RAI Question: Not Started.

(RAI-5, Please provide the following: Note that the completion date for design Ref.4) has changed from March 2014 to May a) A description of how the two 2014; however, submittal of results in channels of the proposed level August 2014, 6-month Integrated Plan measurement system meet this Page 5 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 requirement so that the potential for update has not changed.

a common cause event to adversely 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

I Channel independence information is not available at this time. This I information will be developed during the I detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 2014.

The requested information will be provided in the August 2014, 6-month Integrated Plan update.

6 RAI Question: Not Started.

(RAI-6, Please provide the following: Note that the completion date for design Ref.4) a) A description of the electrical ac has changed from March 2014 to May I 2014; however, submittal of results in power sources and capabilities for August 2014, 6-month Integrated Plan the primary and backup channels.

update has not changed.

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 Page 6 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six*Month Status Report for the Implementation of SFPLI February 28, 2014 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 Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 2014.

The requested information will be provided in the August 2014, 6-month Integrated Plan update.

7 RAI Question: Not Started.

(RAI-7, Ref.4)

Please provide the following:

a} An estimate of the expected Note that the completion date for design has changed from March 2014 to May I

2014; however, submittal of results in instrument channel accuracy August 2014, 6-month Integrated Plan performance under both (a} normal update has not changed.

SFP level conditions (approximately Level1 or higher) and (b) at the-16beyond design-basis conditions (i.e., radiation, temperature, humidity, postseismic 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 operating conditions as an l acceptance criterion for a calibration procedure to flag to operators and to l technicians that the channel requires adjustment to within the normal I

condition design accuracy.

RESPONSE

Channel accuracy information is not available at this time. This information Page 7 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 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 Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 2014.

The requested information will be provided in the August 2014, 6-month Integrated Plan update.

8 RAI Question: Not Started.

(RAI-8, Please provide the following: Note that the completion date for design Ref.4) has changed from March 2014 to May a) A description of the capability and 2014; however, submittal of results in provisions the proposed level August 2014, 6-month Integrated Plan sensing equipment will have to update has not changed.

enable periodic testing and 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 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 Page 8 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 channels are fully conditioned to accurately and reliably perform their functions when needed.

RESPONSE

Equipment testing, calibration, functional checks and maintenance I 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 Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 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 August 2014, 6*

month Integrated Plan update.

9 RAJ Question: Replaced by Interim SE RAI #12(Ref. 5)

Please provide the following: open issue in this report (RAI-9, Ref.4) a) The specific location for each of Note that the completion date for design the primary and backup instrument has changed from March 2014 to May channel displays. 2014; however, submittal of results in b) If the primary and backup display August 2014, 6-month Integrated Plan location is other than the main control room, provide justification for update has not changed.

prompt accessibility to displays including primary and alternate route I 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.

c) The reasons justifying why the locations selected enable the information from these instruments to be considered 11 promptly accessible .. to various drain-down Page 9 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six~Month Status Report for the Implementation of SFPLI February 28, 2014 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 Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 2014.

The requested information will be provided in the August 2014, 6-month Integrated Plan update.

10 RAI Question: Replaced by Interim SE RAI #13 (Ref. 5)

Please provide a description of the open issue in this report (RAI-1 0, Ref.4) standards, guidelines and/or criteria Note that the completion date for design that will be utilized to develop has changed from March 2014 to May procedures for inspection, 2014; however, submittal of results in maintenance, repair, operation, August 2014, 6-month Integrated Plan abnormal response, and administrative controls associated update has not changed.

with the SFP level instrumentation, as well as storage and installation of portable instruments.

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 plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Quad Cities is to begin the design phase in October 2013 with design completion and 100%

acceptance of the design in May 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 August 2014, 6-month Integrated Plan update.

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Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 11 RAJ Question: Not Started.

(RAI-11, Please provide the following: Note that the completion date for design Ref.4) has changed from March 2014 to May a) Further information describing the 2014; however, submittal of results in maintenance and testing program August 2014, 6-month Integrated Plan the licensee will establish and update has not changed.

implement to ensure that regular 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 I

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 NEI 12-02 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 I

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 Quad Cities is to begin the design phase in October 2013 with design completion and 100% acceptance of the design in May 2014. Following the issue of the design, procedures will start Page 11 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 being developed. The requested information will be developed early in the process and will be provided in the August 2014, 6-month Integrated Plan update.

12 RAI Question: Complete (RAI-1, Please provide the following: (Addressed in Reference 4)

Ref. 4) a) For level L 1, 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 I 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 L 1, L2, and L3 as well as the top of the fuel.

Indicate on this sketch the portion of the level sensormeasurement range that is sensitive to measurement of the fuel pool level, with respect to the L 1, L2, and L3 datum points.

Interim Safety Evaluation Open Items (Ref. 5 & 6}

01# Description Status 1 RAI Question: Complete (RAI-1, Please provide the following: a) Complete redundant Ref. 5, a) Describe the impact of the installation of the monitoring of the pools will

6) gates between the SFPs and transfer canal on not be available when the the reliability of the SFP level instrumentation for gates are installed. The each SFP. Describe the compensatory measures gates are normally not that would be taken to ensure reliable indication in each SFP when the gates are installed. installed during any b) Describe the elevation for the bottom of the expected plant modes of gate opening or highest elevation of the bottom operation. There is an of the transfer canal to demonstrate that both the existing procedure QCFPH primary and backup S FP level instrument 1200-14 to remove and channels can measure the same Level 3 install the gates. To address elevation in both SFPs.

the concern related to the unexpected plant modes of Page 12 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPU February 28, 2014 operation when the gates may be installed, the procedure QCFPH 1200-14 will be revised to:

• Note that installation of the gates affects the redundancy of the Reliable Spent Fuel Pool Instrumentation.

• If the gates have to be installed, the procedure already has established administrative guidance/controls to follow that are more restrictive than the NEI 12-02 revision 1 guidance for the 90 day out of service rule and are therefore acceptable.

b) The elevation for the bottom of the gate opening for Quad Cities is 666'-8 W'.

Level 3 for Quad Cities will be revised to be defined as the bottom of the gate opening elevation 666'-8 W', rather than the top of the storage rack elevation 666"-2" to demonstrate that both the primary and backup SFP level instrument channels can measure the same Level 3 elevation in both SFPs.

2 RAI Question: Not Started.

(RAI-4, For RA13(a) above, please provide the analyses Ref. 5) used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, Including design basis maximum seismic toads Page 13 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPU February 28, 2014 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-5, For each of the mounting attachments required Ref.5) to attach SFP level equipment to plant structures, please describe the design inputs and methodology used to qualify the structural integrity of the affected structures and equipment. I 4 RAI Question: Not Started.

(RAI-7, For RAI #6 above, please provide the results for I

Ref. 5) the selected methods, tests and analyses utilized to demonstrate the qualification and reliability of the installed equipment In accordance with the Order requirements.

5 RAI Question: Not Started.

(RAI-12, Please provide the following:

Ref. 5) a) The specific location for each of the primary and backup instrument channel displays.

b) If a display will be located somewhere other than the control room or alternate shutdown panel, 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 II personnel to access the display as credited in the evaluation, as we as the actual time (e.g.,

based on walk-throughs) that it will take for personnel to access the display. Additionally, I

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.

6 RAI Question: Not Started.

(RAI-13, 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 spent SFP instrumentation. Please provide a brief description of the specific technical objectives to be achieved within each procedure.

Page 14 of 15

Quad Cities Nuclear Power Station, Units 1 and 2 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Note: RAis not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAis in Reference 3 and are listed in the Overall Integrated Plan Open Item Table.

7 Potential Draft Safety Evaluation Impacts (Ref. 5)

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 035)

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, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7, 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-12-051)", dated July 3, 2013 (RS-13-159).

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 October 9, 2013.

6. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated November 26, 2013.

7. 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-13-128).

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