RS-14-202, 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)

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)

ML14241A303
Person / Time
Site:	Peach Bottom
Issue date:	08/28/2014
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-202
Download: ML14241A303 (30)

Text

Exelon Generation RS-14-202 August 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Order No. EA-12-051 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278

Subject:

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)

References:

1. NRG Order Number EA-12-051," Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

2. NRG 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 NRG 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-13-034)

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-13-126)

7. Exelon Generation Company, LLC Secind 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 024)

8. NRG letter to Exelon Generation Company, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - 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. MF0849 and MF0850), dated October 30, 2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 August 28, 2014 Page2 On March 12, 2012, the Nuclear Regulatory Commission ("NRG" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGG). Reference 1 was immediately effective and directs EGG 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 EGG initial status report regarding reliable spent fuel pool instrumentation. Reference 5 provided the Peach Bottom Atomic Power Station, Units 2 and 3 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 and 7 provided the first and second six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Peach Bottom Atomic Power Station. The purpose of this letter is to provide the third 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 NRG Interim Staff Evaluation Request for Additional Information Items contained in Reference 8.

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 281h day of August 2014.

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

Enclosure:

1. Peach Bottom Atomic Power Station, Units 2 and 3 Third 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 August 28, 2014 Page3 cc:

Director, Office of Nuclear Reactor Regulation NRG Regional Administrator - Region I NRG Senior Resident Inspector-Peach Bottom Atomic Power Station, Units 2 and 3 NRG Project Manager, NRR - Peach Bottom Atomic Power Station, Units 2 and 3 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRG Mr. Stephen R. Monarque, NRR/JLD/PMB, NRG Mr. Robert L. Dennig, NRR/DSS/SCVB, NRG Mr. Richard B. Ennis, NRR/DORULPL3-2, NRG Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resouorces S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (26 pages)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1

Introduction Peach Bottom Atomic Power Station, Units 2 and 3, developed an Overall Integrated Plan (Reference 1 in Section 8), documenting the requirements to install reliable Spent Fuel Pool Level Instrumentation (SFPLI), in response to Reference 2. This enclosure provides an update of milestone accomplishments since submittal of the second six month status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the second six month status report (Reference 7), and are current as of July 31, 2014.

Provided Final Safety Evaluation (SE) information via ePortal submittal on June 27, 2014.

3 Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change.

The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

Revised Milestone Target Completion Activity Target Date Status Completion Date Submit 60 Day Status Report October 25, 2012 Complete Submit Overall Integrated Plan February 28, 2013 Complete Submit Response to RAls July 19, 2013 Complete Submit 6 Month Updates:

Update 1 August28,2013 Complete Page 1of26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete with this submittal.

Provide Final Safety Evaluation September 30, 2014 Complete (SE) Info Update 4 February 28, 2015 Not Started Update 5 August 28, 2015 Not Started Update 6 February 28, 2016 Not Started Modifications:

Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Engineering 402013 Complete Design for Unit 3 and Unit 2 Complete and Issue SFPI 302014 Started Modification Package for Unit 3 Complete and Issue SFPI 302014 Started Modification Package for Unit 2 Begin SFPI Installation for Unit 3 202015 Not Started Complete SFPI Installation for P3R20 Not Started Unit 3 and Put Into Service (Fall 2015)

Begin SFPI Installation for Unit 2 202016 Not Started Complete SFPI Installation for P2R21 Not Started Unit 2 and Put Into Service (Fall 2016) 4 Changes to Compliance Method 402014 402014 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 Peach Bottom Atomic Power Station, Units 2 and 3, expects to comply with the order implementation date and no relief/relaxation is required at this time.

Page 2 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 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 OI#

Description Status 1

Open Item:

Complete.

(Ref.1)

Continuous level indication will (Addressed in Reference 6) 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:

Complete.

(RAl-1, a) For level 1, specify how the (Addressed in Reference 4)

Ref. 4) 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 Level 1, Level 2, and Level 3 as well as the top of the fuel racks. Indicate on this sketch the portion of the level sensor measurement range that is sensitive to measurement of the fuel pool level, with respect to the Level 1,Level2,andLevel3 datum points.

Page 3 of 26

3 (RAl-2, Ref.4) 4 (RAl-3, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 RAI Question:

Started.

Please provide a clearly labeled Please see Attachment 1 for the sketch which sketch or marked-up plant shovys the probe locations. The cable routing drawing of the plan view of the detailed design is not complete. The design is SFP area, depicting the SFP targeted for completion by October 31, 2014.

inside dimensions, the planned locations/placement of the primary and backup SFP level As shown on Peach Bottom Atomic Power sensor, and the proposed routing Station drawing S-226, sheet 1, each pool is of the cables that will extend from the sensors toward the location of 35' - 4" in the north-south direction and 40' -

the read-out/display device.

O" in the east-west direction. The sensors are diagonally opposed on opposite sides, north and south, of the pool which is a distance that is greater than the shortest dimension of the pool.

RAI Question:

Started.

Please provide the following:

a) All SFPIS equipment will be designed in accordance with the Peach Bottom a) The design criteria that will be Atomic Power Station Safe Shutdown used to estimate the total loading Earthquake (SSE) design on the mounting device(s),

requirements.

including static weight loads and The vendor, Westinghouse, will dynamic loads. Describe the evaluate the structural integrity of the methodology that will be used to mounting brackets in a calculation. The estimate the total loading, GTSTRUDL model, used by inclusive of design basis Westinghouse to calculate the stresses maximum seismic loads and the hydrodynamic loads that could in the bracket assembly, considers load result from pool sloshing or other combinations for the dead load, live effects that could accompany load and seismic load on the bracket.

such seismic forces.

The reactionary forces calculated from these loads become the design inputs b) A description of the manner in to design the mounting bracket which the level sensor (and anchorage to the refuel floor to stilling well, if appropriate) will be withstand a Safe Shutdown Earthquake attached to the refueling floor (SSE).

and/or other support structures for each planned point of Seismic attachment of the probe assembly. Indicate in a schematic The seismic loads are obtained from the portions of the level sensor Peach Bottom Atomic Power Station's that will serve as points of UFSAR Appendix C Section 2.6, attachment for mechanical/mounting or electrical including dead, live, and earthquake connections.

loads. This section has been transmitted to the vendor, c) A description of the manner Westinghouse, for input to their design by which the mechanical analysis. The following methodology connections will attach the level Page 4of26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 instrument to permanent SFP will be used in determining the stresses structures so as to support the on the bracket assembly:

level sensor assembly.

• Frequency analysis, taking into account the dead weight and the hydrodynamic mass of the structure, is performed to obtain the natural frequencies of the structure in all three directions.

• SSE (Safe Shutdown Earthquake) response spectra analysis is performed to obtain member stresses and support reactions.

• Modal responses are combined using the Ten Percent Method per U.S. NRG Regulatory Guide 1.92, Revision 1, "Combining Modal Responses and Spatial Components in Seismic Response Analysis".

• The seismic loads for each of the three directions are combined by the Square Root of the Sum of Squares (SASS) Method.

• Sloshing analysis is performed to obtain liquid pressure and its impact on bracket design.

• The seismic results are combined with the dead load results and the hydrodynamic pressure results in absolute sum. These combined results are compared with the allowable stress values.

Sloshing Sloshing forces will be obtained by analysis. The TID-7024, Nuclear Reactors and Earthquakes, 1963, by the US Atomic Energy Commission, approach will be used to estimate the wave height and natural frequency.

Horizontal and vertical impact force on the bracket components will be calculated using the wave height and natural frequency obtained using the Page 5 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 TID-7024 approach. Using this methodology, sloshing forces will be calculated and added to the total reactionary forces that would be applicable for bracket anchorage design. The analysis will also confirm that the level probe can withstand a credible design basis seismic event.

The following Westinghouse documents will provide information with respect to the design criteria used, and a description of the methodology used to estimate the total loading on the device.

a. Pool-side Bracket Seismic Analysis (This calculation has not been completed. The calculation number will be provided in a future six month update.)

b. LTR-SEE-11-13-47, WNA-TR-03149-GEN - Sloshing Analysis

c. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 - Seismic Qualification of other components of SFPI Peach Bottom Atomic Power Station specific calculations will be developed to address the seismic qualification of the readout display in the Radwaste Building. The design criteria in this calculation will meet the requirements to withstand a SSE. The methods that will be used in the calculation follow IEEE Standard 344-2004 and IEEE Standard 323-2003 for seismic qualification of the instrument.

b) The level sensor, which is one long probe, will be suspended from the launch plate via a coupler/connector assembly. The launch plate is a subcomponent of the bracket assembly, which is mounted to the refuel floor via anchors.

Page 6of26

5 (RAl-4, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 c) The bracket assembly that supports the sensor probe and launch plate will be mounted to the refuel floor and span over the SFP without touching permanent SFP structures. The refuel floor mounting consists of four concrete expansion anchors that will bolt the bracket assembly to the refuel floor via the base plate. The concrete expansion anchors and welds will be designed to withstand SSE and will meet the Peach Bottom Atomic Power Station augmented installation requirements.

The qualification details of the bracket will be provided in a pool-side bracket Seismic Analysis and the qualification of the anchorage to the floor will be provided in a Peach Bottom Atomic Power Station specific calculation -

Evaluation of SFPI Sensor Mounting Detail Anchorage and Mounting.

The design is targeted for completion by October 31, 2014.

RAI Question:

Started.

Please provide the following:

a) Beyond Design Basis Environment -

Westinghouse will qualify the components a) A description of the specific (probe, connector, cable) of the SFPIS method or combination of located in the SFP area to the beyond methods that will be applied to design basis environment. Components demonstrate the reliability of the of the system will be subjected to beyond permanently installed equipment design basis conditions of heat and under beyond-design-basis humidity, thermal and radiation aging (BOB) ambient temperature, mechanisms. This testing will confirm the humidity, shock, vibration, and functionality of these system components radiation conditions.

under beyond design basis environmental conditions. Westinghouse will perform b) A description of the testing testing to ensure aging of the components and/or analyses that will be in the SFP area will not have a significant conducted to provide assurance effect on the ability of the equipment to that the equipment will perform perform following a plant design basis reliably under the worst-case earthquake.

credible design basis loading at Mild Environment-Westinghouse will the location where the equipment will be mounted.

qualify the components (display panel, Include a discussion of this transmitter) of the SPFIS located in the seismic reliability demonstration Radwaste Building Fan Room to the mild Page 7 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 as it applies to (i) the level environment to determine that the sensor mounted in the SFP area, components can satisfactorily perform to and (ii) any control boxes, those conditions. Westinghouse will electronics, or read-out and re-confirm that aging does not have a transmitting devices that will be significant effect on the ability of the employed to convey the level information from the level equipment to perform following a plant sensor to the plant operators or design basis earthquake.

emergency responders.

c) A description of the specific Display-The methods to be used by the method or combination of vendor to qualify the readout display follow methods that will be used to IEEE Standard 344-2004 and IEEE confirm the reliability of the Standard 323-2003 for seismic permanently installed equipment qualification of the instrument. For such that following a seismic temperature and humidity qualification of event the instrument will maintain its required accuracy.

the displays IEEE 344-2004, IEEE 323-2003, NRG Regulatory Guides 1.100, Revision 3; 1.209, March 2007; and EPRI TR-107330 guidance will be followed. The readout display will be located in the Radwaste Building and is not expected to be subject to harsh environmental or radiological conditions seen in the Reactor Building.

Shock and Vibration - SFPIS pool side brackets will be analyzed for Safe Shutdown Earthquake design requirements per the NRG Order EA 051, the NEI 12-02 guidance and as clarified by the NRG interim staff guidance, the probe, coaxial cable, and the mounting brackets are "inherently resistant to shock and vibration loadings."

As a result, no additional shock and vibration testing is required for these components. SFPIS pool side brackets for both the primary and backup Westinghouse SFP measurement channels will be permanently installed and fixed to rigid refuel floors, which are Seismic Category 1 structures. The SFPI system components, such as level sensor and its bracket, disolav enclosure and its Page 8 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 bracket, will be subjected to seismic testing, including shock and vibration test requirements. The level sensor electronics are enclosed in a NEMA-4X housing. The display electronics panel utilizes a NEMA-4X rated stainless steel housing as well. These housings will be mounted to a seismically qualified wall and will contain the active electronics, and aid in protecting the internal components from vibration induced damage.

b) The seismic adequacy of the SFPIS (all components) will be demonstrated by vendor testing and analysis in accordance with below listed standards:

• IEEE 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1 E Electrical Equipment for Nuclear Power Generating Stations

• IEEE-323-1974, Standard for Qualifying Class 1 E Equipment for Nuclear Power Generating Stations

• USNRC Regulatory Guide 1.100,Rev.3

• USNRC Regulatory Guide 1.92, Rev. 1

• Peach Bottom Calculation -

Seismic Qualification of the SFPIS Indicator Seismic adequacy of the level sensor probe supporting bracket within the SFP area will be demonstrated by analysis as discussed in the response to RAl-3.

c) Westinghouse will seismically qualify the SFPI instrument and its components. With the instrument to be seismically qualified and installed as Page 9 of 26

6 (RAl-5, Ref.4) 7 (RAl-6, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 described in RAI 5b response, including the readout display in the Radwaste Building, the instrument is assured to maintain reliable and accurate indication when required.

The design is targeted for completion by October 31, 2014.

RAI Question:

Started.

Please provide the following:

The two channels of the proposed level measurement system will be installed such a) A description of how the two that:

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

for channel separation.

b) Further information on how b) Detailed design has just begun and is each level measurement system, targeted for completion by October 31, consisting of level sensor 2014.

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.

RAI Question:

Replaced by Interim SE RAI #9.

Please provide the following:

a) A description of the electrical alternating current power sources and capacities for the primary and backup channels.

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 Page 10of26

8 (RAl-7, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 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).

RAI Question:

Complete.

Please provide the following:

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

seismic and post-shock The instrument channels will retain this conditions) that would be accuracy after BDB conditions, in present if the SFP level were at accordance with the above the Level 2 and Level 3 datum Westinghouse documents. This value points.

is within the channel accuracy requirements of the Order (+/-1 foot).

b) A description of the b) The Westinghouse document WNA-TP-methodology that will be used 04709-GEN describes the methodology for determining the maximum for routine testing/calibration verification allowed deviation from the and calibration methodology. This instrument channel design document also specifies the required accuracy that will be employed accuracy criteria under normal under normal operating operating conditions. Peach Bottom conditions as an acceptance Atomic Power Station calibration and criterion for a calibration channel verification procedures will procedure to flag to operators follow the guidance and criteria provided in this document.

and to technicians that the channel requires adjustment to Instrument channel calibration will be within the normal condition performed if the level indication reflects design accuracy.

a value that is outside the acceptance band established in the Peach Bottom Atomic Power Station calibration and channel verification procedures.

Calibration will be performed once per refuelinq cycle for Peach Bottom Page 11of26

9 (RAl-8, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Atomic Power 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.

RAI Question:

Started.

Please provide the following:

a) Westinghouse calibration procedure WNA-TP-04709-GEN and functional a) A description of the capability test procedure WNA-TP-04613-GEN and provisions the proposed describe the capabilities and provisions level sensing equipment will of SFPI periodic testing and calibration, have to enable periodic testing including in-situ testing. Peach Bottom and calibration, including how Atomic Power Station will determine if a this capability enables the different in-situ test methodology is equipment to be tested in-situ.

necessary to accommodate the bracket installation after final bracket design is b) A description of how such completed on October 31, 2014.

testing and calibration will b) The level displayed by the channels will enable the conduct of regular be verified per the Peach Bottom channel checks of each Atomic Power Station operating independent channel against the procedures, as recommended by other, and against any other Westinghouse vendor technical manual permanently-installed SFP level WNA-G0-00127-GEN. If the level is instrumentation.

not within the required accuracy per Westinghouse recommended tolerance c) A description of how in WNA-TP-04709-GEN, channel functional checks will be calibration will be performed.

performed, and the frequency at c) Functional checks will be performed per which they will be conducted.

Westinghouse functionality test Describe how calibration tests procedure WNA-TP-04613-GEN at the will be performed, and the Westinghouse recommended frequency at which they will be frequency. Calibration tests will be conducted. Provide a discussion performed per Westinghouse as to how these surveillances calibration procedure WNA-TP-04709-will be incorporated into the GEN at the Westinghouse plant surveillance program.

recommended frequency.

In accordance with Peach Bottom d) A description of what Atomic Power Station maintenance and preventive maintenance tasks operating programs, Peach Bottom are required to be performed Atomic Power Station will develop during normal operation, and calibration, functional test, channel the planned maximum verification procedures per surveillance interval that is Westinghouse recommendations to Page 12of26

10 (RAl-9, Ref.4) 11 Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 necessary to ensure that the ensure reliable, accurate and channels are fully conditioned to continuous SFPI functionality by March accurately and reliably perform 31, 2015.

their functions when needed.

d) Peach Bottom Atomic Power Station will develop preventive maintenance tasks for the SFPI per Westinghouse recommendation identified in the technical manual WNA-G0-00127-GEN to assure that the channels are fully conditioned to accurately and reliably perform their functions when needed by March 31, 2015.

RAI Question:

Replaced by Interim SE RAI #12.

Please provide the following:

a) The specific location for the primary and backup instrument channel displays.

b) If the primary and backup displays are not located in the main control room, please provide a description of the selected location(s) for the primary and backup displays, including prompt accessibility to displays, 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.

c) The reasons justifying why the locations selected will enable the information from these instruments to be considered "promptly accessible" to various drain-down scenarios and external events.

RAI Question:

Replaced by Interim SE RAI #13.

Page 13of26

(RAl-10, Ref.4) 12 (RAl-11, Ref.4)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Please provide the following:

a) A list of the operating (both 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.

RAI Question:

Complete.

Please provide the following:

Response for a:

a) Further information Performance tests (functional checks) and describing the maintenance and Operator performance checks will be testing program the licensee will described in detail in the vendor operator's 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.

verified by inspection and audit to demonstrate conformance Operator performance tests are planned to be with design and system performed periodically as recommended by the readiness requirements. Please equipment vendor.

include a description of your plans for ensuring that Channel functional tests per operations necessary channel checks, procedures with limits established in functional tests, periodic consideration of vendor equipment calibration, and maintenance will be conducted for the level specifications are planned to be performed at measurement system and its appropriate frequencies established equivalent supporting equipment.

to or more frequently than existing SFPI.

b) A description of how the Manual calibration and operator performance Quidance in NEl12-02, Section checks are planned to be performed in a Page 14 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 4.3 regarding compensatory periodic scheduled fashion with additional actions for one or both non-maintenance on an as-needed basis when functioning channels will be flagged by the system's automated diagnostic addressed.

testing features.

c) A description of what compensatory actions are Channel calibration tests per maintenance planned in the event that one of the instrument channels cannot procedures with limits established in be restored to functional status consideration of vendor equipment within 90 days.

specifications are planned to be performed at frequencies established in consideration of vendor recommendations.

SFPI channel/equipment maintenance/preventative maintenance and testing program requirements to ensure design and system readiness are planned to be 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) of relatively simple and robust augmented quality equipment. Permanent installation coupled with stocking of adequate spare parts reasonably diminishes the likelihood that a single channel (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 are summarized as follows:

Page 15 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Required Channel(s)

Restoration Out-of-Action Se Nice 1

Restore Channel to functional status within 90 days (or if channel restoration not expected within 90 days, then proceed to Compensatory Action 2

Initiate action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore one channel to 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 />.

Compensatory Action if Required Restoration Action not completed within Specified Time Immediately initiate action in accordance with note below Immediately initiate action in accordance with note below Note: Present a report to the on-site Plant Operations Review Committee (PORC) within the following 14 days. The report shall outline the planned alternate method of monitoring, the cause of the non-functionality, and the plans and schedule for restoring the instrumentation channel(s) to functional status.

Page 16 of 26

0 1#

1

{RAl-1, Ref. 5) 2 (RAl-4, Ref. 5) 3 (RAl-5, Ref. 5)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 Draft Safety Evaluation Open Items Description Status RAI Question:

Complete.

Please specify The elevation for Level 1 is 232 ft. 1 O in.

which of the three elevations provided is the correct elevation for Level 1.

RAI Question:

Started.

For RAI 3(a)

The following Westinghouse documents will provide the above, please provide the analyses used to verify the design criteria and describe the analyses used to methodology for seismic testing of the SFP instrumentation verify the design and electronics units, inclusive of design basis maximum criteria and seismic loads and hydrodynamic loads that could result from methodology for pool sloshing and other effects that could accompany such seismic testing of seismic forces:

the SFP instrumentation a) Pool-side Bracket Seismic Analysis {This calculation has and the not been completed. The calculation number will be electronics units, provided October 31, 2014.)

including, design b) LTR-SEE-11-13-47, WNA-TR-03149-GEN - Sloshing basis maximum

Analysis, seismic loads and the hydrodynamic c) EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 -

loads that could Seismic Qualification of other components of SFPI result from pool Peach Bottom Atomic Power Station specific calculations will sloshing or other address the seismic qualification of the indicators located in the effects that could accompany such Radwaste Building. The design criteria that will be used in this seismic calculation satisfies the requirements to withstand a SSE and forces.

will meet the Peach Bottom Atomic Power Station safety related installation requirements for mounting the readout displays in the Radwaste Building.

The design is targeted for completion by October 31, 2014.

RAI Question:

Started.

For each of the The structural integrity and mounting of SFP level equipment mounting will be based on formal calculations, plant drawings, and attachments approved work plans per Exelon procedures and processes.

required to attach SFP level Design Inputs will include, but not limited to, the following:

equipment to plant

1. Component weights and dimensions, anchor hole locations structures, please Page 17of26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 describe the and support details.

design inputs, and

2. The capability of concrete expansion anchors.

the methodology that was used to

3. The loads (dynamic and static) for the probe mounting qualify the bracket.

structural integrity

4. Concrete properties of the affected

5. Seismic accelerations requirements for electrical equipment structures/

equipment.

6. Allowable stresses for structural bolts.

Methodology to qualify the safety related structural integrity will include, but not limited to, the following:

1. Structural Weldments -Qualifying the weld design entails the selection of a weld's physical attributes, such as type, configuration and size, which will make it suitable for transferring the prescribed loads within appropriate limits.

This process involves determining the maximum unit forces on the weld and comparing them with the weld capacity. The methodology determines weld design forces by assuming nominal linear stress/strain distribution. For each design, the engineer must confirm that the distribution of stiffness within the joint is consistent with this assumption. In some cases more refined techniques may be required to predict appropriate distribution of weld forces.

2. Concrete Expansions - The design methodology of concrete expansion anchor assemblies involves 1) application of component attachment loads to the plate, 2) analysis of the assembly to determine the resultant tension and shear forces on individual anchors, 3) evaluation of the anchor forces relative to anchor allowables and 4) computation and evaluation of bending stresses in the CEA plate. Reactions for the attached component (applied to the plate at the centroid of the attachment weld) shall be resolved into moments, shears and axial loads (about the major axes of the expansion anchor plate).

3. Local Stress Effects - The member local stresses for open sections are computed according to specific procedures for flange attachments, web attachments, attachments to flanges of beams supporting concrete, and attachments to webs of beams supporting concrete.

4. Existing Embedment Plate Evaluation - Embedment plates for mechanical/electrical component support attachments (i.e., pipe supports, conduit supports, HVAC supports, etc.)

are evaluated as follows:

• Determine embedment plate detail based on the Page 18 of 26

4 (RAl-7, Ref. 5)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August 28, 2014 RAI Question:

For RAI 6 above, please provide the results for the selected methods, tests and analyses used to demonstrate the qualification and reliability of the installed equipment in accordance with the Order requirements.

component support design drawing and appropriate structural drawings.

Determine an allowable load for the embedment plate detail per plant design tables.

Ensure that the attachment location satisfies the location tolerances used in determining the embedment plate allowables.

Calculate reactions at face of embedment plate.

Determine if the embedment plate can be qualified per criteria.

5. Conduit and Conduit Supports - Structural adequacy of rigid conduit is evaluated by determining the critical span condition, loads, checking conduit stresses and verifying structural adequacy of conduit clamps. Structural adequacy of Conduit, Junction Boxes and Junction Box supports is evaluated by determining loads, calculating member forces and joint reactions, checking member stresses, checking connections, checking expansion anchor assemblies, checking attachments to structure and resolving overstresses.

6. Cable Tray Loading Violations (CTLVs) - The structural evaluation of cable tray supports for potential increase in design basis loading will be performed by identifying the hangers affected by the routing point. For each affected hanger controlling routing point will be determined. Then actual load associated with the routing point will be computed. Then the actual load will be compared to the load used in the hanger design. An evaluation of cable tray hanger for any increased load will be performed.

Detailed design is targeted for completion completed by October 31, 2014.

Started Some RAl's have been renumbered. This question refers to RAl-4, Reference 4.

Below is a summary of the test conditions used by Westinghouse to qualify the SFPIS. These test conditions are also documented in Attachment 2 items 3, 4, 5, 6, 7, and 8.

Environmental Conditions for SFPIS Components installed in the Spent Fuel Pool Area at Peach Bottom Atomic Power Station are bounded by below test conditions, except for radiation TID 12" above top of fuel rack for beyond design basis conditions (BDB). The BDB radiation TID, 12" above top of fuel rack for Peach Bottom is 4.E07 Ry, per calculation BYR13-051 - NEI 12-02 Spent Fuel Pool Doses. The BDB radiation value to which the Westinghouse equipment is qualified to is 1.E07 Ry, per Section 5.1.1 of WNA-TR-03149-GEN. The radiation value of 4.E07 Ry is higher than 1.E07 R Page 19 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 y to which Westinghouse qualified the instrument to. However, this value of 4.E07 Ry is applicable only when the water is at Level 3. At Level 2 the TIO reduces to 2.E07 Ry and it further reduces to 8.E06 at Level 1 and above. With SFP water level at Level 3 the only components of SFPI that are exposed to high radiation are the stainless steel probe and the stainless steel anchor. The materials with which the probe and the anchor are manufactured are resistant to radiation effects.

The stainless steel anchor and stainless steel probe can withstand 40 year dose. Westinghouse updated the design specification (WNA-OS-02957-GEN) and L TR-SFPIS-13-35, Revision 1 documentation to include the above technical justification.

Environmental Conditions for SFPIS Components in the Spent Fuel Pool Area Level sensor probe, coax coupler and connector assembly, launch plate and pool side bracket assembly, coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Parameter Normal BOB Temperature 65-109.7 °F 212 °F Pressure

-0.25 "we Atmospheric Humidity 100%

10-90% RH (saturated steam)

Radiation TIO y 1E03 Rads 1E07 Rads (above pool)

Radiation TIO y 1 E09 Rads

( 12" above top of fuel (probe and 1E07 Rads rack) weight only)

Environmental Conditions Outside of the Spent Fuel Pool Area The level sensor transmitter and bracket, electronics display enclosure and bracket are designed and qualified to operate reliably in the below specified environmental conditions.

Page 20 of 26

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Parameter Normal BDB Temperature 65-107.1 65-107.1 °F OF Pressure Atmospheric Atmospheric Humidity 0-95%

0-95% RH (non-condensing)

Duration 3 days 3 days Radiation s 1 E03 Ry s 1E03 R TID y BDB (Level Sensor Electronics Only)65-107.1 OF Atmospheric 0-95%

(non-condensing) 3 days s 1 E03 R Thermal and Radiation Aging - Organic Components in SFP Area Westinghouse documents EQ-QR-269, EQ-TP-354, WNA-TR-03149-GEN provide thermal and radiation aging program details for the SFPI components. Westinghouse completed their thermal and radiation aging testing programs to qualify the SFPI components to 1.25 years. Exelon has reviewed the documents and found acceptable.

Additionally, Westinghouse is continuing their aging tests to age the system components to 1 o years. These tests are projected to be completed towards end of Summer 2014. Final test reports are scheduled to be provided to Exelon by September 4, 2014. Exelon has targeted the test report reviews by September 30, 2014.

Seismic Category I Testing Seismic qualification testing performed by Westinghouse along with the technical evaluations performed by Westinghouse confirms that the SFPIS meets the seismic requirements of the vendor's design specification document WNA-DS-02957-GEN.

Westinghouse's design specification satisfies the Peach Bottom Atomic Power Station installation requirements to withstand a SSE.

Vibration Justification Page 21of26

5 (RAl-9, Ref. 5) 6 Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 RAI Question:

Please provide the following:

a) A description of the electrical ac power sources and capacities for the primary and channels.

backup b) Please provide the results of the calculation depicting battery duty the backup cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until off site resource availability is reasonably assured.

RAI Question:

As specified in RAl-5, components of the system (i.e., bracket, transmitter, display enclosure) will be permanently installed to meet the requirements to withstand a SSE and will meet the Peach Bottom Atomic Power Station safety related installation requirements. Westinghouse has analyzed the pool side bracket to withstand design basis SSE. Other components of the SFPIS were subjected to shock and vibration during the seismic testing and met the requirements necessary for mounted equipment.

Sloshing Justification The sloshing calculation performed by Westinghouse in document L TR-SEE-11-13-47 was reviewed for a design basis seismic event and found acceptable.

Sloshing forces were taken into consideration for the anchorage design of the pool side bracket to ensure the bracket is rigidly mounted to include sloshing affects.

Started.

a) Detailed design has begun but this information is not yet available. The detailed design is targeted for completion by October 31, 2014.

b) The 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 of the display, located in the 165 foot elevation of the Radwaste Building. The results of the calculation meet the NEI 12-02 requirements.

Complete.

Page 22 of 26

(RAl-12, Ref. 5)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 Please provide the following:

a) The primary and backup instrument channels will be located in the Fan Room on the 165 foot elevation of the Radwaste Building which is directly behind (West of) the Main Control Room. Unit 2 channels with be in the southern half of the room and the Unit 3 channels will be in the northern half.

a)

The specific location for the primary and backup instrument b) channel display.

b) For any SFP level instrumentation displays located outside the main control

room, please describe the evaluation used to validate that the display location can be accessed 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-through) 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 The primary and backup instrument channel displays will be located outside of the control room and alternate shutdown panel as described above. This location was selected due to the display location proximity to the main control room.

Radiological habitability at this location has been evaluated against Peach Bottom Atomic Power Station UFSAR section 12.3, Radiation Shielding, as well as estimated dose rates from SFP drain-down conditions to level 3, (calculation BYR13-187) and exposure to personnel monitoring SFP levels would remain less than emergency exposure limits allowable for emergency responders to perform this action.

The location is at an elevation below the SFP operating floor and located in a different building physically separated by concrete walls, closed air lock/fire doors from the SFP such that heat and humidity from a boiling SFP would not comprise 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 less than 5 minutes based on walkdowns.

Radiological habitability for the transit routes to both displays has been evaluated against Peach Bottom Atomic Power Station UFSAR section 12.3, Radiation Shielding, as well as estimated dose rates from SFP drain-down conditions to Level 3, (calculation BYR13-187) and exposure to personnel monitoring SFP levels would remain less than emergency exposure limits allowable for emergency responders to perform this action. The access routes are below the SFP operating floor and located in a different building physically separated by closed air lock/fire doors from the SFP such that heat and humidity from a boiling SFP would not compromise habitability concerns with accessing these displays.

Diverse communication methods are available for operators to contact the control room to provide the SFP level from the display location, for both the primary and backup channels displays.

The display will be accessed on demand. It takes up to 5 minutes to reach the display 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 walkdowns. The walk to access the Page 23 of 26

7 (RAl-13, Ref. 5)

Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 environmental conditions following a BOB event.

Describe whether personnel are continuously stationed at the display or monitor the display periodically.

RAI Question:

Please provide a

list of the procedures 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.

display locations is through a short distance of the 165 foot elevation of the turbine building and then into the robust seismic category I structures to the display locations, located in the Fan Room directly behind the Main Control Room. The operator can access the fan room from either the Unit 2 or Unit 3 side. Being able to provide the indicated SFP level within approximately 10 minutes is not considered an unreasonable delay.

Started.

Site procedures will be developed for system inspection, calibration and test, maintenance, operation and normal and abnormal responses, in accordance with Exelon's procedure control process. Technical objectives to be achieved in each of the respective procedures are described below:

Procedure Objectives to be achieved:

1. System Inspection: To verify that visible portions of system components are in place, complete, and in the correct configuration.

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. Operation: To provide sufficient instructions for operation and use of the system by plant operation staff.

5. 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.

Procedure creation will be completed by March 31, 2015.

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

Page 24of26

8 References Peach Bottom Atomic Power Station, Units 2 and 3 Third Six-Month Status Report for the Implementation of SFPLI August28,2014 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 034)

2. NRG 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 24, 2013.

4. Exelon Generation Company, LLC, letter to USN RC, "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 19, 2013 (RS-13-178)

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 30, 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-13-126).

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 February 28, 2014 (RS-14-024).

Page 25 of 26

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