RS-15-032, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML15058A254
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/27/2015
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-15-032
Download: ML15058A254 (31)
v • d • e


Text

Order No. EA-12-051 RS-15-032 February 27, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"

Revision 0, dated August 29, 2012

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012
4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 25, 2012
5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2013 (RS-13-034)
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 Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28, 2014 (RS 024)
8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated August 28, 2014 (RS-14-202)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 2015 Page2

9. NRC 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 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 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, 7, and 8 provided the first, second, and third 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 fourth 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 9.

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 27'h day of February 2015.

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

Enclosure:

1. Peach Bottom Atomic Power Station, Units 2 and 3 Fourth 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 27, 2015 Page 3 cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region I NRC Senior Resident Inspector Peach Bottom Atomic Power Station, Units 2 and 3 NRC Project Manager, NRR Peach Bottom Atomic Power Station, Units 2 and 3 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Stephen R. Monarque, NRR/JLD/PMB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. Richard B. Ennis, NRR/DORULPL3-2, NRC Mr. Peter J. Bamford, NRR/JLD/PPSD/JOMB, NRC 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 Fourth Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (27 pages)

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 Enclosure Peach Bottom Atomic Power Station, Units 2 and 3 Fourth 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 NRC Order EA-12-051 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the third 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 third six month status report (Reference 8), and are current as of January 31, 2015.

  • None 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 Response to RAls July 19, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Page l of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 Update 2 February 28, 2014 Complete Update 3 August 28, 2014 Complete Provide Final Safety Evaluation September 30, 2014 Complete (SE) Info Complete with Update 4 February 28, 2015 this submittal 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 tor Unit 3 and Unit 2 I Complete and Issue SFPI I 302014 Started 102015 Modification Package tor Unit 3 Complete and Issue SFPI 302014 Started 102015 Modification Package for Unit 2 Begin SFPI Installation tor 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 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 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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.

I Overall Integrated Plan Open Items I

01# Description Status I

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 Level1, Level2,and Level3 datum points.

Page 3 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 3 RAJ Question: Started.

(RAl-2, Please provide a clearly labeled Please see Attachment 1 for the sketch which Ref. 4) sketch or marked-up plant shows 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 inside targeted for completion by March 31, 2015.

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.

4 RAI Question: Started.

(RAl-3, Please provide the following: a) All SFPIS equipment will be designed Ref. 4) 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. I 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 in the bracket assembly, considers load hydrodynamic loads that could combinations for the dead load, live result from pool sloshing or other load and seismic load on the bracket.

effects that could accompany The reactionary forces calculated from such seismic forces.

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 The seismic loads are obtained from portions of the level sensor that Peach Bottom Atomic Power Station's will serve as points of attachment UFSAR Appendix C Section 2.6, for mechanical/mounting or including dead, live, and earthquake electrical connections.

loads. This section has been c) A description of the manner transmitted to the vendor, by which the mechanical Westinghouse, for input to their design connections will attach the level analysis. The following methodology instrument to permanent SFP Page 4 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 structures so as to support the will be used in determining the stresses level sensor assembly. on the bracket 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 (Sate 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. NRC 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 (SRSS) 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 usinq the Page 5 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report tor the Implementation of SFPLI February 27, 2015 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. PS-1115, Seismic Analysis of the SFP Primary Mounting Bracket Units 2 & 3
b. PS-1116, Seismic Analysis of the SFP Backup Mounting Bracket Units 2 & 3
c. LTR-SEE-11-13-47, WNA-TR-03149-GEN - Sloshing Analysis
d. EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 - Seismic Qualification of other components of SFPI Peach Bottom Atomic Power Station calculation PS-1123 addresses 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 6 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 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 computation -

Reactor Building (RB) Primary and Backup Spent Fuel Pool Instrumentation System (SFPIS)

Baseplate and Anchorage Evaluation Units 2 and 3.

The design is targeted for completion by March 31, 2015.

5 RAI Question: Started.

(RAl-4, Please provide the following: a) Beyond Design Basis Environment -

Ref. 4) 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 fallowing a plant design basis reliably under the worst-case earthquake.

credible design basis loading at Mild Environment -Westinghouse will the location where the Page 7 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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 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, electronics, or read-out and re- those conditions. Westinghouse will transmitting devices that will be confirm that aging does not have a employed to convey the level significant effect on the ability of the 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 such that following a seismic qualification of the instrument. For event the instrument will temperature and humidity qualification of maintain its required accuracy. the displays IEEE 344-2004, IEEE 323-2003, NRC 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 NRC Order EA 051, the NEI 12-02 guidance and as clarified by the NRC 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 riaid refuel floors, which are Page 8 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 Seismic Category 1 structures. The SFPI system components, such as level sensor and its bracket, display enclosure and its 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 1E Electrical Equipment for Nuclear Power Generating Stations
  • IEEE-323-1974, Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations
  • Peach Bottom Calculation PS-1123 - Seismic Qualification of the Spent Fuel Pool Level Instrumentation System Equipment Seismic adequacy of the level sensor probe supporting bracket within the SFP area will be demonstrated by analvsis as discussed in the response Page 9 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 to RAl-3.

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

I I The design is targeted for completion by I March 31, 2015.

6 RAI Question: Started. Target completion date is March 31, Please provide the following:

2015.

(RAl-5, Ref. 4) The two channels of the proposed level a) A description of how the two measurement system will be installed such channels of the proposed level that:

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

meets the NEI 12-02 Revision 1 guidance for channel separation.

b) Further information on how each level measurement system, b) The signal cables from the level probes consisting of level sensor will maintain physical separation for the electronics, cabling, and readout routing on the refuel floor. After they devices will be designed and penetrate the refuel floor their proximity installed to address independence will increase as they are routed to the through the application and level transmitters located in the Radwaste selection of independent power Building Fan Room. Maintaining sources, the use of physical and separation in this area is not necessary as spatial separation, independence it is in the Reactor Building; also, the of signals sent to the location(s) signal cables will be in separate conduits of the readout devices, and the for the entire route.

independence of the displays.

The Unit 2 level transmitters and electronics enclosures are located in the south end of the Radwaste Building Fan Room while the Unit 3 level transmitters and electronics enclosures are located in the north end of the Radwaste Building Fan Room. The Radwaste Building Fan Room is a location readily accessible by operators during a postulated BDBEE.

The primary channels of both Unit 2 and Unit 3 receive power from 120VAC power Page 10 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report tor the Implementation of SFPLI February 27, 2015 distribution panel 20Y035. The backup channels of both Unit 2 and Unit 3 receive power from 120VAC power distribution panel 30Y035. Both power sources, 20Y035 and 30Y035, are fed from safety-related Division 1 MCCs. Furthermore, both of the MCCs that feed the power sources are backed up by a power supply which is part of the station FLEX strategy.

Each of the four power feeds is routed in its' own conduit.

7 RAI Question: Replaced by Interim SE RAI #9.

(RAl-6, Please provide the following:

Ref. 4) 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 design criteria that will be applied to size the battery in a manner that ensures, with margin, that the channel will be available to run reliably and continuously following the onset of the BOB event for the minimum duration needed, consistent with the plant mitigation strategies for BOB external events (Order EA 049).

8 RAI Question: Complete.

(RAl-7, Please provide the following: (Addressed in Reference 8)

Ref. 4) a) An estimate of the expected instrument channel accuracy performance under both (i) normal SFP level conditions (approximately Level 1 or higher) and (ii) at the BOB conditions Page 11of27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 (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 operating conditions as an acceptance criterion for a calibration procedure to flag to operators and to technicians that the channel requires adjustment to within the normal condition design accuracy.

9 RAI Question: Started.

(RAl-8, Please provide the following: a) Westinghouse calibration procedure Ref. 4) 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 different in-situ test methodology is this capability enables the necessary to accommodate the bracket equipment to be tested in-situ.

installation after final bracket design is completed on February 28, 2015.

b) A description of how such 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 WNA-G0-00127-GEN. If the level is permanently-installed SFP level not within the required accuracy per instrumentation.

Westinghouse recommended tolerance in WNA-TP-04709-GEN, channel c) A description of how calibration will be performed.

functional checks will be 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 frequencv. Calibration tests will be Page 12 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 frequency at which they will be performed per Westinghouse conducted. Provide a discussion calibration procedure WNA-TP-04709-as to how these surveillances GEN at the Westinghouse will be incorporated into the recommended frequency.

plant surveillance program. In accordance with Peach Bottom Atomic Power Station maintenance and d) A description of what operating programs, Peach Bottom preventive maintenance tasks Atomic Power Station will develop, by are required to be performed March 31, 2015, calibration, functional during normal operation, and the test, and channel verification planned maximum surveillance procedures per Westinghouse interval that is necessary to recommendations to ensure reliable, ensure that the channels are accurate and continuous SFPI fully conditioned to accurately functionality.

and reliably perform their d) Peach Bottom Atomic Power Station functions when needed. will develop, by March 31, 2015, 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.

10 RAI Question: Replaced by Interim SE RAI #12.

(RAl-9, Please provide the following:

Ref. 4) 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 I 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.

Page 13 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six*Month Status Report for the Implementation of SFPLI February 27, 2015 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.

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

(RAl-10, Please provide the following:

Ref. 4) 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.

12 RAI Question: Complete.

(RAl-11, Please provide the following: Peach Bottom revised the compensatory action plan requirements applicable to Ref. 4) conditions where the instrument channel(s) are a) Further information describing the maintenance and testing not restored to functional status within the specified time, as specified in the Note. The program the licensee will condition will be entered into the corrective establish and implement to action program in lieu of a report to PORC.

ensure that regular testing and calibration is performed and Response for a:

verified by inspection and audit Performance tests (functional checks) and to demonstrate conformance Operator performance checks will be with design and system readiness requirements. Please described in detail in the vendor operator's include a description of your manual, and the applicable information is Page 14 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 plans for ensuring that planned to be contained in plant operating necessary channel checks, procedures.

functional tests, periodic calibration, and maintenance will Operator performance tests are planned to be be conducted for the level performed periodically as recommended by the measurement system and its equipment vendor.

supporting equipment.

Channel functional tests per operations b) A description of how the guidance in NEl12-02, Section 4.3 procedures with limits established in regarding compensatory actions consideration of vendor equipment for one or both non-functioning specifications are planned to be performed at channels will be addressed. appropriate frequencies established equivalent c) A description of what to or more frequently than existing SFPI.

compensatory actions are planned in the event that one of Manual calibration and operator performance the instrument channels cannot checks are planned to be performed in a be restored to functional status periodic scheduled fashion with additional within 90 days. maintenance on an as-needed basis when flagged by the system's automated diagnostic testing features.

Channel calibration tests per maintenance procedures with limits established in consideration of vendor equipment 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 Page 15 of27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 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:

  1. Required Compensatory Channel(s) Restoration Action if Out-of- Action Required Service Restoration Action not completed within Specified Time 1 Restore Immediately Channel to initiate action functional in accordance status within with note 90 days (or if below channel restoration not expected within 90 days, then proceed to Compensatory Action) 2 Initiate action Immediately within 24 initiate action hours to in accordance restore one with note channel to below functional Page 16 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 I 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 />.

Note: Initiate an Issue Report to enter the condition into the Corrective Action Program.

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

Draft Safety Evaluation Open Items 01# Description Status 1 RAI Question: Complete.

(RAl-1, Please specify (Addressed in Reference 7)

Ref. 5) which of the three elevations provided is the correct elevation for Level 1.

2 RAI Question: Started.

For RAI 3(a)

(RAl-4, above, please The following Exelon and Westinghouse documents will Ref. 5) provide the provide the analyses used to verify the design criteria and analyses used to describe the methodology for seismic testing of the SFP verify the design instrumentation and electronics units, inclusive of design basis criteria and maximum seismic loads and hydrodynamic loads that could methodology for result from pool sloshing and other effects that could seismic testing of accompany such seismic forces:

the SFP instrumentation a) PS-1115, Seismic Analysis of the SFP Primary Mounting and the Bracket Units 2 & 3 electronics units, b) PS-1116, Seismic Analysis of the SFP Backup Mounting including, design Bracket Units 2 & 3 basis maximum seismic loads and c) LTR-SEE-11-13-47, WNA-TR-03149-GEN - Sloshing the hydrodynamic Analysis, loads that could Page 17of27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 result from pool d) EQ-QR-269, WNA-TR-03149-GEN, EQ-TP-353 -

sloshing or other Seismic Qualification of other components of SFPI effects that could Peach Bottom Atomic Power Station calculation PS-1123, accompany such seismic Seismic Qualification of the Spent Fuel Pool Level forces. Instrumentation System Equipment, addresses the seismic qualification of the indicators located in the Radwaste Building.

The design criteria that will be used in this calculation satisfies the requirements to withstand a SSE and 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 March 31 2015.

3 RAI Question: Started.

(RAl-5, For each of the The structural integrity and mounting of SFP level equipment Ref. 5) 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 and support details.

describe the design inputs, and 2. The capability of concrete expansion anchors.

the methodology 3. The loads (dynamic and static) for the probe mounting that was used to bracket.

qualify the

4. Concrete properties structural integrity of the affected 5. Seismic accelerations requirements for electrical equipment structures/ 6. Allowable stresses for structural bolts.

equipment.

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 Page 18 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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 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 aft ected by the routing point. For each affected hanger controlling routing point will be determined. Then actual load associated with the routinq point will be computed. Then the Page 19 of27

Peach Bottom Atomic Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 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 by March 31, 201 4 RAI Question: Started Expected Completion Date is March 31, 201 (RAl-7, For RAI 6 above, Some RAls have been renumbered. This question refers to Ref. 5) please provide the RAl-4, Reference 4.

resutts for the selected methods, Below is a summary of the test conditions used by Westinghouse to qualify the SFPIS. These test conditions are tests and analyses I also documented in Attachment 2 items 3, 4, 5, 6, 7, and 8. [

used to Environmental Conditions for SFPIS Components installed in demonstrate the the Spent Fuel Pool Area at Peach Bottom Atomic Power qualification and Station are bounded by below test conditions, except for reliability of the radiation TID 12" above top of fuel rack for beyond design installed basis conditions (BDB). The BDB radiation TID, 1 above top equipment in of fuel rack for Peach Bottom is 3.E07 Ry, per calculation PM*

accordance with 1176 NEI 12-02 Spent Fuel Pool Doses. The BDB radiation the Order value to which the Westinghouse equipment is qualified to is requirements. 1.E07 Ry, per Section 5.1.1 of WNA-TR-03149-GEN. The radiation value of 3.E07 R y is higher than 1.E07 R y to which Westinghouse qualified the instrument. However, this value of 3.E07 Ry is applicable only when the water is at Level 3. At Level 2 the TID reduces to 2.E07 Ry and it further reduces to 7.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-DS-02957-GEN) and LTR-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, and coax cable are designed and qualified to operate reliably in the below specified environmental conditions.

Parameter Normal BDB Temperature 65- 109.7 °F 212 °F Pressure -0.25 "we Atmospheric Humidity 10-90% RH 100%

(saturated Page 20 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 2015 steam)

Radiation Tl D y 1E03 Rads 1E07 Rads (above pool)

Radiation Tl D y 1E09 Rads

( 12" above top of fuel 1E07 Rads (probe and 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.

BOB (Level Sensor Parameter Normal BOB Electronics Only)

Temperature 65-107.1 65-107.1 65 - 107.1 °F OF OF Pressure Atmospheric Atmospheric Atmospheric Humidity 0-95% 0-95%

0-95% RH (non- (non-condensing) condensing)

Duration 3 days 3 days 3 days Radiation $ 1E03 Ry $ 1E03 R $ 1E03 R TIDy 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 Page 21of27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 and found them acceptable.

Additionally, Westinghouse has completed their aging tests to age the system components to 1O years. The tests were completed satisfactorily for Byron Station's configuration and the final test reports were reviewed and found acceptable by Exelon for Peach Bottom.

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 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 satety 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 LTR-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.

5 RAI Question: Complete.

(RAl-9, Please provide the a) The primary channels of both Unit 2 and Unit 3 receive Ref. 5) following: power from 120VAC power distribution panel 20Y035.

a) A description of The backup channels of both Unit 2 and Unit 3 receive the electrical ac power from 120VAC power distribution panel 30Y035.

power sources and Both power sources, 20Y035 and 30Y035, are fed from capacities for the safety-related Division 1 MCCs. Furthermore, both of primary the MCCs that feed the power sources are backed up by and backup a power supply which is part of the station FLEX channels. strategy. Each of the four power feeds is routed in its' Page 22 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 b) Please provide own conduit.

the results of the Westinghouse document WNA-CN-003~0-GEN state~

calculation that the maximum load of each electronics enclosure 1s depicting the 0.696 amps. Each power feed is protected at the source battery backup by a 1 amp fast blow fuse. The power feed cables are duty 2/C #1 O copper conductor cables which are capable of cycle requirements carrying 40 amps.

demonstrating that its capacity is b) The Westinghouse Report, WNA-CN-00300-GEN, sufficient to provides the results of the calculation depicting the maintain the battery backup duty cycle. This calculation level indication demonstrates that battery capacity is 4.22 days to function until maintain the level indicating function of the display, offsite resource located in the 165 foot elevation of the Radwaste availability is Building. The results of the calculation meet the NEI 12-reasonably 02 requirements.

assured.

6 RAI Question: Complete.

(RAI- Please provide the (Addressed in Reference 8) 12, following:

Ref. 5) a) The specific I location for the primary and backup instrument 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 Page 23 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 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 periodicallv.

7 RAI Question: Started.

(RAI- Please provide a Site procedures will be developed for system inspection, list of the calibration and test, maintenance, operation and normal and 13, abnormal responses, in accordance with Exelon's procedure procedures Ref. 5) control process. Technical objectives to be achieved in each of addressing operation (both the respective procedures are described below:

normal and Procedure Objectives to be achieved:

abnormal response), 1. System Inspection: To verify that visible portions of calibration, test, system components are in place, complete, and in maintenance, and the correct configuration.

inspection 2. Calibration and Test: To verify, that the system is procedures that will within the specified accuracy, is functioning as be developed for designed, and is appropriately indicating SFP water use of the SFP level.

instrumentation.

The licensee is 3. Maintenance: To establish and define scheduled and requested to preventive maintenance requirements and activities include a brief necessary to minimize the possibility of system description of the interruption.

specific technical 4. Operation: To provide sufficient instructions for Page 24 of 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015 objectives to be operation and use of the system by plant operation achieved within staff.

each procedure.

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 August 31, 2015.

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

8 References The following references support the updates to the Overall Integrated Plan described in this enclosure.

1. Exelon Generation Company, LLC, letter to USNRC, "Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 )," dated February 28, 2013 (RS-13-034).
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 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 19, 2013 (RS-13-178).
5. USN RC letter to Exelon Generation Company, LLC, "Interim Staff Evaluation and Request tor Additional Information Regarding the Overall Integrated Plan tor Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation", dated October 30, 2013.
6. First Six-Month Status Report tor 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 27

Peach Bottom Atomic Power Station, Units 2 and 3 Fourth Six-Month Status Report for the Implementation of SFPLI February 27, 2015

8. Third Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated August 28, 2014 (RS-14-202).

Page 26 of 27

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