RS-14-024, 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)

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)

ML14059A227
Person / Time
Site:	Peach Bottom
Issue date:	02/28/2014
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-024
Download: ML14059A227 (19)

Text

RS-14-024 February 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 NRC Docket Nos. 50-277 and 50-278

Subject:

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

References:

1. NRC Order Number EA-12-051, " Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12,2012 2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012 3. NE112-02, 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. 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 U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page 2 On March 12, 2012, the Nuclear Regulatory Commission

("NRC" or "Commission")

issued an order (Reference

1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to install reliable spent fuel pool level instrumentation.

Specific requirements are outlined in Attachment 2 of Reference

1. Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference

2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-02, Revision 1 (Reference

3) with clarifications and exceptions identified in Reference

2. Reference 4 provided the EGC initial status report regarding reliable spent fuel pool instrumentation.

Reference 5 provided the 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. Reference 6 provides the first six-month status report 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 second six-month status report pursuant to Section IV, Condition C.2, of Reference 1 , that delineates progress made in implementing the requirements of Reference

1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference

7. This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28 th day of February 2014. Respectfully submitted, David P. Helker Manager -Licensing

& Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of Order EA-12-051 , Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-0S1 February 28, 2014 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. Greg A. Casto, NRR/DSS/SBPB, NRC Mr. Richard B. Ennis, NRR/DORULPL3-2, 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 Second Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (15 pages)

Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1 Introduction 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 first six month status report including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any. 2 Milestone Accomplishments The following milestones have been completed since the development of the First six month status report (Reference 6), and are current as of January 31,2014.

• Begin detailed design engineering design for Unit 3 and Unit 2 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 I ntegrated Plan February 28, 2013 Complete Submit Response to RAls July 19, 2013 I Complete Submit 6 Month Updates: Update 1 August 28, 2013 Complete Update 2 February 28,2014 Complete with this submittal Page 1 of 15 Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Milestone Target Completion Activity Date Status Update 3 August 28, 2014 Not Started Provide Final Safety Evaluation September 30, 2014 Not Started (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 202014 Not Started Modification Package for Unit 3 Complete and Issue SFPI 202015 Not 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 SFPllnstaliation 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 Revised Target I Completion Date 302014 302014 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 15 Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 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 Interim Staff Evaluation (ISE) and the status of each item. 01# 1 (Ref. 1 ) 2 (RAI-1, Ref. 4) Overall Integrated Plan Open Items Description Status Open Item: Complete.

Continuous level indication will be (Addressed in Reference

6) 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. RAI Question:

Complete.

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

4) identified location represents the HIGHER of the two pOints described in the NE112-02 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, Level 2, and Level 3 datum points. Page 3 of 15 3 (RAI-2, Ref.4) 4 (RAI-3, Ref.4) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 2014 RAI Question:

Not Started. Please provide a clearly labeled sketch The requested information for both Unit 2 or marked-up plant drawing of the plan and Unit 3 will be provided by September view of the SFP area, depicting the 30, 2014 in accordance with the ISE SFP inside dimensions, the planned locations/placement of the primary and (Reference 5). backup SFP level sensor, and the proposed routing of the cables that will extend from the sensors toward the location of the read-out/display device. RESPONSE:

Final sensor locations and cable routings are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

Please provide the following:

a) The design criteria that will be used to estimate the total loading on the mounting device(s), including static weight loads and dynamic loads. Describe the methodology that will be used to estimate the total loading, inclusive of design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces. b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.

Indicate in a schematic the portions of the level sensor that will serve as Page 4 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

5 (RAI-4, Ref.4) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 points of attachment for mechanical/mounting or electrical connections.

c) A description of the manner by which the mechanical connections will attach the level instrument to permanent SFP structures so as to support the level sensor assembly.

RESPONSE:

Mounting device total loading and attachments are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

Please provide the following:

a) A description of the specific method or combination of methods that will be applied to demonstrate the reliability of the permanently installed equipment under beyond-design-basis (BOB) ambient temperature, humidity, shock, vibration, and radiation conditions.

b) A description of the testing and/or analyses that will be conducted to provide assurance that the equipment will perform reliably under the worst-case credible design basis loading at the location where the equipment will be mounted. Include a discussion of this seismic reliability demonstration as it applies to (i) the level sensor mounted in the SFP area, and (ii) any control boxes, electronics, or read-out and transmitting devices that will be employed to convey the level information from the level sensor to Page 5 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

6 (RAI-5, Ref A) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28,2014 the plant operators or emergency responders.

c) A description of the specific method or combination of methods that will be used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy.

RESPONSE:

Equipment reliability qualification information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

Please provide the following:

a) A description of how the two channels of the proposed level measurement system meet this requirement so that the potential for a common cause event to adversely affect both channels is minimized to the extent practicable.

b) Further information on how each level measurement system, consisting of level sensor electronics, cabling, and readout devices will be designed and installed to address independence through the application and selection of independent power sources, the use of physical and spatial separation, independence of signals sent to the location(s) of the readout devices, and the independence of the displays.

RESPONSE:

Page 6 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5). I 7 (RAI-6, Ref A) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 Channel independence information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

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 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-12-049). RESPONSE:

Equipment total power supply configuration and characteristics are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion Page 7 of 15 Replaced by Interim SE RAI #9 The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

8 (RAI-7, Ref.4) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28,2014 and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

Please provide the following:

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 (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 operati ng 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.

RESPONSE:

Channel accuracy information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). Page 8 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

9 (RAI-8, Ref A) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 2014 RAI Question:

Please provide the following:

a) A description of the capability and provisions the proposed level sensing equipment will have to enable periodic testing and calibration, including how this capability enables the equipment to be tested in-situ. b) A description of how such testing and calibration will enable the conduct of regular channel checks of each independent channel against the other, and against any other permanently-installed SFP level instrumentation.

c) A description of how functional checks will be performed, and the frequency at which they will be conducted.

Describe how calibration tests will be performed, and the frequency at which they will be conducted.

Provide a discussion as to how these surveillances will be incorporated into the plant surveillance program. d) A description of what preventive maintenance tasks are required to be performed during normal operation, and the planned maximum surveillance interval that is necessary to ensure that the channels are fully conditioned to accurately and reliably perform their functions when needed. RESPONSE:

Equipment testing, calibration, functional checks and maintenance requirements are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design Page 9 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

10 (RAI-9, RetA) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 completion and 100% acceptance of the design in September 2014. Procedures will start being developed, early in the process, in parallel with the design efforts. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

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 mai n 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. RESPONSE:

Channel display location information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. The requested information will be provided Page 10 of 15 Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September 30, 2014 in accordance with the ISE (Reference 5).

11 (RAI-10, Ref.4) 12 (RAI-11, Ref.4) Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 2014 by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

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. RESPONSE:

Procedural details are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 1 00% acceptance of the design in September 2014. Procedures will start being developed, early in the process, in parallel with the design efforts. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). RAI Question:

Not Started. The requested information for both Unit 2 and Unit 3 will be provided by September I 30, 2014 in accordance with the ISE (Reference 5). Not Started. Please provide the following:

The requested information for both Unit 2 a) Further information describing the and Unit 3 will be provided by September maintenance and testing program 30, 2014 in accordance with the ISE Page 11 of 15 Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 the licensee will establish and (Reference 5). implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements.

Please include a description of your plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment.

b) A description of how the guidance in NEI12-02, Section 4.3 regarding compensatory actions for one or both non-functioning channels will be addressed.

c) A description of what compensatory actions are planned in the event that one of the instrument channels cannot be restored to functional status within 90 days. RESPONSE:

Testing and calibration program requirements and compensatory actions are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current plan for the design of the SFPLI system based on the current Exelon Nuclear program schedule for Peach Bottom is to start the design phase for Unit 3 and Unit 2 in January 2014 with design completion and 100% acceptance of the design in September 2014. Procedures will start being developed, early in the process, in parallel with the design efforts. The requested information will be provided by September 30, 2014 in accordance with the ISE (Reference 5). Page 12 of 15 01# Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28,2014 Interim Safety Evaluation Open Items Description Status 1 RAI Question: (RAI-1, Ref. 5) 2 (RAI-4, Ref. 5) 3 (RAI-5, Ref. 5) 4 (RAI-?, Ref. 5) 5 (RAI-9, Ref. 5) 6 (RAI-12, Ref. 5) Please specify which of the three elevations provided is the correct elevation for level 1. RAI Question:

For RAI 3(a) above, please provide the analyses used to verify the design criteria and methodology for seismic testing of the SFP instrumentation and the electronics units, including, design basis maximum seismic loads and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces. RAI Question:

For each of the mounting attachments required to attach SFP level equipment to plant structures, please describe the design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment.

RAI Question:

The elevation for Level 1 is 232 f1. 10 in. Not Started. Not Started. Not Started. For RAI 6 above, please provide the results for the selected methods, tests and analyses used to demonstrate the qualification and Some RAls have been reliability of the installed equipment in renumbered.

This question accordance with the Order requirements.

refers to RAI-4, Reference

4. RAI Question:

Please provide the following:

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

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

Please provide the following:

a) The specific location for the primary and backup instrument channel display. Page 13 of 15 Not Started. Not Started.

Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 28, 2014 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 environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

7 RAI Question:

Not Started. (RAI-13, Ref. 5) 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.

Note: RAls not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAls in Reference 3 and are listed in the Overall Integrated Plan Open Item Table. 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. Page 140f15 Peach Bottom Atomic Power Station, Units 2 and 3 Second Six-Month Status Report for the Implementation of SFPLI February 2014 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-12-051), 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).

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