RS-14-019, 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)

ML14062A058
Person / Time
Site:	Clinton  (NPF-062)
Issue date:	02/28/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, RS-14-019
Download: ML14062A058 (17)

Text

ti RS-14-019 February 28, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Order No. EA-12-051

Subject:

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

References:

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

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

Revision 0, dated August 29, 2012

3. NEI12-02, Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051}, dated October 25,2012

5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated February 28,2013 (RS-13-029}

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-13-116)

7. NRC letter to Exelon Generation Company, LLC, Clinton Power Station, Unit 1 -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. MF0791), dated November 15,2013

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-051 February 28, 2014 Page2 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 Clinton Power Station, Unit 1 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 Clinton Power Station. The purpose of this letter is to provide the second six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Request for Additional Information Items contained in Reference 7.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 28th day of February 2014.

Respectfully submitted,

~ZL¥ Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

Enclosure Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (14 pages)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 1

Introduction Clinton Power Station, Unit 1, (CPS) 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 February 28, 2014.

Commenced procurement of equipment Began detailed design engineering of the SFPLI for Clinton Power Station 3

Milestone Schedule Status The following provides an update to the milestone schedule to support the Overall Integrated Plan. This section provides the activity status of each item, and the expected completion date noting any change. The dates are planning dates subject to change as design and implementation details are developed.

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

Revised 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 Responses to RAis July 5, 2013 Complete Submit 6 Month Updates:

Update 1 August 28, 2013 Complete Update 2 February 28, 2014 Complete with this submittal Update 3 August 28, 2014 Not Started Page 1 of 14

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 Milestone Target Completion Activity Date Status Provide Final Safety Evaluation September 30, 2014 Not Started (SE) Info Modifications:

I Conceptual Design 302012 Complete Issue Exelon Fleet contract to 202013 Complete procure SFPI Equipment Begin Detailed Engineering 402013 Complete Design Complete and Issue SFPI 202014 Started Modification Package Begin Installation 102015 Not Started Complete SFPI Installation and 202015 Not Started Put Into Service 4

Changes to Compliance Method Revised Target Completion Date 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 CPS expects to comply with the order implementation date and no relief/relaxation is required at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Safety Evaluation (IS E) and the status of each item.

Overall Integrated Plan Open Items 01#

Description Status 1

Open Item:

Complete.

(Ref.1)

Continuous level indication will be provided by a guided wave radar system, submersible pressure Page 2 of 14 I

1 (RAI-1, Ref.4) 2 (RAI-2, Ref.4)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28,2014 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 NEI12*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 Level 3 datum points.

RAI Question:

Started.

Please provide a clearly labeled sketch Note that the start date for the design or marked-up plant drawing of the plan has changed from November 2013 to view of the SFP area, depicting the December 2013 and completion date for SFP inside dimensions, the planned locations/placement of the primary and design has changed from June 2014 to backup SFP level sensor, and the September 2014; however, all required proposed routing of the cables that information for Final SE will be provided will extend from the sensors toward in accordance with the Interim SEdate the location of the read-out/display for Clinton by September 30, 2014.

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 Page 3 of 14 I I I

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3 (RAI-3, Ref.4)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 design of the SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 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 Interim SEdate.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) The design criteria that will be used has changed from November 2013 to to estimate the total loading on the December 2013 and completion date for mounting device(s), including static weight loads design has changed from June 2014 to and dynamic loads. Describe the September 2014; however, all required methodology that will be used to information for Final SE will be provided estimate the total loading, inclusive of in accordance with the Interim SEdate design basis maximum seismic loads for Clinton by September 30, 2014.

and the hydrodynamic loads that could result from pool sloshing or other effects that could accompany such seismic forces.

b) A description of the manner in which the level sensor (and stilling well, if appropriate) will be attached to the refueling floor and/or other support structures for each planned point of attachment of the probe assembly.

Indicate in a schematic the portions of the level sensor that will serve as points of attachment for mechanical/mounting or electrical connections.

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

RESPONSE

Mounting device total loading and attachments are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design Page 4 of 14 I

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4 (RAI-4, Ref.4)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 phase in December 2013 with design completion and 1 00% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the Interim SEdate.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) A description of the specific has changed from November 2013 to method or combination of methods December 2013 and completion date for that will be applied to demonstrate design has changed from June 2014 to the reliability of the permanently September 2014; however, all required installed equipment under beyond-design-basis (BOB) ambient information for Final SE will be provided temperature, humidity, shock, in accordance with the Interim SEdate vibration, and radiation conditions.

for Clinton by September 30, 2014.

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 re-transmitting devices that will be employed to convey the level information from the level sensor to the plant operators or emergency responders.

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

RESPONSE

Equipment reliability qualification information is not available at this time.

This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Page 5 of 14 I

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{RAI-5, Ref.4) 6 (RAI-6, Ref.4)

Clinton Power Station, Unit i Second Six-Month Status Report for the Implementation of SFP Ll February 28, 20i 4 Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 with design completion and 1 00% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the Interim SE date.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) A description of how the two has changed from November 2013 to channels of the proposed level December 2013 and completion date for measurement system meet this requirement so that the potential for a design has changed from June 2014 to common cause event to adversely September 2014; however, all required affect both channels is minimized to information for Final SE will be provided the extent practicable.

in accordance with the Interim SE date b) Further information on how each for Clinton by September 30, 2014.

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

RESPONSE

Channel independence information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SF PI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 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 Interim SE date.

RAI Question:

Replaced by Interim SE RAI #8 Please provide the following:

Note that the start date for the design a) A description of the electrical AC has changed from November 2013 to power sources and capacities for the Page 6 of 14 I I

7 (RAI-7, Ref.4)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 primary and backup channels.

December 2013 and completion date for b) If the level measurement channels design has changed from June 2014 to are to be powered through a battery September 2014; however, all required system (either directly or through an information for Final SE will be provided Uninterruptible Power Supply (UPS)),

in accordance with the Interim SE date please provide the design criteria that for Clinton by September 30, 2014.

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).

RESPONSE: Equipment total power supply configuration and characteristics are not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 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 Interim SE date.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) An estimate of the expected has changed from November 2013 to instrument channel accuracy December 2013 and completion date for performance under both (a) normal design has changed from June 2014 to SFP level conditions (approximately September 2014; however, all required Level1 or higher) and (b) at the BOB conditions (i.e., radiation, information for Final SE will be provided temperature, humidity, post-seismic in accordance with the Interim SEdate and post-shock conditions) that for Clinton by September 30, 2014.

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 Page 7 of 14 I

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Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 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.

RESPONSE

Channel accuracy information is not available at this time. This information will be developed during the detailed design process. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 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 Interim SE date.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) A description of the capability and has changed from November 2013 to provisions the proposed level December 2013 and completion date for sensing equipment will have to design has changed from June 2014 to enable periodic testing and September 2014; however, all required calibration, including how this capability enables the equipment to information for Final SE will be provided be tested in-situ.

in accordance with the Interim SEdate b) A description of how such testing for Clinton by September 30, 2014.

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.

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Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP U February 28, 2014 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 SF PI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 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 Interim SE date.

RAI Question:

Replaced by Interim SE RAI #11 Please provide the following:

Note that the start date for the design a) The specific location for the has changed from November 2013 to primary and backup instrument December 2013 and completion date for channel displays.

design has changed from June 2014 to b) If the primary and backup displays September 2014; however, all required are not located in the main control room, please provide a description of information for Final SE will be provided the selected location(s) for the in accordance with the Interim SEdate primary and backup displays, for Clinton by September 30, 2014.

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 Page 9 of 14 I

10 (RAI-10, Ref.4)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 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 SF PI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 with design completion and 1 00% acceptance of the design in September 2014. The requested information will be provided by September 30, 2014 in accordance with the Interim SE date.

RAI Question:

Replaced by Interim SE RAI #12 Please provide a description of the Note that the start date for the design standards, guidelines and/or criteria has changed from November 2013 to that will be utilized to develop December 2013 and completion date for procedures for inspection, design has changed from June 2014 to maintenance, repair, operation, September 2014; however, all required abnormal response, and information for Final SE will be provided administrative controls associated in accordance with the Interim SEdate with the SFP level instrumentation, for Clinton by September 30, 2014.

as well as storage and installation of portable instruments.

RESPONSE: Procedural details are not available at this time. This information will be established during process and procedure development following the detailed design phase. The current plan for the design of the SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 with design completion and 1 00% acceptance of the design in September 2014. Procedures will start Page lO of 14 I

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Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 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 Interim SEdate.

RAI Question:

Started.

Please provide the following:

Note that the start date for the design a) Further information describing the has changed from November 2013 to maintenance and testing program December 2013 and completion date for the licensee will establish and design has changed from June 2014 to implement to ensure that regular testing and calibration is performed September 2014; however, all required and verified by inspection and audit information for Final SE will be provided to demonstrate conformance with in accordance with the Interim SE date design and system readiness for Clinton by September 30, 2014.

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 SFPI system based on the current Exelon Nuclear program schedule for Clinton Power Station is to begin the design phase in December 2013 with design completion and 1 00%

acceptance of the design in September Page 11 of 14 I

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01#

1 (RAI-3, Ref. 5) 2 (RAI-4, Ref. 5) 3 (RAI-6, Ref. 5) 4 (RAI-8, Ref. 5)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 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 Interim SEdate.

Interim Safety Evaluation Open Items Description Status RAI Question:

Not Started.

For RAI 2(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:

Not Started.

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:

Not Started.

For RAI #5 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.

RAI Question:

Not Started.

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 depleting 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.

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5 (RAI-11, Ref. 5) 6 (RAI-12, Ref. 5)

Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014 RAI Question:

Not Started.

Please provide the following:

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

b) If a display will be located somewhere other than the control room or alternate shutdown panel, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BOB event. Include the time available for personnel to access the display as credited in the evaluation, as well as the actual time (e.g., based on walk-throughs) that it will take for personnel to access the display. Additionally, please include a description of the radiological and environmental conditions on the paths personnel might take. Describe whether the display location remains habitable for radiological, heat and humidity, and other environmental conditions following a BOB event. Describe whether personnel are continuously stationed at the display or monitor the display periodically.

RAI Question:

Not Started.

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: RAis not included in the Interim Staff Evaluation Open Items Table are duplicate to the RAis in Reference 3 and are listed in the Overall Integrated Plan Open Item Table.

7 Potential Draft Safety Evaluation Impacts 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.

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Clinton Power Station, Unit 1 Second Six-Month Status Report for the Implementation of SFP Ll February 28, 2014

1. Exelon Generation Company, LLC, letter to US NRC, "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 029)

2. NRC Order Number EA-12-051, "Issuance of Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation", dated March 12, 2012.

3. USNRC letter to Exelon Generation Company, LLC, Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation, dated June 7, 2013.

4. Exelon Generation Company, LLC, letter to USNRC, "Response to Request for Additional Information-Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA 051)", dated July 3, 2013 (RS-13-157).

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 November 15,2013.

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-13-116).

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