RS-13-176, Response to Request to Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
| ML13200A125 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/18/2013 |
| From: | Kaegi G Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-13-176 | |
| Download: ML13200A125 (15) | |
Text
ExetonGenerationRS-13-176Order No. EA-12-051July 18, 2013U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Dresden Nuclear Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-19 and DPR-25NRC Docket Nos. 50-237 and 50-249
Subject:
Response to Request for Additional Information - Overall Integrated Plan in Responseto Commission Order Modifying License Requirements for Reliable Spent Fuel PoolInstrumentation (Order No. EA-12-051)
References:
1.Exelon Generation Company, LLC letter to USNRC, "Overall Integrated Plan in Responseto March 12, 2012 Commission Order Modifying Licenses with Regard to Requirementsfor Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated February28, 2013 (RS-13-030)2.NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard toReliable Spent Fuel Pool Instrumentation," dated March 12, 20123.USNRC letter to Exelon Generation Company, LLC, "Request for Additional InformationRegarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation," datedJune 26, 2013In Reference 1, Exelon Generation Company,LLC (EGC)provided the Dresden Nuclear PowerStation, Units 2 and 3, Overall Integrated Plan in Response to the March 12, 2012, CommissionOrder Modifying Licenses with Regard to Requirements for Reliable Spent Fuel PoolInstrumentation, pursuant to NRC Order No. EA-12-051 (Reference 2).The purpose of this letter is to provide the response to the NRC request for additional information(Reference 3) regarding the Dresden Nuclear Power Station, Units 2 and 3, Overall IntegratedPlan in Response to the Commission Order Modifying Licenses with Regard to Requirements forReliable Spent Fuel Pool Instrumentation (Order No. EA-12-051).The Dresden Nuclear Power Station, Units 2 and 3, Spent Fuel Pool Instrumentation design isproceeding on the schedule identified in the Overall Integrated Plan provided in Reference 1.The enclosed responses to the NRC request for additional information are intended not to providepreliminary or conceptual information. The requested information, when fully developed, will beprovided upon detailed design completion based on the milestone schedule dates provided ineach response.
U.S. Nuclear Regulatory CommissionResponse to Request for Additional Information (Order EA-1 2-051)July 18, 2013Page 2This letter contains no new regulatory commitments. If you have any questions regarding thisresponse, 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 18tr' dayof July 2013.Respectfully submitted,Glen T. KaegiDirector - Licensing & Regulatory AffairsExelon GenerationCompany, LLC
Enclosure:
Dresden Nuclear Power Station, Units 2 and 3 - Response to Request for AdditionalInformation - Overall Integrated Plan in Response to Commission Order Modifying LicenseRequirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-1 2-051)cc:Director, Office of Nuclear Reactor RegulationNRC Regional Administrator - Region IIINRC Senior Resident Inspector - Dresden Nuclear Power Station, Units 2 and 3NRC Project Manager, NRR - Dresden Nuclear Power Station, Units 2 and 3Mr. Robert J. Fretz, Jr, NRRIJLD/PMB, NRCMr. Robert L. Dennig, NRRIDSS/SCVB, NRCMr. Blake Purnell, NRC Project Manager, NRRIllinois Emergency Management Agency - Division of Nuclear Safety U.S. Nuclear Regulatory CommissionResponse to Request for Additional Information (Order EA-12-051)July 18, 2013Page 3bcc:Site Vice President - Dresden Nuclear Power Station, Units 2 and 3Vice President Operations SupportSite Engineering Director - Dresden Nuclear Power Station, Units 2 and 3Regulatory Affairs ManagerRegulatory Assurance Manager - Dresden Nuclear Power Station, Units 2 and 3Severe Accident Management DirectorSite Operations Director - Dresden Nuclear Power Station, Units 2 and 3Corporate Licensing Manager - WestCorporate Licensing Director - WestExelon Records ManagementVinod AggarwalRoger SchiavoniJonathan HodappThomas J. Griffith Dresden Nuclear Power Station, Units 2 and 3Responseto Request for Additional InformationOverall Integrated Plan in Response to Commission Order ModifyingLicense Requirements for Reliable Spent Fuel Pool Instrumentation(Order No. EA-12-051)(11 pages)
Response to Request for Additional Information (Order EA-1 2-051)Enclosure 1Page 1 of 1
11.0INTRODUCTION
By letter dated February 28, 2013 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML13060A125), Exelon Generation Company, LLC, submitted anoverall integrated plan (OIP) in response to the March 12, 2012, U.S. Nuclear RegulatoryCommission (NRC) Order modifying licenses with regard to reliable spent fuel pool (SFP)instrumentation (Order EA-12-051; ADAMS Accession No. ML12054A679) for Dresden NuclearPower Station, Units 2 and 3. The NRC staff endorsed Nuclear Energy Institute, NEI 12-02,"Industry Guidance for Compliance with NRC Order EA-12-051, to Modify Licenses with Regardto Reliable SFP Instrumentation," Revision 1, dated August 2012 (ADAMS AccessionNo. ML12240A307), with exceptions as documented in NRC Interim Staff Guidance, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation,"Revision 0, dated August 29, 2012 (ADAMS Accession No. ML12221A339).The NRC staff has reviewed the February 28, 2013, response by the licensee and determinedthat the following request for additional information (RAI) is needed to complete its technicalreview.2.0LEVELS OF REQUIRED MONITORINGThe OIP states, in part, that:Key spent fuel pool water levels will be identified as follows:Level adequate to support operation of the normal fuel pool cooling system (Level 1):For both units, indicated level on either primary or backup instrument channel of greaterthan 23 feet (elevation 612') plus instrument channel accuracy above the top of thestorage racks based on the design accuracy of the instrument channel (which is to bedetermined) and a resolution of 1 foot or better for both the primary and backupinstrumentchannels.This is based on the height of the SFP weirs, demonstrating awater level of 23 feet (elevation 612') above the top of the storage racks is adequate fornormal fuel pool cooling system operation.Level adequate to provide substantial radiation shielding for a person standing on thespent fuel pool operating (Level 2): For both units, indicated level on either the primaryor backup instrument channel of greater than 10 feet (elevation 599') plus instrumentchannel accuracy above the top of the storage racks based on the specification of thislevel as adequate in JLD-ISG-2012-03 and NEI 12-02, the specified design accuracy ofthe instrument channel, and the relatively low sensitivity of dose rates to changes inwater depth at this level. This monitoring level ensures there is an adequate water levelto provide substantial radiation shieldingfor a person standing on the spent fuel pooloperating deck from direct gamma radiation from stored fuel.Level where fuel remains covered (Level 3): For both units, indicated level on either theprimary or backup instrument channel of greater than 0 feet (elevation 589') plusinstrument channel accuracy above the top of the storage racks based upon the designaccuracy (which is to be determined) of the instrument channel for both the primary andbackup instrument channels. This monitoring level assures that water is covering thestored fuel seated in the racks.
Response to Request for Additional Information (Order EA-12-051)Enclosure 1Page 2 of 11RAI-1Please provide the following:a)For Level 1, specify how the identified location represents the higher of the two pointsdescribed in the NEI 12-02 guidance for this level,b)A clearly labeled sketch depicting the elevation view of the proposed typical mountingarrangement for the portions of instrument channel consisting of permanentmeasurement channel equipment (e.g., fixed level sensors and/or stilling wells, andmounting brackets). Indicate on this sketch the datum values representing Level 1,Level 2, and Level 3 as well as the top of the fuel. Indicate on this sketch the portion ofthe level sensor measurement range that is sensitive to measurement of the fuel poollevel, with respect to the Level 1, Level 2, and Level 3 datum points.Responsea)Fuel Pool water level is normally maintained at approximately elevation 612' as indicatedin the Overall Integrated Plan (OIP). Based on the following discussion, Level 1 is beingdesignated to be approximately elevation 611'-3". This represents a small change fromthe OI P. The Spent Fuel Pool at Dresden Station has skimmers and scuppers located atan approximate 611'-3" elevation that water must flow into. From there the water isrouted to the surge tanks from which the Fuel Pool Cooling Pumps draw suction. Thesuction trip is at an approximate 595'-0" elevation. Thus the approximate 611'-3"elevation reflects the higher of the two points noted in NEI 12-02, Section 2.3.1.b)Please reference the sketch below. Instrument probe mounting details in the Spent FuelPool area will be provided in accordance with the response to RAI-3. Please note thatthe 23'-0" level sensor instrument range indicated below represents a small change fromthat discussed in the OIP.
Response to Request for Additional Information (Order EA-12-©51)Enclosure 1Page 3of11Floor EL 613'-0'Normal Water Level: EL 612'-0"^^L-Ll 1:617'-3"CurbEL 613'-4"Normal WaterLevel: EL 612'-0"::f___rworrLoi3_uNNmLevel 2:EL 599'-0"mC0arEL594' 6°aEL594'6"Level 3:EL 539'-0"Top of Fuel Rack: EL 587-0"Top of FuelRack:EL 589°-0"Bottom of SFP:EL 574'-Cr'33"-0"Bottom ofSFP: EL 574'-0"33'-0Unit 3 SFPUnit 2 SFPSpentFuel PoolElevation View SketchNOTE:All elevations and distancesare approximate Response to Request for Additional Information (Order EA-12-051)Enclosure 1Page 4 of 113.0INSTRUMENTATION DESIGN FEATURES3.2ArrangementThe OIP states,in part, that:The current plan is to install SFP level sensors in the northeast and southeast areas ofthe Unit 2 SFP separated by a distance in excess of 20 feet and in the northwest andsouthwest areas of the Unit 3 SFP separated by a distance in excess of 20 feet. Thesensors themselves will be mounted, to the extent practical, near the pool walls andbelow the pool curb to minimize their exposure to damaging debris and not interfere withSFP activities. Instrument channel electronics and power supplies will be located inseismic and missile protected areas either below the SFP operating floor or in buildingsother than the RB [Reactor Building]. The areas to be selected will provide suitableradiation shielding and environmental conditions for the equipment consistent withinstrument manufacturer's recommendations. Equipment and cabling for power suppliesand indication for each channel will be separated equivalent to that provided forredundant safety related services.RAI-2Please provide a clearly labeled sketch or marked-up plant drawing of the plan view of the SFParea, depicting the SFP inside dimensions, the planned locations/placement of the primary andback-up SFP level sensor, and the proposed routing of the cables that will extend from thesensors toward the location of the read-out/display device.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.3.3MountingThe OIP states, in part, that:Design of the mounting of the sensors in the SFP shall be consistent with the seismicClass I criteria. Installed equipment will be verified to be seismically adequate for theseismic motions associated with the maximum seismic ground motion considered in thedesign of theplant areainwhich it is installed.RAI-3Please provide the following:a)The design criteria that will be used to estimate the total loading on the mountingdevice(s), including static weight loads and dynamic loads. Describe the methodologythat will be used to estimate the total loading, inclusive of design basis maximum seismic Response to Request for Additional Information (Order EA-12-051)Enclosure 1Page 5 of 11loads and the hydrodynamic loads that could result from pool sloshing or other effectsthat could accompany such seismic forces.b)A description of the manner in which the level sensor (and stilling well, if appropriate) willbe attached to the refueling floor and/or other support structures for each planned pointof attachment of the probe assembly. Indicate in a schematic the portions of the levelsensor that will serve as points of attachment for mechanical/mounting or electricalconnections.c)A description of the manner by which the mechanical connections will attach the levelinstrument to permanent SFP structures so as to support the level sensor assembly.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.3.4QualificationThe OI P states, in part, that:Components of the instrument channels will be qualified for shock and vibration usingone or more of the following methods:components are supplied by manufacturers using commercial quality programs (suchas ISO9001, "Quality management systems - Requirements") with shock andvibration requirements included in the purchase specification at levels commensuratewith portable hand-held device or transportation applications;components have substantial history of operational reliability in environments withsignificant shock and vibration loadings, such as portable hand-held device ortransportation applications; orcomponents are inherently resistant to shock and vibration loadings, such as cables.For seismic effects on instrument channel components used after a potential seismicevent for only installed components (with the exception of battery chargers andreplaceable batteries), the following measures will be used to verify that the design andinstallation is adequate. Applicable components are rated by the manufacturer (orotherwise tested) for seismic effects at levels commensurate with those of postulateddesign basis event conditions in the area of instrument channel component use usingone or more of the following methods:...
Response to Requestfor Additional Information (Order EA-1 2-051)Enclosure 1Page 6 of 11RAE-4Please provide the following:a)A description of the specific method or combination of methods you intend to apply todemonstrate the reliability of the permanently installed equipment under beyond-design-basis ambient temperature, humidity, shock, vibration, and radiation conditions.b)A description of the testing and/or analyses that will be conducted to provide assurancethat the equipment will perform reliably under the worst-case credible design basisloading at the location where the equipment will be mounted. Include a discussion ofthis seismic reliability demonstration as it applies to a) the level sensor mounted in theSFP area, and b) any control boxes, electronics, or read-out and re-transmitting devicesthat will be employed to convey the level information from the level sensor to the plantoperators or emergency responders.c)A description of the specific method or combination of methods that will be used toconfirm the reliability of the permanently installed equipment such that following aseismic event the instrument will maintain its required accuracy.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.3.5IndependenceThe Ol P states, in part, that:The primary instrument channel will be independent of the backup instrument channel.This independence will be achieved through physical and electrical separation of eachchannels' components commensurate with hazard and electrical isolation needs.RAI-5Please provide the following:a)A description of how the two channels of the proposed level measurement system meetthis requirement so that the potential for a common cause event to adversely affect bothchannels is minimized to the extent practicable.b)Further information describing the design and installation of each level measurementsystem, consisting of level sensor electronics, cabling, and readout devices. Pleaseaddress how independence of these components of the primary and back-up channels isachieved through the application of independent power sources, physical and spatial Response to Request for Additional Information (Order EA-1 2-051)Enclosure 1Page 7 of 11separation, independence of signals sent to the location(s) of the readout devices, andthe independence of the displays.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.3.6Power suppliesThe OIP states, in part, that:Each channel will be normally powered from a different 120Vac [120 volts-alternatingcurrent] bus. Upon loss of normal ac power, individual channel installed batteries willautomatically maintain continuous channel operation. The batteries will be replaceableand be sized to maintain channel operation until off-site resources can be deployed bythe mitigating strategies resulting from Order EA-12-0494. Additionally, each channel willhave provisions for connection to another suitable power source.RAI-6Please provide the following:a)A description of the electrical ac power sources and capacities for the primary andbackup channels.b)If the level measurement channels are to be powered through a battery system(either directly or through an uninterruptible power supply), please provide the designcriteria 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 onsetof the beyond-design-basis event for the minimum duration needed, consistent withthe plant mitigation strategies for beyond-design-basis external events (OrderEA-12-049).ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.
Response to Request for Additional Information (Order EA-1 2-051)Enclosure 1Page 8of 113.7AccuracyThe OI P states, in part, that:The instrument channels will be designed to maintain their design accuracy following apower interruption or change in power source without recalibration. Instrument channelaccuracy, to be determined during detailed design, will consider Spent Fuel Poolconditions (e.g., saturated water, steam environment, concentrated borated water), aswell as, other applicable radiological and environmental conditions and include displayaccuracy. Instrument channel accuracy will be sufficient to allow trained personnel todetermine when the actual level exceeds the specified lower level of each indicatingrange (levels 1, 2 or 3) without conflicting or ambiguous indications.RAI-7Please provide the following:a)An estimate of the expected instrument channel accuracy performance (e.g., in percentof span) under both a) normal SFP level conditions (approximately Level 1 or higher)and b) at the beyond design-basis conditions (i.e., radiation, temperature, humidity, post-seismic and post-shock conditions) that would be present if the SFP level were at theLevel 2 and Level 3 datum points.b)A description of the methodology that will be used for determining the maximum alloweddeviation from the instrument channel design accuracy that will be employed undernormal operating conditions as an acceptance criterion for a calibration procedure to flagto operators and to technicians that the channel requires adjustment to within the normalcondition design accuracy.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.3.8TestingThe OiP states,in part, that:Instrument channel design will provide for routine testing and calibration consistent withthe guidelinesof NRC JLD-ISG-2012-032and NEI 12-023. Details will be determinedduring detailed design engineering.
Response to Request for Additional Information(Order EA-1 2-051)Enclosure 1Page 9 of 11RAI-8Please provide the following:a)A description of the capability and provisions the proposed level sensing equipment willhave to enable periodic testing and calibration, including how this capability enables theequipment to be tested in-situ.b)A description of how such testing and calibration will enable the conduct of regularchannel checks of each independent channel against the other, and against any otherpermanently-installed SFP level instrumentation.c)A description of how calibration tests and functional checks will be performed, and thefrequency at which they will be conducted. Discuss how these surveillances will beincorporated into the plant surveillance program.d)A description of what preventative maintenance tasks are required to be performedduring normal operation, and the planned maximum surveillance interval that isnecessary to ensure that the channels are fully conditioned to accurately and reliablyperform their functions when needed.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. Following the issue of the design, procedures will start being developed with aprojected July 2015 or 2016 completion date, respectively. The requested information will beprovided in the August 2015, 6-month Integrated Plan Update for Unit 2 and August 2016, 6-month Integrated Plan Update for Unit 3.3.9DisplayThe OIP states,in part, that:The primary and backup instrument displays will be located at the control room, alternateshutdown panel, or other appropriate and accessible location. The specific location will bedetermined during detailed design.RAI-9Please provide the following:a)The specific location for each of the primary and backup instrument channel displays.b)If the primary and backup display location is other than the main control room, providejustification for prompt accessibility to displays including primary and alternate routeevaluation, habitability at display location(s), continual resource availability for personnelresponsible to promptly read displays, and provisions for communications with decisionmakers for the various SFP drain down scenarios and external events.
Response to Request for Additional Information (Order EA-1 2-051)Enclosure 1Page 10 of 11c)The reasons justifying why the locations selected enable the information from theseinstruments to be considered "promptly accessible." Include consideration of variousdrain-down scenarios.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. The requested information will be provided in the February 2015, 6-monthIntegrated Plan Update for Unit 2 and February 2016, 6-month Integrated Plan Update forUnit 3.4.0PROGRAM FEATURES4.2ProceduresThe OIP states, in part, that:Procedures will be developed using guidelines and vendor instructions to address themaintenance, operation and abnormal response issues associated with the primary andbackup channels of SFP instrumentation.RAI-10Please provide the following:a)A list of the operating (both normal and abnormal response) procedures,calibration/test procedures, maintenance procedures, and inspection procedures thatwill be developed for use of the SFP instrumentation in a manner that addresses theorder requirements.b)A brief description of the specific technical objectives to be achieved within eachprocedure. If your plan incorporates the use of portable spent fuel level monitoringcomponents, please include a description of the objectives to be achieved withregard to the storage location and provisions for installation of the portablecomponents when needed.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. Following the issue of the design, procedures will start being developed with aprojected July 2015 or 2016 completion date, respectively. The requested information will beprovided in the August 2015, 6-month Integrated Plan Update for Unit 2 and August 2016, 6-month Integrated Plan Update for Unit 3.
Response to Request for Additional Information ((Order EA-12-051)Enclosure 1Page 11 of 114.3Testing and CalibrationThe OIPstates, in part, that:The testing and calibration of the instrumentation will be consistent with vendorrecommendations or other documented basis. Calibration will be specific to themounted instruments and the displays. A Maintenance Procedure will be written todirect calibration and repair of the instruments. Passport will be used to control thecalibration and setpoint parameters. The Passport PMID system will be used to directthe calibration frequency of the instruments.RAI-11Please provide the following:a)Further information describing the maintenance and testing program the licensee willestablish and implement to ensure that regular testing and calibration is performed andverified by inspection and audit to demonstrate conformance with design and systemreadiness requirements. Include a description of your plans for ensuring that necessarychannel checks, functional tests, periodic calibration, and maintenance will be conductedfor the level measurement system and its supporting equipment.b)A description of how the guidance in NEI 12-02, Section 4.3, regarding compensatoryactions 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 theinstrument channels cannot be restored to functional status within 90 days.ResponseThe current plan for the design of the SFPI system based on the current Exelon Nuclearprogram schedule for Dresden is to begin the design phase in September of 2014 with designcompletion and 100% acceptance of the design in December 2014 for Unit 2 and December2015 for Unit 3. Following the issue of the design, procedures will start being developed with aprojected July 2015 or 2016 completion date, respectively. The requested information will beprovided in the August 2015, 6-month Integrated Plan Update for Unit 2 and August 2016, 6-month Integrated Plan Update for Unit 3.It is noted that the above wording for RAI-1 1 is editorially corrected to identify parts (a), (b), and(c) to be consistent with the NRC draft email RAI issued on June 19, 2013. The NRC RAI letterto Exelon, dated June 26, 2013 (Reference 3), incorrectly listed parts (a), (b), (c), and (d).