NL-13-0172, Southern Nuclear Operating Company'S Overall Integrated Plan in Response to 3/12/2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (EA-12-051)

Southern Nuclear Operating Company'S Overall Integrated Plan in Response to 3/12/2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (EA-12-051)

ML13059A389
Person / Time
Site:	Hatch
Issue date:	02/27/2013
From:	Ivey B Southern Nuclear Operating Co, Southern Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-051, NL-13-0172
Download: ML13059A389 (19)

Text

B. L. "Pete" Ivey Southern Nuclear Vice President Operating Company, Inc.

Regulato ry Affairs 40 Invemess Center Parkway Post Office Box 1295 Bi rming ham, AL 35242 Tel 205.992.7619 Fax 205.992.5217 February 27,2013 Docket Nos.: 50-321 NL-13-0172 50-366 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Overall Integrated Plan In Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reguirementsfor Reliable Spent Fuel Pool Instrumentation (Order EA-12-051l

References:

1. I\lRC Order Number EA-12-051, Order Modifying 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-12-0S1, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29,2012

3. NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-0S1, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 1, dated August 24, 2012

4. Southern Nuclear Operating Company letter NL 2151 to the NRC, Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company'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-12-0S1), dated October 23, 2012 Ladies and Gentlemen:

On March 12,2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs SNC to have

U. S. Nuclear Regulatory Commission NL-13-0172 Page 2 a reliable indication of the water level in associated spent fuel storage pools.

Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013. The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document NEI12-02, Revision 1 (Reference 3) with clarifications and exceptions identified in Reference 2.

Reference 3 provides direction regarding the content of this Overall Integrated Plan. Reference 4 provided Edwin I. Hatch Nuclear Plant's (HNP) initial status report regarding reliable spent fuel pool instrumentation, as required by Reference 1.

The purpose of this letter is to provide the Overall Integrated Plan for HNP pursuant to Section IV, Condition C.1, of Reference 1. This letter confirms SNC has received Reference 2 and has an Overall Integrated Plan for HNP developed in accordance with the guidance for the purpose of ensuring a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of required wide range pool water level conditions by trained personnel.

The information in the Enclosure provides the HNP Units 1 and 2 Overall Integrated Plan for reliable spent fuel pool instrumentation pursuant to Reference

3. The enclosed Integrated Plan is based on conceptual design information. Final.

design details and associated procedure guidance, as well as any revisions to the information contained in the Enclosure, will be provided in the 6-month Integrated Plan updates required by Reference 1.

SNC intends to fully implement the requirements of the Order by breaker closure of the Unit 1 Spring 2016 refueling outage and by December 31, 2016, for Unit 2 per Section IV, Condition A.2 of Reference 1. In accordance with Section IV, Condition C.3 of Reference 1, SNC intends to submit notification to the NRC that full compliance of the Order has been achieved within 60 days of full implementation for each unit at HNP.

This letter contains no new regulatory commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

U. S. Nuclear Regulatory Commission NL-13-0172 Page 3 Respectfully submitted, B. L. Ivey Vice President - Regulatory Affairs BLl/CLN Mr. B. L. Ivey states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Sworn to and subscribed before me this _0"

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_ _ day of c5U-ti,fuuU)?f ,2013.

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Enclosure:

Edwin I. Hatch Nuclear Plant Units 1 and 2 Integrated Plan with Regard to Reliable Spent Fuel Pool Instrumentation cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President - Hatch Mr. B. J. Adams, Vice President - Fleet Operations Mr. C. R. Pierce, Director - Regulatory Affairs RType: CHA02.004 U. S. Nuclear Regulatory Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulation Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Hatch Mr. E. D. Morris, Senior Resident Inspector - Hatch Mr. Blake A. Purnell, NRRI..ILD/PMB, NRC Mr. Steven R. Jones, NRRlDSS/SBPB, NRC State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Overall Integrated Plan In Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

Enclosure Edwin I. Hatch Nuclear Plant Units 1 and 2 Integrated Plan with Regard to Reliable Spent Fuel Pool Instrumentation

Southern Nuclear Operating Company Edwin I. Hatch Nuclear Plant Units 1 & 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Implementation Plan Revision 0, February 27,2013 Hf\IP 1 & 2 RSFPI Integrated Plan Page 1 of 15 2/27/2013 12:20 PM

Table o f Contents

1. Introduction ......... .. ...... .................. ............ .. ........... ......................... ..... .. ..................... 3 II. Schedule ................................................. .... .................................... .. .......................... 4 III. Identification of Spent Fuel Pool Water Levels ............................... ...... ... .... .... ............... .. 5 IV. Instruments ......... ....................................... .. ....................... ........................................ 5 V. Reliability............. ...... .............................. ..... .......................... ............ ... ...................... 6 VI. Instrument Channel Design Criteria ................................................................................ 6 A. Arrangement .... ...... ........ .. ........................ .. ... .. ... ......... .. .. ............. ..... ..... ........... ..... .... ................. 6 B. Mounting.... .... ... ..... .... .... ... .... .................... ... .............. .. ..... ... ........ .. .... .. ...... .. ... ... ... ... ..... ..... ..... .... 7 C. Qualification ............... ... .. .. .......... ..... ............. ................................................. .... ... ................. ..... 7 D. Independence .. .. .. .. ... .... ...... ...... ..... ... .. ..... ...... .. .. .... ........ .. ....... .... ... ............. .. ..... .. .... .. ....... ..... .. ... 9 E. Power Supplies .. .. ... ... ......... ..... .. .... .... .. ...... ..... .... ..... .. ... ..................... .... ... ... .. .. ... .... .... .. .. ..... ........ 9 F. Accuracy ..................... ..... ....................... .. .... .. ....... .... ....................................... .. ......... .... .. .......... 9 G. Testing .......... .. ....... .... .... .... .... ............. .. .... ... .. ... .......... .. .. ....................... .. ........ ... ............ .. ........... 9 H. Display .............. .................. ................ .. ......... ............. ....... .. .... ........ .......... ...... .......................... 10 VII. Instrument Cliannel Program Criteria ........... ..... .................... ............. .. ... .... ................. 10 A. Training ....... ....... .... ... .. .. .. ............................. ... ... ...... .. .... .. ..... ..... ..... ...... ... ... ...... ... .. ............ ..... .. 10 B. Procedures ............. .......... .. ..... ...... ... ... ... .......... ......................................................................... 10 C. Testing and Calibration ..... .. ......... .. .. .. .............. ..... ......................................... .. .. .. .. .. ...... .. ......... 10 VIII. Need for Relief and Basis ............................. .... ............................. .. ..... .. ..................... 10 IX. References ................................................................................................................ 11 : Probe Layout Sketch ......................................................................................... 12 : Electrical Sketches ........... .. ................. ..... .................................. ...... ........ ......... 13 HNP 1 & 2 RSFPI Integrated Plan Page 2 of 15 2/27/2013 12:20 PM

L Introduction The Regulatory Commission {NRC} issued Issuance to Modify Licenses Regard to Fuel Pool {Reference 1} on March 12, 2012. Order requires the water level in associated spent pools capable of supporting identification of the following pool water level conditions by trained personnel: {l} level that is to support operation of the normal fuel pool system, (2) level that is adequate to provide substantial radiation shielding for on the pool operating and (3) level remains water should no longer The integrated which will provide a description of how will be achieved.

NEI Industry Guidance for Compliance with NRC Order EA-12-0S1, "To Modify Licenses with Regard to Reliab/e Spent Poo/lnstrumentation," (Reference 4) provides an approach for complying with order EA-12-0S1. NRC Interim Compliance with Order EA-12-0S1, Reliable Fuel Poo/lnstrumentation, (Reference that the methodologies and guidance in conformance with the guidelines provided in NEI 12-02, Revision 1, to the and to NEI 12-02 Section requirements of Order EA-12-051.

This plan provides the Edwin L Hatch Nuclear Power Plant (Hatch or HNP) Units 1 and 2 for complying with Order EA-12-0S1 methods in NE112-02 with exceptions and clarifications as detailed in following sections. Six month progress reports will provided consistent with the requirements Order EA-12-051 and guidance in NEI12-02.

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II. Schedule Installation of reliable spent fuel pool (SFP) level instrumentation will be completed prior to startup from the second refueling outage per unit after submittal of this plan (the Second Refueling outage commencing at HNP following February 28,2013 is Spring 2016 for Unit 1 and Spring 2017 for Unit 2), but no later than December 31,2016, (Reference 6).

The following milestone schedule is provided. The dates are planning dates subject to change as design and implementation details are developed. Any changes to the following target dates will be reflected in the subsequent six (6) month status reports.

The current milestones are:

Original Target Activity Status Date {Include date changes in this columnl Oct. 2012 Submit 60 Day Status Report Complete Feb 2013 Submit Overall Integrated Implementation Plan Complete Aug 2013 Submit 6 Month Status Report Feb. 2014 Submit 6 Month Status Report s

Mar 2014 Unit 1 1 RFO June 2014 Develop Modifications Unit 1 Aug. 2014 Submit 6 Month Status Report.

Feb 2015 Receipt of Unit 1 SFP Instrument Channel Feb. 2015 Submit 6 Month Status Report Mar 2015 Unit 21 5 RFO Apr 2015 Develop Modifications Unit 2 Aug 2015 Submit 6 Month Status Report 302015 Complete Functional Test of Unit 1 SFP Instruments Nov 2015 Receipt of Unit 2 SFP Instrument Channel Feb . 2016 Submit 6 Month Status Report no Mar 2016 Unit 1 Implementation Complete (2 RFO)*

Aug. 2016 Submit 6 Month Status Report 402016 Complete Functional Test of Unit 2 SFP Instruments Dec 2016 Unit 2 Implementation Complete **

Dec 2016 Submit Completion Report

'Full compliance after second listed refuelmg outage

• • Full compliance by 12/31/2016 since second refueling outage is after 12/31/2016 HNP 1 & 2 RSFPI Integrated Plan Page 4 of 15 2/27/2013 12:20 PM

HI. Identification of Spent Fuel Pool Water Levels The wet spent-fuel storage facility is located on the common refueling floor in secondary containment. It provides specially designed underwater storage space for the spent fuel assemblies which require shielding and cooling during storage and handling. A Seismic Category 1 backup system is provided to add water if the normal makeup system is not available. The important levels for the pool are as follows:

Key spent fuel pool water levels:

1. Level adequate to support operation of the normal fuel pool cooling system - The low level alarm setpoint, Elevation 225'-9" for Unit 1, Elevation 226'-2.5" for Unit 2, which is above the elevation where the pumps lose suction from a low level in the skimmer surge tank (Engineering Central File (ECF) application of the Plant Data Management System (PDMS) for instruments lG41N372 and 2G411\J372).

2. Level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck - For Unit 1 and 2, elevation 214'-0" is approximately 10'-0" above (elevation 204'-0" is the nominal level of the highest fuel rack) the highest point of the fuel racks (plus or minus 1 foot) (Unit 2* FSAR Sections 9.1.2.2.2b and 9.1.3.2.5, Reference 10; Drawing H26105, Reference 11).

3. level where fuel remains covered - For Unit 1 and 2 elevation 204'-0" is the nominal level of the highest fuel rack (Unit 2 FSAR Section 9.1.2.2.2b, Reference 10; Drawing H26105, Reference 11).

Note:

• Many items in the HNP Unit 1 FSAR reference the HNP Unit 2 FSAR for supporting information versus repeating information in both documents. Thus, in this report, Unit 1 items may reference the Unit 2 FSAR as a controlling reference.

IV. Instruments Design of the instruments will be consistent with the guidelines of !\IRC .lLD-ISG-2012-03 and I\IE112-02 with the exceptions and clarifications as detailed below.

• Primary and backup instrument channels will consist of fixed components.

• The plan is for both channels to utilize Guided Wave Radar, which functions according to the principle of Time Domain Reflectometry (TDR). A generated pulse of electromagnetic energy travels down the probe. Upon reaching the liquid surface the pulse is reflected and based upon reflection times, level is inferred.

• The measured range will be continuous from the high pool level elevation (227' - 5") to the top of the spent fuel racks at elevation (204') (Reference 10).

• Instrument channel level sensing components (probe) will be located in the SFP directly adjacent to the spent fuel. The electronics processing module will be capable of being located in a non-harsh environment area outside the SFP area.

• The display shall provide a continuous indication of spent fuel pool water level at the Display location. In the event the link to the Display is lost, a field accessible HNP 1 & 2 RSFPI Integrated Plan Page 5 of 15 2/27/2013 12:20 PM

signal/Indication (remote to the Display location) will be available for determination of pool level.

• The electronic processing module and the Display will be installed in a location that will meet the criteria established in NE112-02 and endorsed by NRC JLD-ISG-2012-03. The specific location of the electronic processing module and the Display has not been determined yet.

V. Reliability Reliability of the primary and backup instrument channels will be assured by conformance with the guidelines of NRC JLD-ISG-2012-03 or NE112-02, as discussed in Section 3.4, Qualification and 3.8 Testing . Reliable level indication will be functional during all times when used fuel is in the SFP consistent with NE112-02 Section 4.3, Testing and Calibration.

VI. Instrument Channel Design Criteria Instrument channel design will meet the guidelines of NRC JLD-ISG-2012-03 and NE112-02 and applicable sections of the plant FSAR with the exceptions and clarifications as detailed below.

A. Arrangement SFP level probes will be installed separate from each other in the SFP. Primary and backup level indication will be installed in the Main Control Room, at the alternate shutdown panel, or another appropriate and accessible location (reference NEI 12-06) that complies with the NE112-02 following characteristics. SNC has not determined the exact location at this time and has several options that provide various benefits . For example, the Main Control Room is the NRC preferred location while an appropriate accessible location in the plant would provide information to personnel in the plant at a location closer to the pool and mitigation equipment . Both existing and new barriers will be used to provide a level of protection for the cable located on the refueling floor from falling debris missiles generated by the event.

Probes will consist of a small diameter stainless steel cable mounted within a protective sleeve (stilling well). The cable will end just above the fuel racks. Based on the light weight of the probe, it is assumed that the probe will survive the event with little or no damage. Likewise, the pool wall or spent fuel will not be damaged by any interaction with the protective sleeve during the event.

Specific channel level sensing components physical properties and installation details will be provided later after the engineering and design phase is completed .

The probe support (including stilling well) will be designed to shield the probe from event generated missiles (falling debris). The design of the probe and probe support will allow the fuel handling machine to pass over it without interference.

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Cabling for power supplies and indications for each channel will be separated for missile protection (falling debris) and routed in separate conduits from cabling for the other channel.

B. Mounting Per NEI 12-02 Section 3.3, Mounting, the new equipment will be mounted to maintain the current Seismic Class of the Spent Fuel Pool which is Seismic Class I (Unit 2 FSAR Section 9.1.2.2.1, Reference 10). Thus, the new equipment will be seismically qualified to Class I. In addition, the mounting of the primary and backup channel components throughout the plant will meet the criteria of the structure it will be routed through or attached to.(refer to Qualification details below relating to cable and raceway installation criteria)

c. Qualification The components/cables/connections for both primary and backup channels will be reliable at the temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for seven (7) days. Saturation temperature at the bottom of the SFP assuming normal water level will be approximately 250°F. Post event temperature at sensors located above the SFP is assumed to be 212°F. Post event humidity in the fuel pool floor near and above the SFP is assumed to be 100% with condensing steam. The components/cables/connections will be qualified for expected conditions at the installed location assuming the SFP has been at saturation for an extended period. The components/cables/connections located in the vicinity of the SFP will be qualified to withstand peak and total integrated dose radiation levels for their installed location assuming that post event SFP water level is equal to the top of irradiated fuel for a time no greater than six (6) hours. It is anticipated that the station personnel can align one of the three (3) SFP Cooling Strategies as detailed in NE112-06 if conditions are degrading as indicated by decreasing SFP level.

Conduit design in the SFP area will be installed to Seismic Category 1 criteria. Both existing and new barriers will be used to provide a level of protection for the cable located on the refueling floor from missiles. The existing and new raceway used to route the cable to the Display will be installed to Seismic Class 1 criteria. Augmented quality requirements, similar to those applied to fire protection, will be applied to the components installed in response to this Order.

The specific values to use for the shock and vibration qualification will be determined in the design phase of the implementation using FSAR and Design Basis information .

Components of the instrument channels installed in the SFP area will be qualified for shock and vibration using one or more of the following methods (note different methods may be used for the various sub components of the primary and back-up instrument channels):

• Instrument channel components use known operating principles, are supplied by manufacturers with commercial quality programs (such as 1509001) with shock and vibration requirements included in the purchase specification and/or instrument HNP 1 & 2 RSFPI Integrated Plan Page 7 of 15 2/27/2013 12:20 PM

design, and commercial design and testing operation in environments where significant shock vibration loadings are common, such as for hand-held or

• Substantial history operational reliability in environments with significant shock vibration as transportation applications; or

• Use of components inherently resistant to shock and vibration load or are seismically reliable as cables.

For seismic impact on instrument channel components required seismic event for installed components, the following measures will that the design and is adequate.

are rated by manufacturer (or commensurate with those of postu basis event conditions in the area instrument channel component use using one or more of the following methods (note different methods may be used for the various sub components the primary and back-up instrument channels):

" Adequacy of seismic and installation is demonstrated in Sections 7, 8, 9, 10 of IEEE Standard IEEE 1E

• Instrument channel components use known operating principles are supplied by manufacturers with quality programs (such as IS09001) with seismic requirements included in the purchase and/or instrument and commercial design testing for operation in environments where seismic effects are common

.. Substantial operational reliability in environments with vibration, such as portable hand-held or transportation

.. Demonstration of reliability using that predict the performance by:

Analysis Testing of equ under seismic conditions Using a combination of test and analysis

.. The use of data.

Demonstration devices are similar in design to that have been previously for seismic in excess of the plant basis at the location the instrument is to installed (g-Ievels and frequency

.. qualification seismic motion consistent with that of existing loading at the location.

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D. Independence The primary and backup instrument channels are of the same technology, are permanently installed, separated by distance or barriers, and utilize independent power supplies from different buses/switchgear.

E. Power Supplies Each channel will normally be powered from independent (different buses/switchgear) 120V AC power sources and will have a dedicated battery backup. The battery backup will be dedicated to each channel, should have the capability of automatically switching and operating on backup batteries and will have manual switching as a minimum. A minimum battery life of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be provided to allow for power restoration from portable equipment (refer to attachment 2 for a typical sketch). Refer to Safety Function Support section of the SNC Integrated Plan February 28, 2013, submittal for NRC Order EA-12-049 for details on the power strategy from portable FLEX Diesel Generators (DGs) .

F. Accuracy Instrument channels will be designed such that they will maintain their design accuracy without recalibration following a power interruption or change in power source.

SNC plans for the instrument design accuracy to be within +/- 1 inch, or as close as reasonably achievable, over the entire range for the expected environmental and process conditions. Accuracy will consider SFP post event conditions, e.g., saturated water, steam environment, or concentrated borated water . Additionally, the instrument accuracy of the GWR technology will be sufficient to allow trained personnel to determine when the actual level exceeds the specified level of each indicating range (levels 1, 2 and 3) without conflicting or ambiguous indication . The accuracy will be with in the resolution requirements of Figure 1 of NEI12-02.

G. Testing Instrument channel design will provide for routine testing and calibration consistent with Order EA-12-0S1 and the guidance in NEI 12-02.

• SNC plans for the design to facilitate in-situ testing and lor calibration of the Static or non-active installed (fixed) sensors

• SNC plans for the design to facilitate the microprocessor based channel features to be capable of testing the instrument channel while mounted in the pool.

• Existing work control processes will be used to control maintenance and testing.

(e.g., Preventive Maintenance (PM) Program, Surveillance Program , Vendor Contracts, or work orders)

• Other testing and calibration requirements are located in Program Controls testing sub section below .

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H. Display Primary and backup indication will be provided in the Main Control Room, at the alternate shutdown panel, or another appropriate and accessible location (reference NEI12-06) that complies w ith the NE112-02 characteristics. If mUltiple display locations are powered from the instrument loop, then the guidance in NEI 12-02 regarding multiple displays will be followed (refer to attachment 2 for a typical sketch).

VII. Instrument Channel Program Criteria Instrument channel program criteria will be consistent with the guidelines of NRC .ILD-ISG-2012 03 and NEI 12-02.

A. Training A systematic approach will be used to identify the population to be trained and to determine both the initial and continuing elements of the required training. Personnel will complete training prior to being assigned responsibilities associated with this instrument.

B. Procedures Procedures will be developed using guidelines and vendor instructions to address the maintenance, operation, and abnormal response issues associated with the new SFP instrumentation consistent with NEI 12-02 .

Procedures will address a strategy to ensure SFP water level addition is initiated at an appropriate time consistent with implementation of NEI12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide (References 5 and 7).

C. Testing and Calibration Processes will be established and maintained for scheduling and implementing necessary testing and calibration of the primary and backup spent fuel pool level instrument channels to maintain the instrument channels at the design accuracy.

Testing and calibration of the instrumentation will be consistent with vendor recommendations and any other documented basis. Calibration will be specific to the mounted instrument and the monitor. Out of service time as identified in NEI 12-02 will be incorporated consistent with the programmatic process used for compliance with NRC Order EA-12-049 (Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond Des ign Basis External Events).

VIII. Need for Relief and Basis Southern Nuclear is not requesting relief from the requirements of Order EA-12-051 or the guidance in NE112-02 at this time, except as discussed herein.

Consistent with the requirements of Order EA-12-051 and the guidance in NE112-02 as endorsed by /\IRC .ILD-ISG-2012-03, the six-month reports will delineate progress made, any HNP 1 & 2 RSFPI Integrated Plan Page 10 of 15 2/27/2013 12:20 PM

proposed changes in our compliance methods, updates to the schedule, and, if needed, requests for relief and their bases.

IX. References 1} EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, March 12, 2012 2} EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012 3} NRC JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29,2012 4} NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, liTo Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," Revision 1, August 2012 5} NE112-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012 6} Letter, NL-12-2151 , Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 23,2012 7} Letter NL-12-2146, Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requ irements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 23,2012 .

8} IS09001, Quality management systems - Requirements 9} IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations 10} Edwin I. Hatch Nuclear Plant Unit 1 and 2 Final Safety Analysis Reports, Revision 31, November 2012 ll} Edwin I. Hatch Nuclear Plant Unit 2 Final General Arrangement Section B-B, H26105 HNP 1 & 2 RSFPI Integrated Plan Page 11 of 15 2/27/2013 12:20 PM

Attachment 1: Probe Layout Sketch (Page 1 of 1)

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