NL-13-0173, 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)

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)

ML13059A386
Person / Time
Site:	Vogtle
Issue date:	02/27/2013
From:	Ivey B Southern Nuclear Operating Co, Southern Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-13-0173, EA-12-051
Download: ML13059A386 (19)

Text

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

Regulatory Affairs 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7619 Fax 205.992.521 7 February 27,2013 Docket Nos.: 50-424 NL-13-0173 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating 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)

References:

1. NRC 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-12-051, 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-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, Revision 1, dated August 24, 2012

4. Southern Nuclear Operating Company letter NL-12-2152 to the NRC, Vogtle Electric Generating 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-12-051), 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 (SI\lC). Reference 1 was immediately effective and directs SNC to have

U. Nuclear Commission NL-13-01 Page 2 a reliable indication of water level in aS~)OClaltm spent fuel pools.

Specific requirements are outlined in 2 of 1.

Reference 1 requires submission of an Overall Plan by February 201 NRC Interim Staff (ISG) (Reference 2) was '''''.'01..1 2 which endorses industry guidance document NEI 12-02, .... c\lIc.nn Qoto,.,onr'o 3) with and identified in I-lo*to ..':>n....*o Reference 3 provides direction regarding the content of this Overall Integrated Plan. Reference 4 provided Vogtle Generating (VEGP) initial status report regarding reliable fuel pool instrumentation, as required by Qoto",Qnr'o 1.

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

The information in the Enclosure provides the VEGP Units 1 and 2 Overall Integrated Plan for reliable spent fuel pool instrumentation pursuant to Reference enclosed Integrated Plan is based on conceptual design information. Final details and procedure as well as revisions to the information contained in the Enclosure, will be provided in 6-month Integrated Plan by Reference 1.

SNC intends to fully implement requirements the Order of the Unit 1 Fall 2015 refueling outage and the Unit 2 Fall 2014 refueling outage Section IV, Condition A.2 of Reference 1. In accordance with Section IV, Condition C.3 of 1, SNC to submit notification to the NRC that full compliance of the Order has achieved within 60 of full implementation for each unit at letter contains no new regulatory commitments. If you any questions, please contact McElroy at (205) 992-7369.

U. S. l\Juclear Regulatory Commission NL-13-0173 Page 3 Respectfully subrnitted,

~=>

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 rJ. 7Wc day of Jdv~/ ,2013.

nHRtt(~~ #1~~1-rlr--/

tary Public My commission expires: :1MA c4"), 2, J-o j if .:

-- ~

.,..........~

Enclosure:

Vogtle Electric Generating 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. T. E. Tynan, Vice President - Vogtle Mr. B. J. Adams, Vice President - Fleet Operations Mr. C. R. Pierce, Director - Regulatory Affairs RType: CVC7000 U. S. Nuclear Regulatory Comrnission 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 - Vogtle Mr. L. M. Cain, Senior Resident Inspector - Vogtle Mr. Blake A. Purnell, NRR/JLD/PMB, NRC Mr. Steven R. Jones, NRR/DSS/SBPB, NRC State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

VogUe Electric Generating Plant - Units 1 2 Southern Nuclear Operating Company's Overall Integrated Plan In to March 12,2012 Commission Order Modifying licenses with

.......,"*.,.,. to Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

Enclosure Vogtle Electric Generating Plant Units 1 and 2 Integrated Plan with Regard to Reliable Fuel Pool Instrumentation

Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 1 & 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Implementation Plan Revision 0, February 27,2013 VEGP-1 & 2 RSFPI Integrated Plan Page 1 of 15 2/27/2013 12:21 PM

Table of Contents I. 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 Channel 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 Location Sketch .... .... ............................................................................ .. 12 : Electrical Sketches ....... .............................................................. .... ............ ...... 13 VEGP-1 & 2 RSFPI Integrated Plan Page 2 of 15 2/27/2013 12:21 PM

I. Introduction The Regulatory Commission (NRC) issued Order EA-12-0S1, Issuance of Order to Modify with Regard to Spent Fuel Instrumentation, 1) on Ma 2012. The Order licensees to have reliable indication the water level in associated spent fuel pools capable of supporting identification of the following pool water level conditions by trained personnel: that is of normal fuel cooling system, (2) is adequate to provide su radiation shielding for a person standing on spent fuel pool operating deck, and (3) where fuel remains and actions to implement water addition should no longer Order also submittal of an integrated plan will provide a description of how the requirements of the Order will be achieved.

NEI Industry Guidance Compliance with NRC Order Modify Licenses with Regard to Reliable Fuel Poo/lnstrumentation," (Reference 4) provides an approach for complying with EA-12-0S1. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order Reliable Poo/lnstrumentation, {Reference 3} that in conformance with the guidelines provided in NE112-02, specific to NEI 12-02 Section 3.4, the Order integrated provides the Generating Plant (VEGP) Units 1 2 approach for complying with Order EA-12-0S1 using methods described in NE112-02 with the and clarifications as in the sections. Six month progress will be provided consistent with the requirements of Order EA-12-0S1 and the in NEI 12-02.

VEGP-l & 2 RSFPI Integrated Plan 3 of 15 12:21 PM

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 VEGP following February 28,2013 is Fall 2015 for Unit 1 and Fall 2014 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 5

Apr2013 Unit 21 RFO Aug 2013 Submit 6 Month Status Report Dec 2013 Develop Modifications Unit 2 Feb. 2014 Submit 6 Month Status Report Apr2014 Unit 1 15 RFO Apr 2014 Receipt of Unit 2 SFP Instrument Channel June 2014 Develop Modifications Unit 1 302014 Complete Functional Test of Unit 2 SFP Instruments Aug. 2014 Submit 6 Month Status Report Dec 2014 Receipt of Unit 1 SFP Instrument Channel 302015 Complete Functional Test of Unit 1 SFP Instruments Oct 2014 Unit 2 Implementation Complete (2 0 0 RFO)*

Feb . 2015 Submit 6 Month Status Report Oct 2015 Unit 1 Implementation Complete (2 00 RFO)*

Dec 2015 Submit Completion Report

'Full compliance after second listed refueling outage VEGP-1 & 2 RSFPI Integrated Plan Page 4 of 15 2/27/2013 12:21 PM

Identification of Spent Fuel Pool Water Levels Each unit at Vogtle Generating Plant its own fuel pool. spent fuel pools are within the Seismic Category 1 handling building. The pool is approximately 41 ft constructed of and lined with a 1/4-in. plate.

Contiguous to each spent fuel pool is a short canal to the transfer The transfer canal is connected to the canal inside the containment by the fuel tube. All movement spent fuel transfer are underwater, and the waterways are of depth to maintain a nominal 10 ft of shielding water above active fuel. A metal gate with gasket assembly the spent fuel the fuel transfer This allows transfer to without with the water level in fuel pool (see Attachment 1).

1. Level adequate to support operation of the normal fuel pool cooling system - Fuel pool level when suction loss occurs can be conservatively defined as SFP cooling low level set point 2 which is above the elevation at top of fuel pool cooling suction line that is at approximately 214'-11" (References 11, 14 through

2. Level adequate to provide substantial radiation shielding for a person standing on spent fuel pool operating deck - Elevation 1/8" is approximately _0" above 1/8", the point of fuel both Unit 1 and 2 (plus or minus 1 (Reference 10 - FSAR Section 9.1.2.2 figure 9.1.2-1 (Sh. 1 of 2) and References 11 & 12).

3. Level where fuel remains covered - Elevation 1/8/J is the nominal of the fuel rack 10 FSAR Section 9.1.2.2 and 9.1.2-1 (Sh. 1 of 2)

References 11 &

IV. Instruments of the instruments will consistent with the of NRC JLD-ISG-2012-03 and NEI 12-02 with the exceptions and clarifications as

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

plan is for both to utilize Wave which functions to principle Time Domain Reflectometry (TOR). A of electromagnetic energy down the probe. Upon reaching the liquid the pulse is reflected and based upon reflection times, level is inferred.

.. The will be continuous from top of the spent fuel racks at elevation 9.1.2-1 10f and KPTPrp

.. Instrument level sensing components (probe) will located in SFP directly adjacent to the fuel. The module will of located in a non-harsh environment area VEGP-1 & 2 RSFPI Integrated Plan 5 of 15 2/27/2013 12:21 PM

• 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 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 NEI12 -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 cons istent with NEI 12-02 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 [\\EI12-02 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 NEI12-06) 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.

VEGP-1 & 2 RSFPI Integrated Plan Page 6 of 15 2/27/2013 12:21 PM

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 (Reference 13).

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 NEI 12-06 if conditions are degrading as indicted 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 IS09001) with shock and vibration requirements included in the purchase specification and/or instrument design, and commercial design and testing for operation in environments where VEGP-1 & 2 RSFPI Integrated Plan Page 7 of 15 2/27/2013 12:21 PM

significant shock vibration loadings are common, as for hand-held devices or transportation applications;

\II Substantial history of operational reliability in environments with significant shock and vibration loading, such as transportation applications; or

\II components inherently resistant to shock vibration loadings or are seismically reliable such as For seismic impact on instrument channel components after a potential event for installed components, the following measures will to verify design and installation is adequate. Applicable components the instrument channels are rated by the manufacturer (or otherwise tested) for seismic impact at commensurate with those of postulated basis event in area of channel component use using one or more the following methods (note different methods may used for the various sub components of the primary and p instrument chan

\II Adequacy of seismic design and installation is demonstrated on the guidance in Sections 7, 8, 9, and 10 of IEEE IEEE Recommended Practice for Seismic Qualification of 1E Equipment for Nuclear Power Stations, (Reference 9) or a substantially similar industrial standard

\II Instrument channel components use known operating principles, are supplied by manufacturers with commercial quality programs (such as 1509001) with seismic requirements included in the specification and/or instrument design, and commercial design and in where seismic oU,>r1"c are common

\II history of operational reliability in environments with vibration, such as for portable hand-held devices or transportation applications

\II Demonstration of seismic reliability methods the performance by:

Analysis of the equipment under simulated seismic conditions

• Using a combination of test

• use of data.

\II Demonstration that proposed devices are substantially similar in design to models have been tested seismic effects in excess of plant design at the location the instrument is to ranges)

\II qualification seismic motion consistent with of existi ng loading at the installation location.

VEGP-l & 2 RSFPI Page 8 of 15 2/27/2013 12:21 PM

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 within the resolution requirements of Figure 1 of NEI 12-02 .

G. Testing Instrument channel design will provide for routine testing and calibration consistent with Order EA-12-051 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 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.

VEGP-1 & 2 RSFPI Integrated Plan Page 9 of 15 2/27/2013 12:21 PM

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 with the NE112-02 characteristics. If multiple display locations are powered from the instrument loop, then the guidance in NE112-02 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 JLD-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 NEI12-02.

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 Design 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 NRC JLD-ISG-2012-03, the six-month reports will delineate progress made, any VEGP-l & 2 RSFPI Integrated Plan Page 10 of 15 2/27/2013 12:21 PM

in our compliance methods, updates to the schedu and, if and their IX. References

1) Issuance of Order to Mod with to Spent Fuel Pool Instrumentation, March 2012

2) EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation for External March 2012

3) NRC JLD-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Pool Instrumentation, Revision 0, August 2012

4) NEI Industry for Compliance with NRC EA-12-051, Modify Licenses with Regard to Reliable Spent Pool Instrumentation," Revision 1, August 2012

5) NEI Diverse and Flexible Coping (FLEX) Implementation Guide, Revision 0, August 2012

6) Letter, NL-12-2152, Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requirements Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), October 2013

7) Letter NL-12-2147, Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events Number d 2013

8) IS09001, Quality management systems - Requirements IEEE Standard IEEE Recommended Practice for Seismic Qualification Class lE Equipment for Nuclear Power Stations

10) Vogtle Nuclear Plant Unit 1 and 2 Safety Reports, Revision 18, 12-05-12

11) lX5DT0037, Ver. 0, "Level Setting Diagram Spent Fuel Pool Pit" 2X5DT0037, Ver. 0, "Level Diagram Spent Fuel Pool Pit" AX6D004, Ver. 0.0, Handling Bldg Floor Plan EI 220 ft 0 in EI 263 ft 8 in Levell and 3 Seismic Category"

14) lK7-1213-001-01, Ver. "Spent Fuel Pit Cooling Sys Fab Iso Fuel Bldg Area 3A Lvi A" lK7-1213-002-01, Ver. 10.0, "Spent Fuel Pit Cooling Sys Fab Iso Fuel Handling Bldg Area 3A Lvi A" 2K7-1213-001-01, Ver. "Fab Iso"

17) Ver. 7.0, "Spent Fuel Pit Sys Fuel Bldg Area 3A, A" VEGP-l & 2 Integrated Plan 11 15 2/27/2013 12:21 PM

Attachment 1: Probe Location Sketch I

North NOTE:

1. Snapshot taken from Reference 13.

• - Potential Probe 1 Location and 0 - Potential Probe 2 Location FNP-1 & 2 RSFPI Integrated Plan Page 12 of 15 2/27/2013 12:21 PM

Attachment 2: Electrical Sketches (Page lof3) aUlA

~ .tC~w ~'Z~

lL!J J... ..~ u"'""

-=-'"""'"

<l

.~- .@

~-- -@1!' -"" .." ~,,1

""e l '- ....It

(;""Ge

- ....u WIll . .

}-----@ .oclOPVT_ au.

~IN_

-~-

HNP 1 & 2 SFPI Integrated Plan Page 13 of 15 2/27/2013 12:21 PM

r f I I

I§ i

,r i

l

I

!I l

I --.

I 1~' I

- 11- ~I m

o m

Q)

--::G tlD nJ 0..