Text

Completion of Required Action for NRC Order EA-12-049 and EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation
	ML15324A243
Person / Time
Site:	Vogtle
Issue date:	11/20/2015
From:	Pierce C; Southern Co, Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, EA-12-051, NL-15-1777
	Download: ML15324A243 (34)
	v • d • e

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

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40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN Fax 205.992.7601 UCLEAR A SOUTHERN COMPANY NOV 2 0 2015 Docket No.: 50-424 NL-15-1777 50-425 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Order Modifying Liqenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directs the Vogtle Electric Generating Plant - Units 1 and 2 (VEGP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. This letter, along with Enclosure 1, provides the notification required by Item IV.C.3 of Order EA-12-049 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for VEGP Unit 1.

On March 12, 2012, the NRC also issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, to SNC. This Order was effective immediately and directed VEGP Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in of the Order. By letter dated December 1, 2014, Vogtle Electric Generating Plant-Unit 2 Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation, SNC indicated full compliance of Order EA-12-051 for VEGP Unit 2. This letter, along with Enclosure 2, provides the notification required by Item IV.C.3 of Order EA-12-051 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for VEGP Unit 1. provides the documented responses for VEGP Unit 1 to the NRC Requests for Information for Reliable Spent Fuel Pool Level Instrumentation.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

U.S. Nuclear Regulatory Commission NL-15-1777 Page2 Mr. C. R. Pierce states he is the Regulatory Affairs Director for 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.

Ree.tt~med, C. R. Pierce Regulatory Affairs Director CRP/JMG/MRE

~=:2ribed befo~me this Notary Pliblic ~

My commission expires: I()" 8 ~;Jot 1

Enclosures:

1. Compliance with Order EA-12-049

2. Compliance with Order EA-12-051

3. SNC Responses to NRC Requests for Information for Reliable Spent Fuel Pool Level Instrumentation cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President- Vogtle 1& 2 Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President - Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation Enclosure 1 Compliance with Order EA-12-049

Enclosure 1 to NL-15-*1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049 Introductio n On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Reference 1), to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directed the Vogtle Electric Generating Plant (VEGP)- Units 1 and 2 to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049. SNC developed an Overall Integrated Plan (OIP) (Reference 2) to provide FLEX. The information provided herein, as well as the implementation of the OIP, documents full compliance for VEGP Unit 1 in response to the Order (Reference 1).

Open Item Resolution Issues from the NRC Interim Staff Evaluation (ISE) (Reference 7) and Audit Report (Reference 12) have been addressed by SNC. The issues that were identified as open and pending in the NRC tracking system are listed below:

ISE Open Item (ISE 01) - ISE 01 3.2.4.1 O.A which was closed by the Audit Report (Reference 12).

Licensee Identified Open Items- VEGP UNIT 1 has no open or pending licensee identified open items- The SAFER Response Plan for Vogtle Electric Generating Plant was completed in June 2015.

The VEGP Unit 1 FLEX Audit Questions/Audit Report had no open items.

Milestone Schedule - Items Complete VEGP Unit 1 Milestone Completion Date Submit 20 Day Letter Acknowledging Receipt of Order March 2012 Submit Overall Integrated Plan February 2013 1st 6 Month Update August 2013 2"d 6 Month Update February 2014 Unit 1 - 1st Refueling Outage April2014 3rd 6 Month Update Aug~st 2014 4th 6 Month Update February 2015 Develop Modifications March 2015 Develop Training Material June 2015 Develop Strategies (Vogtle Response Plan) with. June 2015 National SAFER Response Center 5th 6 Month Update August2015 Develop Operational Procedure Changes October 2015 Unit 1 Walk-throughs or Demonstrations October 2015 Unit 1 - 2"d Refueling Outage /Implementa tion Complete October 22, 2015 Develop FSGs October 2015 E1-1 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049 VEGP Unit 1 Milestone Completion Date Issue FSGs October 2015 Implement Training October 2015 Phase 2 Equipment Procurement Complete for Unit 1 October 2015 Order EA-12*049 Compliance Elements Summary The elements identified below for VEGP Unit 1 as well as the FLEX OIP (Reference 1),

the 6-Month Status Reports (References 6, 8, 10, 11, and 13) and additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies

Complete VEGP Unit 1 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items.

Modification s - Complete The modifications required to support the FLEX strategies for VEGP Unit 1 have been fully implemented in accordance with the station processes.

Equipment - Procured and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for VEGP Unit 1 has been procured, received at VEGP, initially tested and performance verified as recommended in accordance with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and is available for use.

Maintenance and testing requirements are included in the VEGP Preventative Maintenance Program such that equipment reliability is monitored and maintained. All maintenance and testing activities have been identified. All six month or less PM's have been developed and performed. One year or greater PM's to be developed prior to the first due date. Technical Evaluation Quality Record No. 937199 has been generated to ensure all PM's are in place prior to required due date.

Protected Storage

Complete The storage facility required to implement the FLEX strategies for VEGP Unit 1 has been constructed and provides adequate protection from the applicable site hazards. The equipment required to implement the FLEX strategies for VEGP Unit 1 is stored in its protected configuration.

Procedures

Complete FLEX Support Guidelines (FSGs) for VEGP Unit 1 have been developed and integrated with existing procedures. The FSGs and applicable procedures have been verified and are available for use in accordance with the site procedure control program.

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Enclosure 1 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049 Training - Complete Training for VEGP Unit 1 has been completed in accordance with an accepted training process, as recommended in NEI12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

Staffing - Complete The VEGP Phase 2 staffing study for VEGP (Reference 14) has been completed in accordance with 10 CFR 50.54(f) letter (Reference 15). The NRC has reviewed the Phase 2 staffing study and concluded that it adequately addresses the response strategies needed to respond to a beyond design basis external event using Vogtle procedures and guidelines: This is documented in NRC letter dated September 29, 2014 (Reference 16).

Communications - Complete VEGP committed to compliance with the communications capabilities in accordance with the 10 CFR 50.54(f) letter (Reference 15). Implementation of the backup satellite service ultimately did not include shared cellular or data capability as originally planned; however, those capabilities were not relied on for compliance. The Rapidcom system has the capability to provide data communications should the TSC deem it is needed.

National SAFER Response Centers - Complete SNC has established a contract with Pooled Equipment Inventory Company (PEl Co) and has joined the Strategic Alliance for FLEX Emergency Response (SAFER) Team Equipment Committee for off-site facility coordination. It has been confirmed that PEICo is ready to support VEGP 1 and 2 with Phase 3 FLEX equipment stored in the National SAFER Response Centers in accordance with the site specific SAFER Response Plan.

Validation - Complete SNC has completed validation in accordance with industry developed guidance to assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the FLEX OIP for Order EA-12-049 (References 1 and 2).

FLEX Program Document - Established The SNC VEGP FLEX Program Documen~ has been developed in accordance with the requirements of NEI12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012.

E1-3 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049

2. Vogtle Electric Generating Plant - Units 1 and 2 Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27,2013.

3. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance .with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012.

4. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012.

5. Vogtle Electric Generating Plant - Units 1 and 2 Initial Status Report in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated October 23, 2012.

6. Vogtle Electric Generating Plant - Units 1 and 2 First Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated August 27, 2013.

7. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2- Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS. MF0714 and MF0715), dated January 16,2014.

8. Vogtle Electric Generating Plant - Units 1 and 2 Second Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 26, 2014.

9. NRC Letter, Relaxation of Certain Schedule Requirements for Order EA-12-049, dated April14, 2014.

10. Vogtle Electric Generating Plant - Units 1 and 2 Third Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049) dated August 26, 2014, including Enclosure 2- Vogtle Units 1&2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

11. Vogtle Electric Generating Plant - Units 1 and 2 Fourth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 26, 2015.

12. NRC letter, Vogtle Electric Generating Plant, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF0714, MF0715, MF0723, and MF0724), dated August 25,2015. *

13. Vogtle Electric Generating Plant - Units 1 and 2 Fifth Six-Month Status Report of the Implementation of the Requirements of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated August 27, 2015.

E1-4 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-049

14. Vogtle Electric Generating Plant- Units 1 and 2 Response to Request for Information Pursuant to Title 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the NTIF Review of Insights from the Fukushima Daiichi Accident, dated March 12,2012, dated May 16, 2014.

15. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force R*eview of Insights from the Fukushima Dai-lchi Accident, dated March 12, 2012.

16. NRC Letter, Response Regarding Licensee Phase 2 Staffing Submittals Associated With Near-Term Task Force Recommendation 9.3 Related To The Fukushima Dai-lchi Nuclear Power Plant Accident, dated September 29, 2014 (ML14262A296).

17. Vogtle Electric Generating Plant Notification of Commitment Completion - NTIF Recommendation 9.3, dated October 15, 2015.

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Vogtle Electric Generating Plant - Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation Enclosure 2 Compliance with Order EA-12-051

Enclosure 2 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-051 BACKGROUND On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Reference 2), to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directed the Vogtle Electric Generating Plant (VEGP) - Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order.

The compliance date for VEGP Unit 1 was October 22, 2015. The information provided herein documents full compliance for VEGP Unit 1 in response to the Order.

COMPLIANCE Vogtle Electric Generating Plant has installed two independent full scale level monitors on the Unit 1 Spent Fuel Pool (SFP) in response to Reference 2. The VEGP site has two fuel pools (one for each unit) operated independently. Reference 13 documents full compliance of Unit 2 in response to this Order.

In accordance with SNC letter dated February 27,2013 (Reference 1), VEGP Uf!it 1 stated compliance with Reference 2 would coincide with implementation of Order EA-12-049, Order to Modify Licenses with Regard to Mitigation Strategies for Beyond-Design-Bases External Events (Reference 3).

Following SNC submittal of the VEGP Overall Integrated Plan (Reference 1), the NRC provided its interim staff evaluation and requested additional information necessary for completion of the review (Reference 9). The requested information previously provided to the NRC is included in Enclosure 3.

The VEGP Unit 1 Spent Fuel Level Indication Audit Questions/Audit Report (Reference 15) had no open items. However during the site walkdown routing of the Unit 2 SFPI cabling, the NRC staff observed that the cable from the sensor to the wall, crossing the walkway, was routed in the flexible conduit. The flexible conduit did not provide sufficient protection from damages caused by traffic and internal missiles. In response to the NRC staff's concern, SNC generated Technical Evaluation Quality Record No. 921511, in which it states that SNC will add additional protection to the flexible conduit at the Unit 2 SFP level probe brackets and either use rigid conduit or install additional protection to the flexible conduit for VEGP Unit 1 SFP level probe brackets. Work Order SNC680490 was issued to perform the design enhancement. This action has been completed. The Unit 1 conduit design was enhanced prior to installation incorporating ridged conduit all the way to the sensor.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORIN G* COMPLETE VEGP Unit 1 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. With Unit 1 in compliance with Order EA-12-049, Operations procedures have integrated the full capability of the Unit 1 & Unit 2 SFP level indication systems.

INSTRUMENT DESIGNED FEATURES

COMPLETE The design of the instruments installed at VEGP Unit 1 complies with the requirements specified in Reference 2 and described in NEI 12-02 "Industry Guidance for Compliance E2-1

Enclosure 2 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-051 with NRC Order EA-12-051." The instruments have been installed in accordance with the station design control process.

The instruments are arranged to provide reasonable protection against missiles and are mounted to retain design configuration during and following the maximum expected ground motion. The instruments are designed to be reliable at expected environmental and radiological conditions including extended periods when the SFP is at saturation. The instruments are independent of each other and have separate and diverse power supplies. The instruments are designed to maintain their designed accuracy following a power interruption and to allow routine testing and calibration.

The SFP instrument display is readily accessible during postulated events and allows level information to be promptly available to decision makers.

PROGRAM FEATURES - COMPLETE Training for VEGP Unit 1 is complete and was performed in accordance with an accepted training process (Systematic Approach to Training) as recommended in NEI 12-02, Section 4.1.

Operating and maintenance procedures for VEGP Unit 1 have been developed and integrated with existing procedures. Procedures have been verified and are available for use in accordance with the site procedure control program.

Site processes have been established to ensure the instruments are maintained at their design accuracy.

MILESTONE SCHEDULE -ITEMS COMPLETE VEGP Unit 1 Milestone Completion Date Submit 20 Day Letter Acknowledging Receipt of Order March 2012 Submit Overall Integrated Plan February 2013 51 1 6 Month Update August2013 2"d 6 Month Update February 2014 Unit 1 - 1st Refueling Outage Apri12014 3rd 6 Month Update August2014 Instrument Design Complete December 2014 Receipt of Unit 1 SFP Instrument Channel December 2014 4th 6 Month Update February 2015 Complete Functional Test of Unit 1 SFPI July 2015 5th 6 Month Update August2015 Procedures and Training Complete '

September 2015 Unit 1 - 2"d Refueling Outage /Implementation Complete October 22, 2015 E2-2

Enclosure 2 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-051 Based on the above, the requirements of Order EA-12-051 have been achieved for VEGP Unit 1. A summary of VEGP Unit 1 compliance with the Order is provided as follows:

COMPLIANCE ELEMENTS

SUMMARY

In accordance with NRC Order EA-12-051, VEGP shall have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel:

(1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred.

The VEGP Unit 1 Spent Fuel Pool Level Indication System (SFPLIS) is capable of measuring SFP level from approximately ten inches above the top of the fuel racks to approximately one foot below the top of the SFP. A visual aid is included with the SFPLIS display units which indicates the three key SFP levels required by the Order.

1. In accordance with NRC Order EA-12-051, the spent fuel pool level instrumentat ion shall include the following design features:

a. Instruments: The instrumentat ion shall consist of a permanent, fixed primary instrument channel and a backup instrument channel. The backup instrument channel may be fixed or portable.

Two independent level detectors have been permanently installed in the Unit 1 SFP. The level detectors are redundant and either may be used as the primary device with the other acting as the backup device.

b. Arrangement: The spent fuel pool level instrument channels shall be arranged in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the spent fuel pool. This protection may be provided by locating the primary instrument channel and fixed portions of the backup instrument channel, if applicable, to maintain instrument channel separation within the spent fuel pool area, and to utilize inherent shielding from missiles provided by existing recesses and corners in the spent fuel pool structure.

The detectors are located in opposing sides of the SFP, separated by a distance greater than the shortest length of a side of the pool, which provides reasonable protection of the level indicating function against missiles that may result from damage to the structure over the SFP.

c. Mounting: Installed instrument channel equipment within the spent fuel pool shall be mounted to retain its design configuration during and following the maximum seismic ground motion considered in the design of the spent fuel pool structure.

E2-3 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-051 The sensing elements, detectors and display units are seismically qualified and mounted, consistent with the VEGP Unit 1 licensing bases.

d. Qualification : The primary and backup instrument channels shall be reliable at temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for an extended period. This reliability shall be established through use of an augmented quality assurance process (e.g., a process similar to that applied to the site fire protection program).

The sensing elements located in the Fuel Handling Building (FHB) are designed and constructed to be reliable at temperature, humidity, and radiation levels consistent with the SFP water at saturation conditions for an extended period.

Westinghouse, supplier of the SFPLIS, has qualified the equipment through a quality assurance process.

e. Independence: The primary instrument channel shall be independent of the backup instrument channel.

The two instrumentation channels are independent. No equipment is shared between the two channels. Each channel has independent conduit runs and the conduit runs inside the FHB have been routed to provide adequate channel separation.

f. Power supplies: Permanently installed instrumentat ion channels shall each be powered by a separate power supply. Permanently installed and portable instrumentat ion channels shall provide for power connections from sources independent of the plant ac and de power distribution systems, such as portable generators or replaceable batteries. Onsite generators used as an alternate power source and replaceable batteries used for instrument channel power shall have sufficient capacity to maintain the level indication function until offsite resource availability is reasonably assured.

The instrumentation channels are each powered from separate uninterruptable power supplies (UPS). The UPS for each channel is capable of powering the instrument for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Onsite portable generators will be used to supply power to the instruments should an extended loss of AC power occur. A 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months battery life is sufficient time to obtain a portable generator and connect to the SFPLIS. The site acceptance test confirmed the ability of the batteries to power the channels for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

g. Accuracy: The instrument channels shall maintain their designed accuracy following a power interruption or change in power source without recalibration.

The channels are designed to maintain accuracy following a power interruption.

This feature was confirmed during the site acceptance test.

h. Testing: The instrument channel design shall provide for routine testing and calibration.

E2-4 to NL-15-1n7 Vogtle Electric Generating Plant - Unit 1 Compliance with Order EA-12-051 The channels are designed for routine testing and calibration. These features were confirmed during the site acceptance test.

i. Display: Trained personnel shall be able to monitor the spent fuel pool water level from the control room, alternate shutdown panel, or other appropriat e and accessible location. The display shall provide on-demand or continuou s indication of spent fuel pool water level.

The displays provide continuous level indication and are easily accessible by operators. The transmitters and display units are located in the Control Building Level 1 B train electrical chase, CB-R152.

2. In accordance with NRC Order EA-12-051, the spent fuel pool instrumen tation shall be maintained available and reliable through appropriat e developm ent and implemen tation of the following programs:

a. Training: Personnel shall be trained in the.use and the provision of alternate power to the primary and backup instrumen t channels.

The Systematic Approach tq Training process has been used to evaluate and develop personnel training for the SFPLIS.

I&C Technicians: The CRC determined that current task training is adequate to support maintenance and calibration of the new level detection system.

Accordingly, no additional training is required.

Operations: CRC determined that formal training is not required. Skill of the craft and instructions within approved procedures are adequate to monitor displays and to supply backup power, if needed. Training of Operations personnel was conducted to familiarize them with the location of the displays and the procedures associated with this new system.

b. Procedures: Procedures shall be establishe d and maintained for the testing, calibration, and use of the primary and backup spent fuel pool instrumen t channels.

The following procedures have been either updated or created for testing, calibration and use of the SFPLIS:

18030-1 Loss of Spent Fuel Cooling Added new SFPLIS channels for monitoring SFP level in a Beyond Design Basis Event.

19100-1 ECA-0.0 Loss of All AC Power Added directions to initiate SFP level monitoring level per 18030-C.

NMP-OS-019-362 Vogtle Unit 1 SIG-2. 480V Power New procedure which provides instructions for connecting remote power to the SFPLIS from the 480V FLEX Diesel Generator.

11883-1 Radwaste Rounds Sheets Added weekly check/comparison of SFPLIS level displays with the SFP ruler level and check of battery alarms.

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Enclosure 2 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1

. Compliance with Order EA-12-051

23981-1 Spent Fuel Pool Level Indication System 1L-5330 Channel Calibration New procedure which provides instructions for calibration of new SFPLIS and UPS alarm response.

23982-1 Spent Fuel Pool Level Indication System 1L-5331 Channel Calibration New procedure which provides instructions for calibration of new SFPLIS and UPS alarm response.

NMP-OS-019-013: BDB Equipment Unavailabilitv Tracking New procedure which provides instructions for tracking unavailability time of the new SFPLI system

c. Testing and Calibration: Processes shall be established and maintained for scheduling and implementin g necessary testing and calibration of the primary and backup spent fuel pool level instrument channels to maintain the instrument channels at the design accuracy.

Preventive Maintenance Change Requests (PMCR's) were generated to establish frequency of testing/calibration of the SFPLIS:

79288 - SFPLIS Channel 1L-5330 Calibration, 18 month

79289 - SFPLIS Channel 1L-5331 Calibration, 18 month UPS Battery replacement will be based on periodic testing of the batteries.

Battery testing is performed during calibration procedures 23981-1 and 23982-1.

REFERENCES The following references support the VEGP Unit 1 compliance with the requirements of Order EA-12-051 :

1. SNC letter NL-13-0173, Vogtle Electric Generating Plant Units 1 and 2 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 27, 2013.

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

3. NRC Order EA-12-049, Order to Modify Licenses with Regard to Mitigation Strategies for Beyond-Design-Bases External Events, dated March 12, 2012.

4. SNC letter NL-12-0620, Answer to the March 12,2012 Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-51 ),

dated March 27, 2012.

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Enclosure 2 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-051

5. SNC Jetter NL-12-2152, Vogtle Electric Generating Plant- Units 1 and 2 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.

6. NRC Jetter, Vogtle Electric Generating Plant, Units 1 and 2- Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated June 18, 2013.

7. SNC Jetter NL-13-1460, Vogtle Electric Generating Plant- Units 1 afJd 2 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated July 17, 2013.

8. SNC Jetter NL-13-1767, Vogtle Electric Generating Plant- Units 1 and 2, First Six-Month Status Report of Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated August 27, 2013.

9. NRC letter, Interim Staff Evaluation and Request for Additional Information Vogtle Electric .

Generating Plant Units 1 and 2 Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated November 4, 2013.

10. SNC Jetter NL-14-0185, Vogtle Electric Generating Plant- Units 1 and 2, Second Six-Month Status Report of Implementation of the Requirements of the Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated February 26,2014.

11. NRC Letter, Relaxation of Certain Schedule Requirements for Order EA-12-049, dated April 14, 2014.

12. SNC letter NL-14-1111, Vogtle Electric Generating Plant- Units 1 and 2, Third Six-Month Status Report of the Implementation of the Requirements for Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated August 26, 2014.

13. SNC letter NL-14-1745, Vogtle Electric Generating Plant- .Unit 2, Completion of Required Action by NRC Order EA-12-051 Reliable Spent fuel Pool Lave/Instrumentation, dated December 10,2014.

14. SNC letter NL-15-0241, Vogtle Electric Generating Plant- Units 1 and 2, Fourth Six-Month Status Report of the Implementation of the Requirements for Commission Order with Regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated February 26, 2015.

15. NRC Letter, Vogtle Electric Generating Plant, Units 1 and 2- Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAG NOS. MF0714, MF0715, MF0723, and MF0724), dated August 25, 2015.

16. SNC Jetter NL-15-1155, Vogtle Electric Generating Plant- Units 1 and 2, Fifth Six-Month Status Report of the Implementation of the Requirements for Commission Order with regard to Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated August 27, 2015.

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Vogtle Electric Generating Plant- Unit 1 Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation Enclosure 3 SNC Responses to NRC Requests for Information

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Enclosure 3 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information The information provided below is generally a culmination of the material previous shared with the NRC on March 25, 2014 and June 29, 2014 in response to the NRC letter, Interim Staff Evaluation and Request for Additional Information - Vogtle Electric Generating Plant Units 1 and 2 Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated November 4, 2013. Some information has been updated and/or revised.

NRC RAI1:

Please identify the final SFP level instrumentation measurement range.

SNC Response to RA1:

The intended SFP level instrumentation measurement range is 219'-0" to 194'-6" (+/- 1 ft.

of the top of the fuel rack, consistent with NEI 12-02).

NRC RAI2:

Please provide additional information describing how the proposed arrangement of the guided wave radar and routing of the cabling between the radar probe and the electronics in the unspecified location meets the Order requirement to arrange the SFP level instrument channels in a manner that provides reasonable protection of the level indication function against missiles that may result from damage to the structure over the SFP.

SNC Response to RA2:

A plan view sketch of the SFP area is provided as Figure 1 (Page E3-9). The sketch depicts the placement -of the primary and alternate level sensors, and the routing of cables that extend toward the location of the electronics. Physical separation of the primary and alternate channels to the extent practicable and comparable to the short side of the pool, is used to provide reasonable protection of the level indication function against missiles that may result from the damage to the structure over the SFP.

NRC RAI3:

Please provide the following:

a) 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.

b) 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.

E3-1 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 SNC Responses to NRC Requests for Information SNC Response to RA3:

a) The mounting bracket will be attached to the SFP concrete floor utilizing expansion-type concrete anchor bolts. The level sensor consists of a stranded stainless steel cable level probe that is threaded on the top end. The probe attaches (threads) into a coupling that is secured to the mounting bracket launch plate and extends down into the pool. The attachment to the signal cable is via a coaxial connection on the top side of the launch plate coupling.

The simplified drawing below shows a representation of the attachment of the probe and the sensor cable to the mounting bracket (launch plate), and mounting bracket attachment to the SFP structure.

Cable Probe E3-2

Enclosure 3 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 SNC Responses to NRC Requests for Information b) The level sensor (probe) is designed to be attached near its upper end to the mounting bracket, as described in the response to RAI 3a above. The mounting bracket will be attached to the SFP concrete floor utilizing expansion-type concrete anchor bolts. The mounting bracket to the SFP structure concrete floor anchorage is designed to meet the requirements of the Vogtle design and licensing basis for Seismic Category I components including seismic loads, static weight loads and hydrodynamic loads.

NRC RAI4:

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.

SNC Response to RAI 4:

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 are provided in the Attachment to this enclosure.

NRC RAI5:

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.

SNC Response to RAI 5:

The design inputs, and the methodology that was used to qualify the structural integrity of the affected structures/equipment for each of the mounting attachments required to attach SFP Level equipment to plant structures are provided in the Attachment to this Enclosure.

NRC RAI6:

Please provide the following:

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 a) the level sensor mounted in the SFP area, and b) 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.

a) 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.

E3-3

Enclosure 3 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information SNC Response to RAI 6:

The information used to confirm the reliability of the permanently installed equipment such that following a seismic event the instrument will maintain its required accuracy is provided in the Attachment to this Enclosure.

NRC RAI7:

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.

SNC Response to RAI 7:

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 are provided in the Attachment to this Enclosure.

NRC RAI8:

Please provide the NRC staff with the final configuration of the power supply source for each channel so that the staff may conclude that the two channels are independent from a power supply assignment perspective.

SNC Response to RAI 8:

The VEGP Unit 1 (Primary) Channel 1 (1 NCPSFP01) is supplied from 1NLP29-12, fed from MCC 1A8C "A" Train, fed from SWGR 1A805, fed from SWGR 1AA02.

The VEGP Unit 1 (Alternate) Channel2 (1NCSFP02) is supplied from 1NLP32-12, fed from MCC 188C "8" Train, fed from SWGR 18807, fed from SWGR 18A03.

NRC RAI9:

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

SNC Response to RAI 9:

The results of the calculation depicting the battery backup duty cycle requirements demonstrating that its capacity is sufficient to maintain the level indication function until offsite resource availability is reasonably assured are provided in the Attachment to this Enclosure.

NRC RAI10:

Please provide analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and 808 values. Please demonstrate that the E3-4

Enclosure 3 to NL-15-1n 7 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information channels will retain these accuracy performance values following a loss of power and subsequent restoration of power.

SNC Response to RAI 10:

Analysis verifying that the proposed instrument performance is consistent with these estimated accuracy normal and BDB values along with demonstration that the channels will retain these accuracy performance values following a loss of power and subsequent restoration of power is provided in the Attachment to this Enclosure.

NRC RAI11:

Please provide the following:

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

b) For any SFP level instrumentation displays located outside the main control room, please describe the evaluation used to validate that the display location can be accessed without unreasonable delay following a BDB 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 BDB event.

Describe whether personnel are continuously stationed at the display or monitor the display periodically.

SNC Response to RAI 11:

a) See Figure 2 (Page E3-10) for SFPLIS equipment location sketches.

The location of the display panels for VEGP Unit 2 is in room R-126 of the Control Building. The location of the display panels for Vogtle Unit 1 is in room R-152 of the Control Building.

b) The locations described in response to RAI11 (a) have been evaluated considering the accident conditions described in NEI 12-02 and NEI 12-06, using design inputs from Westinghouse, existing Station Blackout evaluations and NUMARC-8700, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors, dated November 20, 1987.

The results of the evaluation performed, to determine accessibility of the SFPLI displays following an ELAP event, indicate the displays can be accessed without unreasonable delay and without placing station personnel at undue risk with regards to temperature, humidity, and radiation levels.

The location of the display panels for Vogtle Unit 2 in room R-126 of the Control Building is approximately 180 feet from the West exit of the Control Room ." The location of the display panels for Vogtle Unit 1 in room R-152 of the Control E3-5

Enclosure 3 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Building is approximatel y 100 feet from the East exit of the Control Room.

Using a conservative walking pace of 1 mph, the Vqgtle Unit 1 and Unit 2 display locations will require Jess than 10 minutes to access the display location, perform local function and return to the Control Room. Validation performed determined the actual time for Vogtle Unit 2 is 3.5 minutes. With the displays located outside the Radiation Controlled Area, the substantial structures between the SFP and the pathway to the display, combined with the short transit duration, personnel traveling the pathways shown in Figure 2 will not require heroic means with the SFP at Level 3 or above.

The display location remains habitable considering the minimal time required to access the displays, distance from the SFP, substantial structures, and the Jack of heat producing equipment within the room during accident conditions. Both locations will allow for prompt, non-heroic access to the displays from the Control Room.

Operators are directed to periodically monitor the displays at two hour intervals during accident conditions.

NRC RAI12:

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.

SNC Response to RAI12:

Procedures have been developed to ensure these objectives:

Procedure Objectives to be achieved

1) System Rounds Weekly rounds are performed to confirm the SFPLIS agrees with the local level indication, that the SFPLIS channels are in agreement and that there are no battery alarms.

2) Calibration and Test To verify that the system is within the specified accuracy, is functioning as designed, and is appropriately indicating SFP water level.

3) Maintenance To establish and define scheduled and preventive maintenance requirements and activities necessary to minimize the possibility of system interruption.

4) Repair Work orders will be generated if repairs are necessary using the vendor manual as the basis for the work order.

5) Operation To provide sufficient instructions for operation and use of the system plant operation staff.

E3-6

Enclosure 3 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information

6) Responses To define the actions to be taken upon observation of system level indications, including actions to be taken at the levels defined in NEI 12-02. With Unit 1 in compliance with Order EA-12-049, Operations procedures have integrated the full capability of the Unit 1 & Unit 2 SFP level indication systems.

NRC RAI13:

Please provide the following:

a) Further information describing the maintenance and testing program the licensee will establish and implement to ensure that regular testing and calibration is performed and verified by inspection and audit to demonstrate conformance with design and system readiness requirements. Please include a description of the 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) Information describing compensatory actions when both channels are out-of-order, and the implementation procedures.

c) Additional information describing expedited and compensatory actions in the maintenance procedure to address when one of the instrument channels cannot be restored to functional status within 90 days.

SNC Response to RAI 13:

a) While the SFP is operating within design basis and at normal level, the indicators are compared to fixed marks within the SFP by visual observation to confirm indicated level weekly. A periodic calibration verification is performed within 60 days of a refueling outage considering normal testing scheduling allowances (e.g.,

25%). Calibration verification is not required to be performed more than once per 12 months. These calibration requirements are consistent with the guidance provided in NEI 12-02 section 4.3. Periodic calibration verification procedures are in place based on information provided by Westinghouse in WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure." Preventive maintenance procedures to include tests, inspection and periodic testing of batteries have been developed based on recommendation from Westinghouse.

b) A Condition Report will be initiated and addressed through the SNC's Corrective Action Program and the out of service (OOS) condition will be tracked in accordance with procedure NMP-OS-019-013. Provisions associated with out of service (OOS) or non-functional equipment including allowed outage times and compensatory actions are consistent with the guidance provided in Section 4.3 of NEI12-02. If one OOS channel cannot be restored to service within 90 days, appropriate compensatory actions, including the use of alternate suitable equipment, will be taken. If both channels become OOS, actions would be initiated within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore one of the channels to operable status and to E3-7 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 8NC Responses to NRC Requests for Information implements appropriate compensatory actions, including the use of alternate suitable equipment and/or supplemental personnel, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

c) Additionally, if both channels are 008, a Condition Report will be initiated and addressed through the 8NC's Corrective Action Program and the 008 condition will be tracked in accordance with procedure NMP-08-019 -013. 8NC will maintain sufficient spare parts for the 8FPI8, taking into account the lead time and availability of spare parts, in order to expedite maintenance activities, when necessary, to provide assurance that a channel can be restored to service within 90 days.

E3-8 to NL-15-1777 Vogtle Electric Generating Plant - Unit 2 SNC Responses to NRC Requests for Information Figure 1 Sketch on section from drawing: AX1 D09A04 E3-9 to NL-15-1 n7 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Figure 2 Sketch on section from drawing:

AX1 D11A04-4 E3-10 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Attachme nt- Design Requirements for Structural Integrity and Reliability (All Westinghouse Reference Documents below have been verified to be bounded by SNC Vogtle Plant Qualificatio n Criteria)

Parameter Westinghouse I

Topic Reference Additional Comment Test or Analysis Summary Results I Documen t# i 1 Design Specification SFPIS Requirements WNA-DS-02 957-GEN Contains technical SFPIS N/A I derived from requirements based on NRC References 1 , 2, & 3 order, NEI guidance, and the I ISG listed above. I 2 Test Strategy Per Requirements. WNA-PT-00 188-GEN Strategy for performing the N/A testing and verification of the SFPIS and pool-side bracket.

I 3 Environmental 50° F to 140° F, EQ-QR-269, Rev. 2 Results are summarized in Test passed conditions qualification for and EQ-QR-269, Rev. 2 and described.

Oto 95% RH electronics enclosure WNA-TR-03149-GEN.

WNA-TR-03 149-GEN with Display for all conditions.

TID s 1E03 R y I normal (outside SFP Radiation Aging verification area) summarized in Section 5 of WNA-TR-03149-GEN.

TID s 1E03 R y abnormal (outside SFP area) 4 Environmental 50 ° F to 212° F and EQ-QR-269, Rev. 2 Testing summarized in Passed Testing for Level 100% humidity Section 5.7.

Sensor components in SFP area-Saturated Steam & 1E03 R y normal (SFP WNA-TR-03 149-GEN Thermal Aging & radiation Passed Radiation area) aging verification summarized in Sections 4.1 and 5 (entire system) of WNA-TR-03 149-GEN ..

E3-11 to NL-15-1n7 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Parameter Westinghouse

Topic Reference Additional Comment Test or Analysis

, Summary Results I

Document#

I 1 E07 R y BOB (SFP EQ-QR-269, Rev. 2 Additional radiation aging Passed area) testing documented in Section 5.3. I 5 Environmental . 50° F to 140° F, EQ-QR-269, Rev. 2 Testing summarized in Passed Testing for Level Section 5.5.

I Oto 95% RH Sensor Electronics Housing - outside 100% RH WNA-TR-0314 9-GEN 100% humidity addressed in Passed I SFP Section 7 .5.

TID s 1E03 R y WNA-TR-0314 9-GEN Radiation Aging verification Passed I normal (outside SFP summarized in Section 5.

area)

TID s 1E03 R y abnormal (outside SFP area) !

6 Thermal & Radiation 1E03 R y normal (SFP EQ-QR-269, Rev. 2 Thermal Aging & radiation Passed Aging - organic area) and WNA-TR-0314 9- aging verification summarized components in SFP GEN in Sections 4.1 and 5 (entire area system) of WNA-TR-0314 9- I GEN. I 1 E07 R y BOB (SFP EQ-QR-269, Rev. 2 Additional radiation aging Passed area) testing documented in Section 5.3.

E3-12 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Westinghouse - .

Topic Parameter Test or Analysis Summary Reference Additional Comment Document# Results I

7 Basis for Dose SFP Normal LTR-SFPIS-13-35 and Explanation of Basis for Passed for all Requirement Conditions: Radiation Dose Requirement conditions WNA-DS-0295 7-GEN 1E03 R y TID (above (includes the clarification of I pool) production equivalency of I

electronics enclosure used for Seismic and EMC Testing) 1 E09 R y TID (1' above fuel rack)

I SFP BDBE Conditions: I I

1E07 R y TID (above pool)

< 1E07 R yTID (1 '

above fuel rack) 8 Seismic Qualification Per Spectra in WNA- EQ-QR-269, Rev. 2 Documented in Section 5.4. Passed DS-02957-GEN WNA-TR-03149-GEN WNA-TR-03149-GEN Passed provides high level summary of the pool-side bracket analysis and optional RTD.

EQ-QR-269, Rev. 2 Seismic Pull test for new Passed connectors documented in Section 4.4.

9 Sloshing N/A LTR-SEE-11-13-47 Calculation to demonstrate Passed that probe will not be sloshed out of the SFP.

E3-13 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Westinghouse -

Topic Parameter 'Test or Analysis

Refelience Additional *Comment Summary Results

Document#

WNA-TR-03149-GEN Sloshing is also addressed in Passed Section 7.2.

i 10 Spent Fuel Pool Acceptance Criteria WNA-TP-04613-GEN Test procedure used to See applicable EQ test.

Instrumentation for Performance demonstrate that SFPIS meet System Functionality during EQ testing its operational and accuracy Test Procedure requirements during I Equipment Qualification Testing programs.

11 Boron Build-Up Per requirement in WNA-TR-03149-GEN Boron build up demonstrated Passed WNA-DS-02957-GEN through Integrated Functional Test (1FT).

12 Pool-side Bracket N/A CN-PEUS-14-7, Rev. 1 Also includes hydrodynamic Passed Seismic Analysis forces, as appropriate.

13 Additional Brackets N/A WNA-DS-02957 -GEN Weights provided to licensees N/A (Sensor Electronics for their own evaluation.

and Electronics Enclosure) 14 Shock & Vibration WNA-DS-02957-GEN WNA-TR-03149-GEN Section 7 provides rationale N/A and summary of RTD.

15 Requirements Maps Requirements to WNA-VR-00408-GEN, The RTM maps the Complete Traceability Matrix documentation I Rev.1 requirements of the NRC evidence that order, NEI guidance, ISG to Requirement is met the applicable technical requirements in the SFPIS design specification and maps the design specification requirements to the documentation demonstrating

- - - ,_ the requirement is met.

E3-14 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Westinghouse Topic Parameter Test or Analysis

Reference Additional Comment Summary Results Document#

16 Westinghouse 1FT Functional WNA-TP-04752-GEN The Integrated Functional Pilot 1FT Factory Acceptance Requirements from Test (1FT) demonstrates executed/passed Test, including testing WNA-DS-02957-GEN functionality of the full system of dead-zones for each customer's FAT, which includes calibration of Vogtle functional each channel. checks executed/

passed 12" dead-zone at top WNA-TP-04752-GEN Dead-zone tests are in N/A of probe Section 9.6.2.

4" dead-zone at bottom of probe 17 Channel Accuracy +1- 3 inches per WNA- WNA-CN-00301-GEN Channel accuracy from Passed DS-02957-GEN measurement to display.

18 Power Consumption 3 day battery life WNA-CN-00300-GEN N/A Passed (minimum) 0.257 Amps power consumption 19 Technical Manual N/A WNA-G0-00127-GE N Information and instructions N/A for Operation, Installation, use, etc. are included here.

20 Calibration Routine WNA-TP-04709-GEN Also, includes preventative N/A Testing/calibration maintenance actions such as verification and those for Boron buildup and Calibration method cable probe inspection.

21 Failure Modes and N/A WNA-AR-00377-GEN Addresses mitigations for the N/A Effects Analysis potential failure modes of the (FMEA) system.

E3-15 to NL-15-1777 Vogtle Electric Generating Plant - Unit 1 SNC Responses to NRC Requests for Information Parameter Westinghouse

Topic Reference Additional Comment Test or Analysis

, summary Results Document#

22 Emissions Testing RG 1.180 R 1 test EQ-QR-269, Rev. 2 Documented in Section 5.6. Passed conditions

References:

1) ML12056A044, NRC Order EA-12-051, "ORDER MODIFYING LICENSES WITH REGARD TO RELIABLE SPENT FUEL POOL INSTRUMENTATION," Nuclear Regulatory Commission, March 12, 2012.

2) ML12240A307, NEI 12-02 (Revision 1), "Industry Guidance for Compliance with NRC Order EA-12-051, "To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation" August, 2012.

3) ML12221A339, Revision 0, JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable .Spent Fuel Pool Instrumentation", August 29, 2012, Nuclear Regulatory Commission Japan Lessons-Learned Project Directorate.

4) Westinghouse Proprietary Document, WNA-DS-02957-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product System Design Specification," Revision 4 reviewed by NRC in April 2014; current revision is Revision 4.

5) Westinghouse Proprietary Document, WNA-PT-00188-GEN, "Spent Fuel Pool Instrumentation System (SFPIS) Standard Product Test Strategy,"

Revision 1 reviewed by NRC in February 2014; NRC did not review in April; current revision is Revision 3.

6) Westinghouse Proprietary Document, EQ-QR-269, "Design Verification Testing Summary Report for the Spent Fuel Pool Instrumentation," Revision 1

reviewed by NRC in April2014; current revision is Revision 2.

7) Westinghouse Proprietary Document, WNA-TR-03149-GEN, "SFPIS Standard Product Final Summary Design Verification Report," Revision 1 reviewed by NRC in April2014; current revision is Revision 1.

8) Westinghouse Proprietary Document, LTR-SFPIS-13-35, "SFPIS: Basis for Dose Requirement and Clarification of Production Equivalency of Electronics Enclosure Used for Seismic Testing," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 1.

9) Westinghouse Proprietary Document, LTR-SEE-ll-13-47, "Determination if the Proposed Spent Fuel Pool Level Instrumentation can be Sloshed out of the Spent Fuel Pool during a Seismic Event," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.

10) Westinghouse Proprietary Document, WNA-TP-04613-GEN, "Spent Fuel Pool Instrumentation System Functionality Test Procedure," Revision 5 reviewed by the NRC in February 2014; NRC did not review in April; currc::nt revision is Revision 5.

11) Westinghouse Proprietary Document, CN-PEUS-14-7, "Seismic Analysis of the SFP Mounting Bracket at Farley Nuclear Plant and Vogtle Electric Generating Station," Revision 1; not reviewed by the NRC.

12) Westinghouse Proprietary Document, WNA-VR-00408-GEN, "Spent Fuel Pool Instrumentation System Requirement Traceability Matrix," Revision 0 reviewed by the NRC in April 2014; current revision is Revision 1.

E3-16 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 SNC Responses to NRC Requests for Information

13) Westinghouse Proprietary Document, WNA-TP-04752-GEN, "Spent Fuel Pool Instrumentation System Standard Product Integrated Functional Test Procedure," Revision 1 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 2.

14) Westinghouse Proprietary Document, WNA-CN-00301-GEN, "Spent Fuel Pool Instrumentation System Channel Accuracy Analysis," Revision 0 reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 2.

15) Westinghouse Proprietary Docqment, WNA-CN-00300-GEN, "Spent Fuel Pool Instrumentation System Power Consumption Calculation," Revision 0

reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 0.

16) Westinghouse Proprietary Document, WNA-G0-0012 7-GEN, "Spent Fuel Pool Instrumentation System Standard Product Technical Manual," Revision 1

reviewed by the NRC in April2014; current revision is Revision 3.

17) Westinghouse Proprietary Document, WNA-TP-04709-GEN, "Spent Fuel Pool Instrumentation System Calibration Procedure," Revision 3 was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.

18) Westinghouse Proprietary Document, WNA-AR-00377-GEN, "Spent Fuel Pool Instrumentation System Failure Modes and Effect Analysis," Revision 2

was reviewed by the NRC in February 2014; NRC did not review in April; current revision is Revision 4.

E3-17

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

c\

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN Fax 205.992.7601 UCLEAR A SOUTHERN COMPANY NOV 2 0 2015 Docket No.: 50-424 NL-15-1777 50-425 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation Ladies and Gentlemen:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Order Modifying Liqenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, to Southern Nuclear Operating Company (SNC). This Order was immediately effective and directs the Vogtle Electric Generating Plant - Units 1 and 2 (VEGP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. This letter, along with Enclosure 1, provides the notification required by Item IV.C.3 of Order EA-12-049 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for VEGP Unit 1.

On March 12, 2012, the NRC also issued Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, to SNC. This Order was effective immediately and directed VEGP Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in of the Order. By letter dated December 1, 2014, Vogtle Electric Generating Plant-Unit 2 Completion of Required Action by NRC Order EA-12-051 Reliable Spent Fuel Pool Level Instrumentation, SNC indicated full compliance of Order EA-12-051 for VEGP Unit 2. This letter, along with Enclosure 2, provides the notification required by Item IV.C.3 of Order EA-12-051 that full compliance with the requirements described in Attachment 2 of the Order has been achieved for VEGP Unit 1. provides the documented responses for VEGP Unit 1 to the NRC Requests for Information for Reliable Spent Fuel Pool Level Instrumentation.

This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.

U.S. Nuclear Regulatory Commission NL-15-1777 Page2 Mr. C. R. Pierce states he is the Regulatory Affairs Director for 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.

Ree.tt~med, C. R. Pierce Regulatory Affairs Director CRP/JMG/MRE

~=:2ribed befo~me this Notary Pliblic ~

My commission expires: I()" 8 ~;Jot 1

Enclosures:

1. Compliance with Order EA-12-049

2. Compliance with Order EA-12-051

3. SNC Responses to NRC Requests for Information for Reliable Spent Fuel Pool Level Instrumentation cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. B. K. Taber, Vice President- Vogtle 1& 2 Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. J. Adams, Vice President - Engineering Mr. D. R. Madison, Vice President- Fleet Operations Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Director of the Office of Nuclear Reactor Regulations Mr. L. D. Wert, Regional Administrator (Acting)

Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant- Unit 1 Completion of Required Action for NRC Orders EA-12-049 & EA-12-051 Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation Enclosure 1 Compliance with Order EA-12-049

Enclosure 1 to NL-15-*1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049 Introductio n On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Reference 1), to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directed the Vogtle Electric Generating Plant (VEGP)- Units 1 and 2 to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049. SNC developed an Overall Integrated Plan (OIP) (Reference 2) to provide FLEX. The information provided herein, as well as the implementation of the OIP, documents full compliance for VEGP Unit 1 in response to the Order (Reference 1).

Open Item Resolution Issues from the NRC Interim Staff Evaluation (ISE) (Reference 7) and Audit Report (Reference 12) have been addressed by SNC. The issues that were identified as open and pending in the NRC tracking system are listed below:

ISE Open Item (ISE 01) - ISE 01 3.2.4.1 O.A which was closed by the Audit Report (Reference 12).

Licensee Identified Open Items- VEGP UNIT 1 has no open or pending licensee identified open items- The SAFER Response Plan for Vogtle Electric Generating Plant was completed in June 2015.

The VEGP Unit 1 FLEX Audit Questions/Audit Report had no open items.

Milestone Schedule - Items Complete VEGP Unit 1 Milestone Completion Date Submit 20 Day Letter Acknowledging Receipt of Order March 2012 Submit Overall Integrated Plan February 2013 1st 6 Month Update August 2013 2"d 6 Month Update February 2014 Unit 1 - 1st Refueling Outage April2014 3rd 6 Month Update Aug~st 2014 4th 6 Month Update February 2015 Develop Modifications March 2015 Develop Training Material June 2015 Develop Strategies (Vogtle Response Plan) with. June 2015 National SAFER Response Center 5th 6 Month Update August2015 Develop Operational Procedure Changes October 2015 Unit 1 Walk-throughs or Demonstrations October 2015 Unit 1 - 2"d Refueling Outage /Implementa tion Complete October 22, 2015 Develop FSGs October 2015 E1-1 to NL-15-1777 Vogtle Electric Generating Plant- Unit 1 Compliance with Order EA-12-049 VEGP Unit 1 Milestone Completion Date Issue FSGs October 2015 Implement Training October 2015 Phase 2 Equipment Procurement Complete for Unit 1 October 2015 Order EA-12*049 Compliance Elements Summary The elements identified below for VEGP Unit 1 as well as the FLEX OIP (Reference 1),

the 6-Month Status Reports (References 6, 8, 10, 11, and 13) and additional docketed correspondence, demonstrate compliance with Order EA-12-049.

Strategies

Complete VEGP Unit 1 strategies are in compliance with Order EA-12-049. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/Audit Report Open Items.

Modification s - Complete The modifications required to support the FLEX strategies for VEGP Unit 1 have been fully implemented in accordance with the station processes.

Equipment - Procured and Maintenance & Testing - Complete The equipment required to implement the FLEX strategies for VEGP Unit 1 has been procured, received at VEGP, initially tested and performance verified as recommended in accordance with NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, and is available for use.

Maintenance and testing requirements are included in the VEGP Preventative Maintenance Program such that equipment reliability is monitored and maintained. All maintenance and testing activities have been identified. All six month or less PM's have been developed and performed. One year or greater PM's to be developed prior to the first due date. Technical Evaluation Quality Record No. 937199 has been generated to ensure all PM's are in place prior to required due date.

Protected Storage

Complete The storage facility required to implement the FLEX strategies for VEGP Unit 1 has been constructed and provides adequate protection from the applicable site hazards. The equipment required to implement the FLEX strategies for VEGP Unit 1 is stored in its protected configuration.

Procedures

Complete FLEX Support Guidelines (FSGs) for VEGP Unit 1 have been developed and integrated with existing procedures. The FSGs and applicable procedures have been verified and are available for use in accordance with the site procedure control program.