Text

Completion of Required Action for NRC Orders EA-12-049 and EA-12-051, Mitigation Strategies for Beyond-Design-Basis External Events and Reliable Spent Fuel Pool Level Instrumentation
	ML16124A737
Person / Time
Site:	Hatch
Issue date:	05/03/2016
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-16-0249
	Download: ML16124A737 (16)
	v • d • e

Charles R. Pierce Regulatory Affairs Director May 3, 2016 Docket No.: 50-321 Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN <<\\

NUCLEAR A SOUTHERN COMPANY NL-16-0249 Edwin I. Hatch Nuclear 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 Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directs the Edwin I. Hatch Nuclear Plant (HNP) - Units 1 and 2 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 HNP 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 HNP Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in of the Order. 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 of the Order has been achieved for HNP Unit 1.

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-16-0249 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.

Respectfully submitted, tr<.~

C. R. Pierce Regulatory Affairs Director CRP/JMG/MRE Swam to and su scribed before me this 3~ay of -Jlhy=

My commission expires: 1-Z- 2 0 I&'

Enclosures:

1. Compliance with Order EA-12-049

2. Compliance with Order EA-12-051 cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President-Hatch 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. L. Johnson, Regulatory Affairs Manager-Hatch RType: CHA02.004 U.S. Nuclear Regulatory Commission

'2016.

Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager-Hatch Mr. D. H. Hardage, Senior Resident Inspector-Hatch State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division

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Edwin I. Hatch Nuclear 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 Compliance with Order EA-12-049 to NL-16-0249 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-049 BACKGROUND 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 Edwin I. Hatch Nuclear Plant (HNP)- Units 1 and 2 to provide diverse and flexible strategies (FLEX) in response to Order EA-12-049. The information provided herein, as well as the implementation of the Overall Integrated Plan (OIP) (Reference 10, originally submitted in Reference 6), documents full compliance for HNP Unit 1 in response to the Order (Reference 1 ).

OPEN ITEM RESOLUTION There were no open items from the NRC Interim Staff Evaluation (ISE) (Reference 9) or Audit Report (Reference 14) but all identified items have been addressed and documented in the site CAP program. The one self-identified item from the OIP (reference 1 0) is listed below:

ISE Open Item (ISE 01)- HNP Unit 1 had no open or pending items Licensee Identified Open Items-HNP Unit 1 has no open or pending licensee identified open items -The SAFER Response Plan for Edwin I. Hatch Nuclear Plant was completed in June 2015.

FLEX Audit Questions/Audit Report Open Items-HNP Unit 1 had no open or pending items.

MILESTONE SCHEDULE - ITEMS COMPLETE HNP 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 February 2014 3'd 6 Month Update (with updated OIP)

August 2014 4th 6 Month Update February 2015 Develop Modifications October 2015 Develop Training Material November 2015 Develop Strategies (Hatch Response Plan) with June 2015 National SAFER Response Center 5th 6 Month Update August 2015 Develop Operational Procedure Changes November 2015 6th 6 Month Update February 2016 Unit 1 Walk-throughs or Demonstrations February 2016 Develop FSGs February 2016 E1-1 to NL 0249 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-049 HNP Unit 1 Milestone Issue FSGs Implement Training Phase 2 Equipment Procurement Complete for Unit 1 Unit 1 - 2"d Refueling Outage /Implementation Complete ORDER EA-12-049 COMPLIANCE ELEMENTS

SUMMARY

Completion Date February 2016 February 2016 February 2016 March 2016 The elements identified below for HNP Unit 1 as well as the FLEX OIP (Reference 1 0),

the 6-Month Status Reports (References 7, 8, 10,13,14 and 17) and additional docketed correspondence, demonstrate compliance with Order EA-12-049.

STRATEGIES-COMPLETE HNP Unit 1 strategies are in compliance with Order EA-12-049 per the guidance in NEI 12-06 Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, revision 0. There are no strategy related Open Items, Confirmatory Items, or Audit Questions/ Audit Report Open Items.

MODIFICATIONS-COMPLETE The modifications required to support the FLEX strategies for HNP Unit 1 have been fully implemented in accordance with the station procedures and processes.

EQUIPMENT-PROCURED AND MAINTENANCE & TESTING - COMPLETE The equipment required to implement the FLEX strategies for HNP Unit 1 has been procured, received at HNP, 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 HNP Preventative Maintenance (PM) Program such that equipment reliability is monitored and maintained. All maintenance and testing activities have been identified. All PM's for FLEX strategy mitigation equipment have been developed.

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

PROCEDURES - COMPLETE A FLEX Support Guideline (FSG) was developed to address a Beyond Design Basis (BOB) Extended Loss of all AC Power (ELAP), and Strategy Implementation Guidelines (SIGs) were developed to provide procedural guidance for operating FLEX Equipment and performing field activities to support that FSG.

E1-2 to NL-16-0249 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-049 TRAINING

COMPLETE Training for HNP 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 Phase 2 staffing study for HNP (Reference 12) has been completed in accordance with 10 CFR 50.54(f) letter (Reference 2). 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 Hatch procedures and guidelines. This is documented in NRC letter dated February 7, 2016 (Reference 16).

COMMUNICATIONS* COMPLETE HNP committed to compliance with the communications capabilities in accordance with the 10 CFR 50.54(f) letter (Reference 2). Implementation of the backup satellite service ultimately did not include shared cellular or data capability after originally planned, but does include additional satellite phone and UHFNHF capabilities for the main control room and TSC. The shared cellular and data capabilities were not relied on for compliance (Reference June 24, 2014 letter NL-14-0747 for the revised commitment date and the revised language, Reference 1 0). The Rapidcom system has the capability to provide data communications should the TSC deem it is needed. Completion of NTTF Recommendation 9.3 for both HNP Units 1 and 2 is documented in NRC letter dated March 14, 2016 (Reference 18).

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 HNP 1 and 2 with Phase 3 FLEX equipment stored in the National SAFER Response Centers in accordance with the HNP site specific SAFER Response Plan.

VALIDATION* COMPLETE SNC has completed validation and verification of FLEX strategies and time sensitive actions (TSAs) 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, 4, 6, and 11).

FLEX PROGRAM DOCUMENT* ESTABLISHED The SNC HNP FLEX Program Document has been developed in accordance with the requirements of NEI12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

E1-3 to NL-16-0249 Edwin I. Hatch Nuclear Plant - Unit 1 Compliance with Order EA-12-049

REFERENCES:

The following references support the HNP Unit 1 compliance with the requirements of Order EA-12-049:

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.

2. 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 Review of Insights from the Fukushima Dai-lchi Accident, dated March 12, 2012.

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. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 23, 2012.

6. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 27, 2013.

7. Edwin I. Hatch Nuclear 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.

8. Edwin I. Hatch Nuclear 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, Edwin I. Hatch Nuclear Plant, Units 1 and 2 - Interim Staff Evaluation Related to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAG NOS. MF0712 and MF0713), dated February 27, 2014.

10. Edwin I. Hatch -Commitment Change Notification Regarding Recommendation 9.3 dated June 23, 2104.

11. Edwin I. Hatch Nuclear 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 - Hatch Units 1 &2 Mitigation Strategies (FLEX) Overall Integrated Implementation Plan (OIP), Revision 4.

12. Edwin I. Hatch Nuclear 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 E1-4 to NL-16-0249 Edwin I. Hatch Nuclear Plant - Unit 1 Compliance with Order EA-12-049 NTTF Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012, providing the Hatch Phase 2 On-Shift Staffing Analysis report sent October 9, 2014.

13. Edwin I. Hatch Nuclear 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.

14. Edwin I. Hatch Nuclear 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.

15. NRC letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2 - Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC NOS. MF0712, MF0713, MF0721, and MF0722}, dated January 13,2016.

16. NRC Letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2-Response regarding Phase 2 Staffing Submittals associated with Near-Term Task Force Recommendation 9.3 related to the Fukushima Dai-ichi Nuclear Power Plant Accident (TAC NOS. MF5038 and MF5039) date February 7, 2016.

17. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Sixth 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 29, 2016.

18. Edwin I. Hatch Nuclear Plant Units 1 and 2, Notification of Commitment Completion

- NTTF Recommendation 9.3, dated March 14, 2016.

E1-5

Edwin I. Hatch Nuclear 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 Compliance with Order EA-12-051 to NL-16-024 Edwin I. Hatch Nuclear 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 1 ), to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directed the Edwin I. Hatch Nuclear Plant (HNP) - Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in Attachment 2 of the Order. The information provided herein documents full compliance for HNP Unit 1 in response to the Order.

OPEN ITEM RESOLUTION Issues from the NRC Interim Staff Evaluation (ISE) (Reference 9) have been addressed in the subsequent 6 month status updates and were reviewed at the October 2016 onsite audit as documented in the Audit Report (Reference 14). There were no SFPLIS Audit Questions/Audit Report Open Items.

COMPLIANCE Edwin I. Hatch Nuclear Plant has installed two independent full scale level monitors on the Unit 1 Spent Fuel Pool (SFP) in response to Reference 1. The HNP site has two fuel pools (one for each unit) operated independently.

In accordance with SNC letter dated February 27,2013 (Reference 5), HNP Unit 1 stated compliance with Reference 1 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 2).

Following SNC submittal of the HNP Overall Integrated Plan (Reference 5), the NRC requested additional information which was provided in reference 8, 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 Reference 12.

The previous responses from reference 8 and 9 were reviewed at the October 2016 onsite audit as documented in the Audit Report (Reference 14). The HNP Unit 1 Spent Fuel Level Indication Audit Questions/Audit Report had no open items.

IDENTIFICATION OF LEVELS OF REQUIRED MONITORING-COMPLETE HNP Unit 1 has identified the three required levels for monitoring SFP level in compliance with Order EA-12-051. Operations procedures have integrated the full capability of the Unit 1 SFP level indication systems.

INSTRUMENT DESIGNED FEATURES-COMPLETE The design of the instruments installed at HNP Unit 1 complies with the requirements specified in Reference 1 and described in NEI 12-02 "Industry Guidance for Compliance 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 E2-1 to NL-16-024 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-051 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 HNP 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 HNP 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 procedures and processes have been established to ensure the instruments are maintained at their design accuracy.

MILESTONE SCHEDULE -ITEMS COMPLETE HNP 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 March 2014 3'd 6 Month Update August 2014 4th 6 Month Update February 2015 Receipt of Unit 1 SFP Instrument Channel June 2015 Develop Modifications August 2015 5th 6 Month Update August 2015 Complete Functional Test of Unit 1 SFPI January 2016 Procedures and Training Complete February 2016 6th 6 Month Update February 2016 Unit 1 - 2"d Refueling Outage /Implementation Complete March 2016 Based on the above, the requirements of Order EA-12-051 have been achieved for HNP Unit 1.

A summary of HNP Unit 1 compliance with the Order is provided as follows:

E2-2 to NL-16-024 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-051 COMPLIANCE ELEMENTS

SUMMARY

In accordance with NRC Order EA-12-051, HNP 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 HNP Unit 1 Spent Fuel Pool Level Indication System (SFPLIS) is capable of measuring SFP level from approximately nine inches above the top of the fuel racks to approximately eleven inches from 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 instrumentation shall include the following design features:

a. Instruments: The instrumentation 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. This 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.

The sensing elements, detectors and display units are seismically qualified and mounted, consistent with the HNP 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 E2-3 to NL-16-024 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-051 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 are 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 Reactor Building have been routed to maximize channel separation.

f.

Power supplies: Permanently installed instrumentation channels shall each be powered by a separate power supply. Permanently installed and portable instrumentation 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 . An onsite portable generator 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.

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 appropriate and accessible location. The display shall provide on-demand or continuous indication of spent fuel pool water level.

The displays provide continuous level indication and are easily accessible by operators.

The display units are located near the Main Control Room on the Reactor Building 164' Elevation for each unit, just inside the Turbine Building to Reactor Building airlock.

E2-4 to NL-16-024 Edwin I. Hatch Nuclear Plant-Unit 1 Compliance with Order EA-12-051

2. In accordance with NRC Order EA-12-051, the spent fuel pool instrumentation shall be maintained available and reliable through appropriate development and implementation of the following programs:

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

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

I&C Technicians: The CRC re-evaluated the current tasks and determined that periodic maintenance and calibration of the new level detection system was considered skill of the craft and no 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 established and maintained for the testing, calibration, and use of the primary and backup spent fuel pool instrument channels.

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

34SO-G41-003, Spent Fuel Pool Level Indication System New system operating procedure 34AB-G41-001-1, Loss of Spent Fuel Cooling Added new SFPLIS channels for monitoring SFP level in a Beyond Design Basis Event.

31 EO-FSG-003 Extended Loss of All AC Power Added directions to initiate SFP level monitoring.

NMP-OS-019-262, U1 SIG-2, 600V Alternate Power New procedure which provides instructions for connecting remote power to the SFPLis from the 600V FLEX Diesel Generator.

34GO-OPS-030-1, Reactor Building Rounds Added weekly check/comparison of SFPLis level displays with the SFP ruler level and check of battery alarms.

571T-G41-001-0, Spent Fuel Pool Level Indication System-Channel Calibration New procedure which provides instructions for calibration of new SFPLis and UPS alarm response E2-5 to NL-16-024 Edwin I. Hatch Nuclear Plant - Unit 1 Compliance with Order EA-12-051

c. Testing and Calibration: Processes shall 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.

SFPLI accuracy is evaluated by a two point response check per procedure 57 IT-G41-001-0 listed above. If required, calibration of the instrument requires vendor involvement. Vendor calibration involves data changes to an EPROM chip in the instrument.

Preventative Maintenance Change Request (PMCR) 83682 was generated to establish multiple Preventative Maintenance (PM) work orders for the SFPLI system:

(1) PM to perform test of level indication every 24 months within 60 days of planned refueling outage (U1 and U2) which begins prior to U2 refueling outage in 2017.

(2) PM to perform 24 volt battery functional test every 24 months.

(3) PM to replace 24 volt battery every 3 years.

Battery testing will be performed during calibration procedures using 571T-G41-001.

REFERENCES:

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

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

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

3. Edwin I. Hatch Nuclear Plant 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. (SNC letter NL-12-0619)

4. Edwin I, Hatch Nuclear 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. (SNC letter NL-12-2151)

5. Edwin I. Hatch Nuclear 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. (SNC letter NL-13-0172)

6. NRC letter, Edwin I. Hatch Nuclear Plant, Units 1 and 2-Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA 051), dated August 1, 2013.

E2-6 to NL-16-024 Edwin I. Hatch Nuclear Plant - Unit 1 Compliance with Order EA-12-051

7. Edwin I. Hatch Nuclear 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. (SNC letter NL-13-1766)

8. Edwin I. Hatch Nuclear Plant - Units 1 and 2 Response to Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051) dated August 29, 2013. (SNC letter NL-13-1865)

9. NRC letter, Interim Staff Evaluation and Request for Additional Information Hatch Nuclear Plant Units 1 and 2 Regarding Overall Integrated Plan (OIP) for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051), dated October 28, 2013.

10. Edwin I. Hatch Nuclear 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. (SNC letter NL 0184)

11. Edwin I. Hatch Nuclear 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. (SNC letter NL 111 0)

12. Edwin I. Hatch Nuclear 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. (SNC letter NL 0240)

13. Edwin I. Hatch Nuclear 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. (SNC letter NL-15-1154)

14. NRC letter, Edwin I. Hatch Nuclear 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. MF0712, MF0713, MF0721, and MF0722),

dated January 13, 2016.

15. Edwin I. Hatch Nuclear Plant-Units 1 and 2, Sixth Six-Month Status Report Regarding Reliable Spent Fuel Pool Instrumentation (EA-12-051), dated February 25,2016.

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Charles R. Pierce Regulatory Affairs Director May 3, 2016 Docket No.: 50-321 Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 SOUTHERN <<\\

NUCLEAR A SOUTHERN COMPANY NL-16-0249 Edwin I. Hatch Nuclear 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 Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, to Southern Nuclear Operating Company (SNC). This Order was effective immediately and directs the Edwin I. Hatch Nuclear Plant (HNP) - Units 1 and 2 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 HNP 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 HNP Units 1 and 2 to install reliable spent fuel pool instrumentation as outlined in of the Order. 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 of the Order has been achieved for HNP Unit 1.

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-16-0249 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.

Respectfully submitted, tr<.~

C. R. Pierce Regulatory Affairs Director CRP/JMG/MRE Swam to and su scribed before me this 3~ay of -Jlhy=

My commission expires: 1-Z- 2 0 I&'

Enclosures:

1. Compliance with Order EA-12-049

2. Compliance with Order EA-12-051 cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President-Hatch 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. L. Johnson, Regulatory Affairs Manager-Hatch RType: CHA02.004 U.S. Nuclear Regulatory Commission

'2016.

Mr. W. M. Dean, Director of the Office of Nuclear Reactor Regulations Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager-Hatch Mr. D. H. Hardage, Senior Resident Inspector-Hatch State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division

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