NL-13-0171, Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation.

Overall Integrated Plan in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation.

ML13059A388
Person / Time
Site:	Farley
Issue date:	02/27/2013
From:	Ivey B Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-051, NL-13-0171
Download: ML13059A388 (20)

Text

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

Regul atory Affairs 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7619 Fax 205.992.521 7 February 27,2013 Docket Nos.: 50-348 NL-13-0171 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Overall Integrated Plan In Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order EA-12-051)

References:

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

2. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order EA-12-0S1, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation, Revision 0, dated August 29, 2012

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

4. Southern Nuclear Operating Company letter NL-12-2150 to the NRC, Joseph M. Farley Nuclear Plant - Units 1 and 2 Southern Nuclear Operating Company's Initial Status Report in Response to March 12,2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-0S1), dated October 23, 2012 Ladies and Gentlemen:

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

Nuclear Regulatory Commission NL-13-0171 Page 2 a reliable indication of the water level in spent fuel pools.

requirements are outlined in Attachment 2 of Reference 1.

Reference 1 submission of an Overall Integrated Plan by February 2013. The NRC Interim Staff (ISG) (Reference 2) was issued August 29,2012 which endorses industry guidance document 12-02, 1

3) with clarifications and exceptions identified in 2.

i-40TOr,Qnr'o 3 provides regarding content of this Reference 4 provided Joseph M. Nuclear (FNP) initial status report regarding spent instrumentation, as required by Reference 1.

The purpose of this letter is to provide the Integrated Plan for FNP pursuant to Section IV, Condition C.1, ~otor'Qnr'o 1. This confirms SNC received 2 and has an Integrated for FNP in accordance with the guidance for purpose of ensuring a reliable indication of the water in associated fuel storage capable of supporting identification of required wide pool water conditions by trained personnel.

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

3. The Integrated Plan is based on design information. Final design and procedure as well as any to the information contained in Enclosure, will provided in the Integrated updates by Reference 1 SNC to fully implement the requirements of Order by breaker of the Unit 1 Spring 2015 refueling outage and the Unit 2 Fall 2014 outage Section IV, Condition A.2 of 1. In accordance with Section IV, Condition C.3 of 1, SNC intends to submit notification to the NRC that full compliance Order has been achieved within 60 of full implementation unit at FNP.

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

U.S. Nuclear Regulatory Commission NL-13-0171 Page 3 Respectfully submitted,

~~

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

Sworn to and subscribed before me this ;L7tLday of jJ.l~([A"o , 2013.

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otary Pubflc My commission expires:1!,VA el~ JJ ~

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Enclosure:

Joseph M. Farley Nuclear Plant Units 1 and 2 Integrated Plan with Regard to Reliable Spent Fuel Pool Instrumentation cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief I\luclear Officer Mr. T. A. Lynch, Vice President - Farley Mr. B. J. Adams, Vice President - Fleet Operations Mr. C. R. Pierce, Director - Regulatory Affairs RTYPE: CFA04.054 U. S. Nuclear Regulatorv Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulation Mr. V. M. McCree, Regional Administrator Ms. E. A. Brown, NRR Project Manager - Farley Mr. P. K. Niebaum, Senior Resident - Farley Mr. J . R. Sowa, Senior Resident - Farley Mr. Blake A. Purnell , NRRlJLD/PMB, NRC Mr. Steven R. Jones, NRR/DSS/SBPB, NRC Alabama Department of Public Health Dr. D. E. Williamson, State Health Officer

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

Enclosure Joseph M. Farley Nuclear Plant Units 1 and 2 Integrated Plan with Regard to Reliable Spent Fuel Pool Instrumentation

Southern Nuclear Operating Company J. M. Farley Nuclear Plant Units 1 & 2 Reliable Spent Fuel Pool Instrumentation Overall Integrated Implementation Plan Revision 0, February 27, 2013 FNP 1 & 2 RSFPI Integrated Plan Page 1 of 16 2/27/2013 12:19 PM

Table of Contents I. Introduction .. ... ....................................................... ................................................... .. 3 II. Schedule ..................................................................................................................... 4 III. Identification of Spent Fuel Pool Water Levels .......... ....................................................... 5 IV. Instruments .. .... ........................................................................................................... 5 V. Reliability....... .............................................................................................................. 6 VI. Instrument Channel Design Criteria ........................ .... ................................................... . 6 A. Arrangement ... .... ... .. ............ ... ............ ... .. ..... ... ..... ....... ... ........................ ... .... .. ..... .... .... ....... ...... . 6 B. Mounting....... ...... .. ....... .. ...... .... .. .. ...... ............. ... ... .... .. .... ...... .. ... .. .. ..... ... ... .. ..... .... ............ ... .... .... 7 C. Qualification ..... .. ...... ....................................................... ........... ....................... .. ...... ....... .... .. ..... 7 D. Independence ....................................................................................... .. ....... .. ....... .. .......... .... .... 9 E. Power Supplies ................................................................. ........................................................... 9 F. Accuracy ........................................................................... .......... .................... .. .................... ....... 9 G. Testing ..... .... ........ ....... .. ... ......................... .. ....... ...... ........ ........... .. .. ........ ..... .... ... .. .. ... ............ .. .... 9 H. Display .. ........... ... ............................................................ .................... .... ........ .. ...... ........ .... ... .... 10 VII. Instrument Channel Program Criteria ........................................................................... 10 A. Training ...... .......... .......................... .. ........... ... ......... .. .. .............................. .. ............................ .. 10 B. Procedures ... .. ......... .... ..... ..... ........ ..... .. ... ..... .... .... ........ ........ .. .... ......... ..... .. .... ..... .... ..... ..... ..... ... 10 C. Testing and Calibration ......... .. .............. ... ..... ..... ......... .... ........ .......... .... ... ........... .. .. ...... .. .. .. ...... 10 VIII. Need for Relief and Basis .......................................................................................... .. 11 IX. References ...... ...... .................................................... ................................................ 11 : Probe Location Sketch ...................................................................................... 12 : Electrical Sketches ............................................ ............................................... 14 FNP 1 & 2 RSFPI Integrated Plan Page 2 of 16 2/27/2013 12:19 PM

I. Introduction The Nuclear Commission (NRC) EA-12-0S1, Issuance Order ta Modify Licenses with Regard to Reliable Spent Fuel Poo/lnstrumentation, 1) on March The Order licensees to have indication of water level in associated storage capable of identification the following water level conditions by trained personnel: (1) that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation sh for a person on the pool deck, and (3) fuel remains covered and actions to implement make-up water addition should no longer be The also requires I of an overall integrated plan which will provide a of the the Order will achieved.

NEll2-02, Industry Guidance for Compliance with NRC fA-12-0S1, Modify Licenses with to Reliable Spent Fuel Poo/lnstrumentation," (Reference 4) provides an approach for with order EA-12-0S1. NRC Interim Staff Guidance JLD-ISG-2012-03, Compliance with Order fA-12-0S1, Reliable Spent Fuel Instrumentation, (Reference 3) that methodologies and guidance in conformance with guidelines provided in NEI12-02, Revision 1, to the clarifications and exceptions specific to NEI 12-02 Section 3.4, means of requirements EA-l2-0S1.

This plan provides the Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 approach for complying with Order EA-12-0Sl methods in IIJEI 12-02 with the and as Six month progress reports EA-12-0Sl and in NEI FNP 1 & 2 RSFPI Integrated Plan Page 3 of 16 2/27/2013 PM

II. Schedule Installation of reliable spent fuel pool (SFP) level instrumentation will be completed prior to startup from the second refueling outage per unit after submittal of this plan (the Second Refueling outage commencing at FNP following February 28, 2013 is Spring 2015 for Unit 1 and Fall 2014 for Unit 2), but no later than December 31, 2016, (Reference 6).

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

The current milestones are:

Original Target Activity Status Date {Include date changes in this columnl Oct. 2012 Submit 60 Day Status Report Complete Feb . 2013 Submit Overall Integrated Implementation Plan Complete May 2013 Unit 2 1s RFO Aug 2013 Submit 6 Month Status Report Nov 2013 Unit 1 1s RFO Dec 2013 Develop Modifications Unit 2 Feb . 2014 Submit 6 Month Status Report Apr 2014 Receipt of Unit 2 SFP Instrument Channel Apr 2014 Develop Modifications Unit 1 June 2014 Receipt of Unit 1 SFP Instrument Channel 3Q2014 Complete Functional Test of Unit 2 SFP Instruments Aug . 2014 Submit 6 Month Status Report 4Q2014 Complete Functional Test of Unit 1 SFP Instruments no Nov 2014 Unit 2 Implementation Complete (2 RFO)*

Feb . 2015 Submit 6 Month Status Report no Apr 2015 Unit 1 Implementation Complete (2 RFO)*

June 2015 Submit Completion Report

• Full compliance after second listed refueling outage FNP 1 & 2 RSFPI Integrated Plan Page 4 of 16 2/27/2013 12:19 PM

III. Identification of Spent Fuel Pool Water Levels Each unit at Joseph M. Farley Nuclear Plant has its own spent fuel pool. The wet spent-fuel storage facility is located in the Auxiliary Building at EI. 155'-00" in separate rooms. The Unit 1 and Unit 2 wet spent fuel pool storage facilities are made of reinforced concrete and each is lined on the inside with X" thick stainless steel plate. The SFPs are designed to provide underwater storage space for spent fuel assemblies and control rods after their removal from containment. The SFPs shall maintain enough heat removal capacity to accommodate the assemblies from a full core emergency off-load as well as the spenf fuel assemblies previously discharged to the pool (See Attachment 1).

Key spent fuel pool water levels:

1. Level adequate to support operation of the normal fuel pool cooling system - Fuel pool level to support spent fuel pump Net Positive Suction Head (NPSH) requirements is 153'-4". (References 15,16, and 18)

2. Level adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck - Elevation 139'-3/8" is approximately 10'-0" above the highest point of the fuel racks (plus or minus 1 foot). (Reference 10 Figure 9.1-2 (sheet 1 of 2) and References 15 & 16)

3. Level where fuel remains covered - Elevation 129'-3/8" is the nominal level of the highest fuel rack. (Reference 10 - Figure 9.1-2 (sheet 1 of 2) and References 15 & 16)

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

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

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

• The measured range will be continuous from the high pool level elevation 153'-10" to the top of the spent fuel racks at elevation 129'-3/8" (Reference 10 - Figure 9.1-2 (sheet 1 of 2) and References 15, 16, 17, & 18).

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

• The display shall provide a continuous indication of spent fuel pool water level at the Display location. In the event the link to the Display is lost, a field accessible signal/Indication (remote to the Display location) will be available for determination of pool level.

FNP 1 & 2 RSFPI Integrated Plan Page 5 of 16 2/27/2013 12:19 PM

• The electronic processing module and the Display will be installed in a location that will meet the criteria established in NEI12-02 and endorsed by NRC JLD-ISG-2012 03 . The specific location of the electronic processi ng modu Ie and the Display has not been determined yet.

V. Reliability Reliability of the primary and backup instrument channels will be assured by conformance with the guidelines of NRC JLD-ISG-2012-03 or NEI12-02, as discussed in Section 3.4, Qualification and 3.8 Testing . Reliable level indication will be functional during all times when used fuel is in the SFP consistent with NEI 12-02 Section 4.3, Testing and Calibration .

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

A. Arrangement SFP level probes will be installed separate from each other in the SFP. Primary and backup level indication will be installed in the Main Control Room, at the alternate shutdown panel, or another appropriate and accessible location (reference NEI12-06) that complies with the NEI12-02 following characteristics . SNC has not determined the exact location at this time and has several options that provide various benefits . For example, the Main Control Room is the NRC preferred location while an appropriate accessible location in the plant would provide information to personnel in the plant at a location closer to the pool and mitigation equipment. Both existing and new barriers will be used to provide a level of protection for the cable located on the refueling floor from falling debris missiles generated by the event .

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

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

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

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

FNP 1 & 2 RSFPI Integrated Plan Page 6 of 16 2/27/2013 12:19 PM

B. Mounting Per NEI 12-02 Section 3.3, Mounting, the new equipment will be mounted to maintain the current Seismic Class of the Spent Fuel Pool which is Seismic Class I (Reference 10 Section 3.8.4). Thus, the new equipment will be seismically qualified to Class I. In addition, the mounting of the primary and backup channel components throughout the plant will meet the criteria of the structure it will be routed through or attached to.

(refer to Qualification details below relating to cable and raceway installation criteria)

C. Qualification The components/cables/connections for both primary and backup channels will be reliable at the temperature, humidity, and radiation levels consistent with the spent fuel pool water at saturation conditions for seven (7) days. Saturation temperature at the bottom of the SFP assuming normal water level will be approximately 250°F. Post event temperature at sensors located above the SFP is assumed to be 212°F. Post event humidity in the SFP room is assumed to be 100% with condensing steam. The components/cables/connections will be qualified for expected conditions at the installed location assuming the SFP has been at saturation for an extended period. The components/cables/connections located in the vicinity of the SFP will be qualified to withstand peak and total integrated dose radiation levels for their installed location assuming that post event SFP water level is equal to the top of irradiated fuel for a time no greater than six (6) hours. It is anticipated that the station personnel can align one of the three (3) SFP Cooling Strategies as detailed in NEI 12-06 if conditions are degrading as indicted by decreasing SFP level.

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

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

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

• Instrument channel components use known operating principles, are supplied by manufacturers with commercial quality programs (such as IS09001, Quality management systems - Requirements (Reference 8)) with shock and vibration requirements included in the purchase specification and/or instrument design, and commercial design and testing for operation in environments where significant shock and vibration loadings are common, such as for portable hand-held devices or transportation applications; FNP 1 & 2 RSFPI Integrated Plan Page 7 of 16 2/27/2013 12:19 PM

• reliability in environments with shock applications; or

• Use of components inherently resistant to shock and vibration loadings or are reliable as For impact on instrument channel components required after a potential event for installed components, the to verify and is adequate. components instrument channels are rated by the manufacturer {or tested} for seismic impact at commensurate with of basis event in the area channel use using one or more of the following methods different methods may used for the various sub components primary back-up instrument channels):

• Adequacy of seismic and installation is demonstrated based on guidance in Sections 7,8,9, and 10 of IEEE Standard IEEE Recommended Practice of 1E Nuclear Power industrial standard

.. Instrument channel use known principles are by manufacturers with commercial quality programs (such as 1509001) with seismic requirements included in the purchase specification and/or instrument and commercial design and for operation in environments where seismic effects are common I reliability in environments with hand-held or transportation applications

.. Demonstration of reliability using methods that predict the equipment's performance by:

Analysis of the equipment under simulated conditions Using a combination test and analysis The use of Demonstration that devices are substantially similar in design to models been previously for seismic in excess of the nt design at the location the instrument is to installed (g-Ievels a uency qualification using seismic motion consistent with that of design loading at the installation location.

FNP 1 & 2 Integrated Plan Page 8 of 16 12:19 PM

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

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

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

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

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

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

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

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

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

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

FNP 1 & 2 RSFPI Integrated Plan Page 9 of 16 2/27/2013 12:19 PM

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

VII. Instrument Channel Program Criteria Instrument channel program criteria will be consistent with the guidelines of NRC JLD-ISG-2012 03 and NEI12-02.

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

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

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

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

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

FNP 1 & 2 RSFPI Integrated Plan Page 10 of 16 2/27/2013 12:19 PM

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

Consistent with the requirements of Order EA-12-051 and the guidance in NEI 12-02 as endorsed by NRC JLO-ISG-2012-03, the six-month reports will delineate progress made, any proposed changes in our compliance methods, updates to the schedule, and, if needed, requests for relief and their bases.

IX. References

1) EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, March 12, 2012

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

3) NRC JLO-ISG-2012-03, Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation, Revision 0, August 29,2012

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

5) NE112-06, Oiverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012

6) Letter, NL-12-2150, Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), dated October 23,2013

7) Letter NL-12-2145, Initial Status Report in Response to Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Oesign-Basis External Events (Order Number EA-12-049), dated October 23,2013

8) IS09001, Quality management systems - Requirements

9) IEEE Standard 344-2004, IEEE Recommended Practice for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations

10) Joseph M. Farley Nuclear Plant Unit 1 and 2 Final Safety Analysis Reports, Revision 25, Nov.

2012

11) 0-175043, "P&IO - Spent Fuel Pool Cooling System" - Unit 1

12) 0-205043, "P&IO - Spent Fuel Pool Cooling System" - Unit 2

13) 0-350804, Ver. 17.0, "Aux. Bldg Cone. Penetration Seals @ EI 155' -0" (PS-155-00)"

14) 0-356039, Ver. 11.0, "Aux. Bldg Concrete Penetration Seals Key Plan @ EI155' _0" (2PS-155-00)"

15) 0-176542, Ver. 15.0, "Section 20 Concrete Auxiliary Building"

16) 0-206542, Ver. 6.0, "Sect 20 Cone AlB"

17) U-266647, Ver. 14.0, "Precautions, Limitations and Setpoints for Nuclear Steam Supply Systems"

18) A-181014, Ver. 14.0, "Functional System Oescription Spent Fuel Pool System" FNP 1 & 2 RSFPI Integrated Plan Page 11 of 16 2/27/2013 12:19 PM

Attachment 1: Probe Location Sketch" (Page 1 of 2)

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Attachment 1: Probe Location Sketch (Page 2 of 2)

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