ML071270287

From kanterella
Jump to navigation Jump to search

Administrative Change to Facility Operating License in Conjunction with the Commission Order EA-02-026
ML071270287
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/27/2007
From: Donohew J
NRC/NRR/ADRO/DORL/LPLIV
To: Naslund C
Union Electric Co
Fields, M B, NRR/DLPM/LPD4, 415-3062
Shared Package
ML071270216 List:
References
EA-02-026, TAC MD4518
Download: ML071270287 (12)
v • d • e


Text

Pkg ML071270216 (Letter _rfcl 2: ML071270287, Encl 1: ML071760542, Attachments to SE (OUO): ML071690506) AfJv jc.

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB

/ /

NAME MFields DBaxley JDonohew DNelso DATE 6/19/07 _ C _Z__"_____

OFFICE NSIR OGC NRR/LPLIV/BC NAME AFrazier JGoldberg THiltz DATE 6/6/07 5/18/07 =PIII-3"I.3'*" __0_7_1 "GF,2,;,-, U.;3,. ONLY - C-ECUlIY .'f; E-LAT'E IN'FORI..LAATION Naslund Plant- cific Regulato*y Action The enclosec E details the interactions between the NRC staff and the Union Electric Company, as w as the rest of the nuclear industry, related to the resolution of Section B.5.b.

of the ICM Order. he outcome of these interactions is a license condition that satisfactorily captures the ICM Or r Section B.5.b mitigation strategy requirements.

This proposed license con *tion was transmitted by the NRC to the Union Electric Company in a letter dated October 12, 200 By letter dated January 10, 2007, the Union Electric Company informed the NRC staff that it uld accept the proposed license condition, with a minor change that the NRC staff finds acceptabe. The effectiveness of the licensee's actions to implement the mitigative strategies contained i this license condition will be subject to future NRC review and inspection.

Consistent with the Order, an administrati license change to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1, i being made to incorporate the agreed upon license condition. This change complies with e standards and requirements of the Atomic Energy Act of 1954, as amended, and the Com ission's rules and regulations set forth in Title 10 of the Code of FederalRegulations (10 C ) Chapter I. Please replace the affected pages of the Facility Operating License with the enc sed pages (Enclosure 1).

The attachments to the SE are designated exempt from ublic disclosure under 10 CFR 2.390(d)(1) since they contain security-related information nd are Official Use Only.

If you have any questions, please contact me at (301) 415-1 7.

Sincerely, Jack Donohew, Senior roject Manager Plant Licensing Branch I Division of Operating Rea or Licensing Office of Nuclear Reactor R ulation Docket No. 50-483

Enclosures:

1. Revised Pages of Facility Operating License No. NPF-30
2. Safety Evaluation cc w/o atts. to Encl. 2: See next page DISTRIBUTION (w/o attachments to Safety Evaluation)

PUBLIC RidsNrrPMMFields RidsOgcRp LPLIV Reading File RidsNrrPMJDonohew GHilI, OIS RidsAcrsAcnwMailCenter RidsNrrLADBaxley AFrazier, NSIR RidsNrrDorl (CHaney/JLubinski) RidsNsirDsp RidsNrrDorlLpl4 RidsNrrDorlDpr RidsRgn4MailCenter ADAMS Accession Nos.: Pkg ML071270216 (Letter & Encl 2: ML071270287, Encl 1: ML07, Attachments to SE (OUO): ML071690506)

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB NAME MFields* DBaxley JDonohew. DNels . .

DATE 1/',:";-/

6/19/07 1- __-7 OFFICE NSIR OGC NRR/LPLIV/C NAME AFrazier JGoldberg THiltz VV DATE 6/6/07 5/18/07 i I__ _1_

OFFIC.IAL RECORDK COP'Y CZý = 7-7 =: I-- =::,:I .2.' fl-AE lflrnM. -E~lT. -IOv

A ..... AJAm mim*R I*lm

  • mm* .... *im m*

~.,..UIA ULLUNL 6CLCRI144 [I1rmA;raIP1 IWR!riT C. D. Naslund Plant-Specific Recqulatory Action The enclosed SE details the interactions between the NRC staff and the .Union Electric Company, as well as the rest of the nuclear industry, related to the res (ution of Section B.5.b.

of the ICM Order. The outcome of these interactions is a license condition that satisfactorily captures the ICM Order Section B.5.b mitigation strategy requirements.

This proposed license condition was transmitted by the NRC tothe Union Electric Company in a letter dated October 12, 2006. By letter dated January 10, 2067, the Union Electric Company informed the NRC staff that it would accept the proposed lin nse condition, with a minor change that the NRC staff finds acceptable. The effectiveness of/he licensee's actions to implement the mitigative strategies contained in this license conditio'n will be subject to future NRC review and inspection. /*

Consistent with the Order, an administrative licens change to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1, is bein g made to incorporate the agreed upon license condition. This change complies with tp e standards and requirements of the Atomic Energy Act of 1954, as amended, and the Cotnmission's rules and regulations set forth in 10 CFR Chapter I. Please replace the affepted pages of the Facility Operating License with the enclosed pages (Enclosure 1). /

The attachments to the SE are designý fed exempt from public disclosure under 10 CFR 2.390(d)(1) since they contain security-related information and are Official Use Only.

If you have any questions, please contact me at (301) 415-1307.

Sincerely, Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Revised Pages/p f Facility Operating License No. ,*PF-30
2. Safety Evalu ion cc w/o attachrnts to Safety Evaluation: See next page DISTRIBUTION ,v/o attachments to Safety Evaluation)

PUBLIC / RidsNrrPMMFields RidsOgcRp LPLIV Readi r)ý File RidsNrrPMJDonohew GHiII, OIS RidsAcrsAc 'wMailCenter RidsNrrLADBaxley AFrazier, NSIR RidsNrrDo I (CHaney/JLubinski) RidsNsirDsp RidsNrrDorlLpl4 RidsNrrDrDpr RidsRgn4MailCenter ADA Accession Nos.: Pkg ML071270216 (Letter & End 2: ML071270287, End 1: ML07, Attachments to SE

( ): ML071690506)

O FICE NRR/LPLIV/PM f! M NRR/LPLIV/PM NRR/DPR/PSPB

ýAME MFields DBaxIt.,J..__) JDonohew DNelson DATE __ I _ _ _ _ __'-_ _ _ _ I OGC NRR/LPLIV/BC

/

OFFICE NSIR NAME AFrazier JGoldberg THiltz DATE 6/6/07 5/18/07 OFFICIAL RECORD COPY

/ OFFCIA 009E GNYSECUWRI** R66ATEB INFOflMATI1111 SrNý

P! g ML071270216 (Letter & Encl 2: ML071270287, Encl 1: ML07, Attachments to SE OUO): ML) /

OFFICE NRR/LP lV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB NAME MField DBaxley JDonohew DNels- ,

DATE __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 7___ _

OFFICE NSIR OGC NRR/LPLIV/BC NAME . JGoldberg THiltz DATE , 7 __

/

Pkg ML071270216 (Letter & Encl 2: ML07127028 Encl 1: ML07, Attachments to SE (OUO): ML) -

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB NAME MFields _ DBaxley JDonohew Nels*nl DATE _ 6 OFFICE NAME DATE NSIR jJGoldberg OGC NRR/LPLIV/BC tHiltz_ __,,

Pkg ML071,270216 (Letter & Endl 2: ML071270287, Encl 1: ML07, Attachments to SE (OUO): ML) / "

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB NAME MFields DBaxley JDonohew DNe7, t DATE +/-__ -F--

OFFICE NSIR / OGC NRR/LPLIV/BC NAME / JGoldberg THiltz DATE / _-' _ __o_

3rr13:lL USE 811'.' CEC8fIT'.' RWLATED- lNOFQAMXWl*l C. D. Naslund As discussed in the SE, the NRC staff has determined that the license condition adequately captures the mitigative strategies required by Section B.5.b of the ICM Order, andicomplies with Title 10 of the Code of FederalRegulations (10 CFR), Part 73, and is, therefore,acceptable.

The effectiveness of the licensee's actions to implement the mitigative strategies contained in this license condition will be subject to future NRC review and inspection. /

Consistent with the Order, an administrative license change to Facility O rating License No. NPF-30 for the Callaway Plant, Unit 1, is being made to incorporate he agreed upon license condition. This change complies with the standards and requjrements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and r6gulations set forth in 10 CFR Chapter I. Please replace the affected pages of the Facility Operating License with the enclosed pages (Enclosure 1).

The attachments to the SE are designated exempt from pub).ic disclosure under 10 CFR 2.390(d)(1) since they contain security-related information and are considered Official Use Only.

If you have any questions, please contact me at (301)741 5-1307.

Sincer4,,l Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing ffice of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Revised Pages of Facility Operating License No. NPF-30
2. Safety Evaluation cc w/o attachments to Safety Eval ation: See next page DISTRIBUTION:

PUBLIC RidsNrrPMMFields RidsOgcRp LPLIV Reading File RidsNrrPMJDonohew GHiII, OIS RidsAcrsAcnwMailCenter RidsNrrLADBaxley  ???, NSIR RidsNrrDorl (CHaney/JLubinsk) RidsNsirDsp RidsNrrDorlDpr RidsRgn4MailCenter RidsNrrDorlLpl4 ADAMS Accession Nos.: Pkg ML071270216 (Letter & Encl 2: ML071270287, Encl 1: ML07, Attachments to SE (OUO,: ML)

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/LPLIV/PM NRR/DPR/PSPB NAME MField~/2_ DBaxley JDonohew DNelson DATE "" .

OFFICE NSI OGCAJ.. ofCosmut NRR/LPLIV/BC NAME t JG JGoldberg. ,,/...jTHiltz DAT E .. .. / X 10 -i .

I'/ E* "

NAEOFFICIAL RECORD COPY OFF,,-,.. LHOF mv ..: - ,_5-.-,-, F ,,. -

ý-q REc OFCA CECL EU47-~Ah UNITED STATES NUCLEAR REGULATORY COMMISSION J WASHINGTON, D.C. 20555-0001

      • ~3June 27, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - CONFORMING LICENSE AMENDMENT TO INCORPORATE THE MITIGATION STRATEGIES REQUIRED BY SECTION B.5.b. OF COMMISSION ORDER EA-02-026 (TAC NO. MD4518)

Dear Mr. Naslund:

This letter documents the results of the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Union Electric Company for the Callaway Plant, Unit 1, in response to Section B.5.b. of the February 25, 2002, Interim Compensatory Measures (ICM) Order (EA-02-026) and related NRC guidance.

The ICM Order was issued following the events of September 11, 2001, as part of a comprehensive effort by the NRC, in coordination with other government agencies, to improve the capabilities of commercial nuclear reactor facilities to respond to terrorist threats. Section B.5.b. of the Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire, including those that an aircraft impact might create. Although it was recognized prior to September 11, 2001, that nuclear reactors already had significant capabilities to withstand a broad range of attacks, implementing these mitigation strategies would significantly enhance the plants' capabilities to withstand a broad range of threats. It should be noted that portions of the ICM Order, as well as other documents referenced in this letter, contain security-related or safeguards information, and are not publicly available.

Licensee actions to implement Section B.5.b mitigation strategies have been ongoing since the issuance of the 2002 ICM Order. In 2005, the NRC issued guidance to more fully describe the NRC staff's expectations for implementing Section B.5.b of the ICM Order. The NRC guidance relied upon lessons learned from detailed NRC engineering studies and industry best practices.

Additionally, the NRC conducted two on-site team assessments at each reactor facility that identified additional mitigating strategies for preservation of core cooling, containment integrity, and spent fuel pool cooling. In total, these efforts have added defense in depth through the use of additional equipment and strategies. Moreover, these enhancements that have strengthened the interface between plant safety and security operations now include fire-fighting response strategies; plant operations to mitigate fuel damage; and actions to minimize releases.

NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this letter and Enclosures 1 and 2 are DECONTROLLED.

r!F^k1" N/-L %

C. D. Naslund The enclosed Safety Evaluation (SE) details the interactions between the NRC staff and the Union Electric Company, as well as the rest of the nuclear industry, related to the final resolution of Section B.5.b. of the ICM Order.

The NRC is incorporating requirements for the B.5.b mitigating strategies into the facility operating license. This letter, therefore, also transmits the license condition that captures the ICM Order Section B.5.b mitigation strategy requirements and incorporates them into the licensing basis.

This proposed license condition was transmitted by the NRC to the Union Electric Company in a letter dated October 12, 2006. By letter dated January 10, 2007, the Union Electric Company informed the NRC staff that it would accept the proposed license condition, with a minor change that the NRC staff finds acceptable. The effectiveness of the licensee's actions to implement the mitigative strategies contained in this license condition will be. subject to future NRC review and inspection.

Consistent with the Order, an administrative license change to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1, is being made to incorporate the agreed upon license condition. This change complies with the standards and requirements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR) Chapter I. Please replace the affected pages of the Facility Operating License with the enclosed pages (Enclosure 1).

The attachments to the SE are designated exempt from public disclosure under 10 CFR 2.390(d)(1) since they contain security-related information and are Official Use Only.

If you have any questions, please contact me at (301) 415-1307.

Sincerely, ack Donohew, Senior Project Manager J%

Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosures:

1. Revised Pages of Facility Operating License No. NPF-30
2. Safety Evaluation cc w/o atts. to Encl. 2: See next page

,_Ol:ltFi I I ~EC2%

CHL' L-flIY IRi4/L A D Hirnr.-.TI"

Callaway Plant, Unit 1 cc: w/o atts. to Encl. 2 John O'Neill, Esq. Technical Services Branch Chief Pillsbury Winthrop Shaw Pittman LLP FEMA Region VII 2300 N. Street, N.W. 2323 Grand Boulevard, Suite 900 Washington, D.C. 20037 Kansas City, MO 64108-2670 Mr. Keith A. Mills, Supervising Engineer Mr. Dan I. Bolef, President Regional Regulatory Affairs/Safety Analysis Kay Drey, Representative AmerenUE Board of Directors Coalition for the P.O. Box 620 Environment Fulton, MO 65251 6267 Delmar Boulevard University City, MO 63130 U.S. Nuclear Regulatory Commission Resident Inspector Office Mr. Lee Fritz, Presiding Commissioner 8201 NRC Road Callaway County Courthouse Steedman, MO 65077-1302 10 East Fifth Street Fulton, MO 65251 Mr. Les H. Kanuckel Manager, Quality Assurance Mr. David E. Shafer AmerenUE Superintendent, Licensing P.O. Box 620 Regulatory Affairs Fulton, MO 65251 AmerenUE P.O. Box 620 Missouri Public Service Commission Fulton, MO 65251 Governor Office Building 200 Madison Street Manager, Regulatory Affairs P.O. Box 360 AmerenUE Jefferson City, MO 65102-0360 P.O. Box 620 Fulton, MO 65251 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Mr. Keith G. Henke, Planner 611 Ryan Plaza Drive, Suite 400 Division of Community and Public Health Arlington, TX 76011-4005 Office of Emergency Coordination 930 Wildwood P.O. Box 570 Mr. H. Floyd Gilzow Jefferson City, MO 65102 Deputy Director for Policy Department of Natural Resources Director, Missouri State Emergency P.O. Box 176 Management Agency Jefferson City, MO 65102-0176 P.O. Box 116 Jefferson City, MO 65102-0116 Mr. Rick A. Muench President and Chief Executive Officer Mr. Scott Clardy, Director Wolf Creek Nuclear Operating Corporation Section for Environmental Public Health P.O. Box 411 P.O. Box 570 Burlington, KA 66839 Jefferson City, MO 65102-0570 Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 June 2007

ENCLOSURE 1 REVISED PAGES OF FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following pages of the Facility Operating License No. NPF-30. The revised pages are identified by the date of the ietter issuing these pages ana contain marginal lines indicating the areas of change.

Facility Operating License REMOVE INSERT (11) Steam Generator Tube Rupture (Section 15.4.4. SSER #3)

Deleted per Amendment No. 169.

(12) Low Temperature Overpressure Protection (Section 15, SSER #3)

Deleted per Amendment No. 169.

(13) LOCA Reanalysis (Section 15, SSER #3, Deleted per Amendment No. 169.

(14) Generic Letter 83-28 Deleted per Amendment No. 169.

(15) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fighting assets
3. Designated staging areas for equipment and materials
4. Command and control
5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
1. Protection and use of personnel assets
2. Communications
3. Minimizing fire spread
4. Procedures for implementing integrated fire response strategy
5. Identification of readily-available, pre-staged equipment
6. Training on integrated fire response strategy
7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders (16) Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 180, are hereby incorporated into this Revised by letter dated June 27, 2007

license. UE shall operate the facility in accordance with the Additional Conditions.

D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21, are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006.

F. Deleted per.Amendment No. 169.

G. UE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as of the date of issuance and shall expire at Midnight on October 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY H. R. DENTON Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments/Appendices:

1. Attachment I (Deleted per Amendment No. 169)
2. Attachment 2 (Deleted per Amendment No. 169)
3. Appendix A- Technical Specifications (NUREG-1 058, Revision 1)
4. Appendix B - Environmental Protection Plan
5. Appendix C - Additional Conditions Date of Issuance: October 18, 1984 Revised by letter dated June 27, 2007 1

UNITED STATES jp, *NUCLEAR REGUI-ATORY COMMISSION V.ASHIINGTON. D,C 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER NO. EA-02-026 UNION ELECTRIC COMPANY CALLAWAY PLANT UNIT 1 DOCKET NO. 50-483

1.0 INTRODUCTION

1.1 Purpose The purpose of this Safety Evaluation (SE) is to document the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Union Electric Company (the licensee) in response to the February 25, 2002, Interim Compensatory Measures (ICM) Order and the subsequent NRC letter to licensees dated February 25, 2005, transmitting NRC guidance (Phase 1 guidance document). This SE describes the basis for finding licensee strategies adequate to satisfy the requirements of the ICM Order. This SE also discusses the license condition that satisfactorily captures the mitigation strategy requirements. If the licensee makes future changes to its strategies within its commitment management program, this SE will be useful to the NRC staff in determining if the changed strategies are adequate to meet the license condition. It should be noted that portions of the ICM Order, as well as other documents referenced in this SE, contain security-related or safeguards information, and are not publicly available.

1.2 Background The February 25, 2002, ICM Order that imposed interim compensatory measures on power reactor licensees required in Section B.5.b, Mitigative Measures, the development of "specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of plant due to explosions or fire." These actions were to be implemented by the end of August 2002. Inspections of the implementation of the Section B.5.b requirements were NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this Safety Evaluation is DECONTROLLED.

orplemm: usE OfIL'. 9EOWfl+*T'.' lE8

IrI IBML UQE ONLb!' GEO81-floRn: lf

-2.

conducted in 2002 and 2003 (Temporary Instruction (TI) 2515/148). The inspections identified large variabilities in scope and depth of the enhancements made by licensees. As a result, the NRC determined that additional guidance and clarification was needed for nuclear power plant licensees.

Subsequent to the conduct of the TI 2515/148 inspections, engineering studies conducted by the NRC Office of Regulatory Research (RES) provided insights into the implementation of mitigation strategies to address the loss of large areas of a plant due to explosions or fire, including those that an aircraft impact might create. The NRC actions resulting from these studies included:, (1) inspections of licensee actions that address plant-specific consequences, (2) issuance of advisories that involve processes and protocols for licensee notification of an imminent aircraft threat, and (3) identification of mitigative measures to enhance plant response to explosions or fire.

On November 24, 2004, the NRC issued a letter to licensees providing information on the Commission's phased approach for enhancing reactor mitigative measures and strategies for responding to Section B.5.b of the ICM Order. On February 25, 2005, the NRC issued guidance (Phase 1 guidance document) to describe more fully the NRC staff's expectations for implementing Section B.5.b of the ICM Order. Determination of the specific strategies required to satisfy the Order, elaborated on by the Phase 1 guidance document, was termed Phase 1.

Further information on the Commission's phased approach and its reliance on the Phase 1 guidance document and related workshop was described in an NRC letter to licensees dated January 14, 2005.

The NRC Phase 1 guidance document relied upon lessons learned from recent NRC engineering studies involving plant assessments, as well as industry best practices. This guidance also included the spent fuel pool mitigative measures described in a NRC letter to licensees dated July 29, 2004, "Issuance of Spent Fuel Pool Mitigative Measures." These best practices were identified during the inspections conducted in 2002 and 2003. The Phase 1 guidance document also incorporated industry comments made at two B.5.b-related workshops held on January 14, 2005, and February 2, 2005.

2.0 REGULATORY EVALUATION

Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily-available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire. Determination of the specific strategies required to satisfy the Order, elaborated on in the Phase 1 guidance document, was termed Phase 1.

In order to assure adequate protection of public health and safety and common defense and security, the NRC determined that differences in plant design and configuration warranted independent assessments to verify that the likelihood of damage to the reactor core, containment, and spent fuel pools and the release of radioactivity is low at each nuclear power plant. The Commission directed the NRC staff to conduct site-specific security and safety assessments to further identify enhanced mitigation capabilities. Site-specific assessments of spent fuel pools was deemed Phase 2 and site-specific assessments of reactor core and containments was deemed Phase 3.

Orrlw~~rW.A.LE" CE;lIR' l FOR MAO'~

11,1rI fIAUSCE fill- W--l-I l The goal of the Phase 2 and 3 mitigation strategy assessments was for the NRC and the licensees to achieve a new level of cognition of safety and security through a comprehensive understanding of the capabilities and limitations of the plants under normal, abnormal, and severe circumstances (from whatever cause). Based on this improved understanding, licensees could take reasonable steps to strengthen their capabilities and reduce their limitations. The NRC expected that safety and security would be well served by further enhancing the licensee's severe accident management strategies for mitigating a wide spectrum of events through the use of readily-available resources and by identifying potential-practicable areas for the use of beyond-readily-available resources.

During 2005, the NRC staff performed inspections (TI 2515/164) to determine licensees' compliance with Section B.5.b of the ICM Order (Phase 1). Subsequent meetings were held with licensees to resolve identified open issues. Confirmatory B.5.b Phase 1 inspections (TI 2515/168) were conducted during the period of June to December 2006. The NRC staff conducted site visits as part of the Phase 2 assessments during 2005. In 2006, the NRC staff observed licensee Phase 3 studies and conducted independent Phase 3 assessments.

On January 24, 2006, the Nuclear Energy Institute (NEI) submitted a letter (M. Fertel to L. Reyes) describing an industry proposal for resolving ("closing") Phase 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML060260220). The industry proposed high level functional mitigating strategies for a spectrum of potential scenarios involving spent fuel pools. In a letter to all Holders of Licenses for Operating Power Reactors dated June 21, 2006 (ADAMS Accession No. ML061670146), the NRC accepted the Phase 2 proposal pending review of site-specific details of its application and implementation.

In arriving at this conclusion, the NRC staff placed significant weight on portions of the proposal that rely on industry commitments to provide beyond-readily-available resources not previously available. These additions will significantly enhance licensees' mitigating strategies capabilities.

On June 27, 2006, the NEI submitted two letters (M. Fertel to W. Kane). In one of the letters, the NEI proposed a license condition to capture the Section B.5.b requirements and addressed items deferred from Phase 1 to Phase 2 (ADAMS Accession No. ML061790400). The license condition includes 14 items in the same broad categories as the February 25, 2005, Phase 1 guidance document; fire fighting response strategy, plant operations to mitigate fuel damage, and actions to minimize releases. The proposal suggested that the implementing details found to be an acceptable means of meeting the license condition would be treated as commitments, and managed in accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes." In the second letter, the NEI proposed generic strategies for closure of Phase 3 (ADAMS Accession No. ML061860753). The required strategies for all three phases would be covered by the license condition and all implementing details would be managed by NEI 99-04.

The February 25, 2005, Phase 1 guidance document included 34 expectations. Two of these items were deferred to Phase 2 and seven items (i.e., six expectations and one element of a seventh expectation) were deferred to Phase 3. The NRC staff reached agreement with licensees on the non-deferred items under Phase 1.

Table 1 provides a cross reference of how the 34 elements of the February 25, 2005, Phase 1 guidance document and Phases 2 and 3 mitigating strategies correspond to the sections of the license condition.

. . . . . .......- -.- ..L ...1 ;[ r -I 1- -- I-On June 29, 2006, the NRC staff issued a letter to the NEI conditionally accepting its proposed license condition and strategies (ADAMS Accession No. ML061790306). The letter reiterated that mitigation strategies in NEI's proposals that were identified during the Phase 2 and 3 assessments, which utilize reasonable, evident, readily-available resources (as identified in the February 25, 2005, Phase 1 guidance document) are required pursuant to Section B.5.b of the ICM Order. The implementing details of the required strategies will be implemented by commitment and managed in accordance with the NEI commitment management guideline, NEI 99-04. The NRC staff believes the NEI proposal reasonably justifies excluding from formal regulatory controls those additional strategies identified during the site-specific Phases 2 and 3 assessments that the NRC previously deemed required under Section B.5.b of the ICM Order, but not identified in NEI's proposals. Inherent in this conclusion is recognition of the addition of beyond-readily-available resouces included in the proposals. The implementing details of mitigation strategies included in the proposal, including those that utilize beyond-readily-available resources, will be treated as commitments, which will become part of the licensing basis of the plant. Additional strategies identified during site-specific assessments which licensees deem acceptable and valuable to promote diversification and survivability, will be incorporated into licensees' Severe Accident Management Guidelines, Extreme Damage Mitigation Guidelines, or appended to other site implementation guidance. To verify compliance, the NRC staff evaluated the site-specific implementation and documentation of the proposed Phases 2 and 3 mitigating strategies for each U.S. nuclear power plant.

3.0 TECHNICAL EVALUATION

The NRC staff's technical evaluation for strategies identified in Phase 1 of Section B.5.b is found in Appendix A. The NRC staff's technical evaluation for strategies identified in Phases 2 and 3 of Section B.5.b is found in Appendix B.

The Mitigating Strategies Table (MST) is included as Appendix C. The purpose of the MST is to capture, at the functional level, a summary of licensee strategies for compliance with the 34 measures presented in the February 25, 2005, Phase 1 guidance document and to indicate how the 34 items correlate to the 14 items in the license condition.

4.0 REGULATORY COMMITMENTS The implementing details of the mitigating strategies required by the license condition are identified in licensee submittals dated January 10, 2007 (ADAMS Accession No. ML070120522), and March 29, 2007 (ADAMS Accession No. ML070950213). These details will be implemented by commitment and managed in accordance with the NEI commitment management guideline, NEI 99-04. The NRC staff concludes this provides reasonable controls for mitigating strategy implementation and for subsequent evaluation of licensee-identified changes.

Because the 14 items required by the license condition correlate to the 34 items presented in the February 25, 2005, Phase 1 guidance document and the mitigating strategies within NEI's Phase 2 and 3 proposals, and because the implementing details will be managed under NEI 99-04, the NRC staff is satisfied that there will be sufficient controls to ensure that the strategies are adequately maintained.

411W ;lA IFE V[L Z Z ff..~ 1 a -2Wf

.F...IA HOF! SUCE'3L'., QEOEflI,"T'; I','-,::,,Tr

'3.'-LA r' ,

5.0 CONCLUSION

Based on the NRC staff's review described in Appendices A, B, and C of this SE, the licensee's responses to the February 25, 2005, Phase 1 guidance document and the spent fuel pool and reactor core and containment mitigating strategy assessments meet the requirements of Section B.5.b, Mitigative Measures, of the February 25, 2002, ICM Order that imposed interim compensatory measures on power reactor licensees. The NRC staff concludes that full implementation of the licensee's enhancements in the submittals identified in Section 4.0, above, constitutes satisfactory compliance with Section B.5.b and the licensee condition, and represents reasonable measures to enhance the licensee's effectiveness in maintaining reactor core and spent fuel pool cooling and containment integrity under circumstances involving the loss of large areas of the plant due to fires or explosions.

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Attachments (Official Use Only - Security-Related Information - ADAMS Accession No. ML071690506):

1. Phase 1 Assessment (Appendix A)
2. Phases 2 and 3 Assessment (Appendix B)
3. Mitigating Strategies Table (Appendix C)

Principal Contributors: David J. Nelson Michael K. Webb Nathan T. Sanfilippo Date: June 27, 2007 OFF-1TI3IA USE OIL'.'66" CE RfIT? fli6"rQ AAQ~o~I2

Table 1 CROSS REFERENCE BETWEEN LICENSE CONDITION AND GUIDANCE DOCUMENT ELEMENTS License Condition section Guidance Document Elements A. Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and B.1.b Staging of personnel guidance B.1.e Outside organization Support B.1.j Treatment of casualties B.1.k Site assembly areas (mass casualties)

B.1 .m Industry best practice - feeding fire protection ring header

2. Assessment of mutual aid fire fighting assets B.1 .c Airlifted resources B.1.f Mobilization of fire fighting resources - existing or new MOUs B.1 .g Mobilization of fire fighting resources - coordination with other than local mutual aid fire fighting resources (i.e, Industrial facilities, large municipal fire departments, airports, and military bases)
3. Designated staging areas for equipment and B.1 .a Staging of equipment materials B.1.h Controlling emergency response vehicles (includes rad monitoring)
4. Command and Control B.1.d Command and control B.l.i Communications enhancements
5. Training of response personnel B.1.1 Training considerations QrflZIAL U~E CT:LV CEoun:T': flELATED IlJrOflr..lATlor:

zrrtolAL uoi OIIL': o~ounrn: flELATED inror IraAiioII B. Operations to. mitigate fuel damage considering the following:

1. Protection and use of personnel assets B.2.a Personnel considerations
2. Communications B.2.b Communications measures
3. Minimizing fire spread B.2.h Compartmentalization of plant areas
4. Procedures for implementing integrated fire response B.2.c Procedures (Included in Phase 3 strategies) strategy B.2.d Evaluation of vulnerable buildings and equipment (Included in Phase 3 strategies)

B.2.e Industry best practice - Containment venting and vessel flooding B.2.f Industry best practice for compensatory function (Included in Phase 3 strategies)

B.2.g Best practice for use of plant equipment B.2.i Best practice involving plant areas potentially affected by fire or explosions (Included in Phase 3 strategies)

B.2.k Best practice for establishing supplemental response capabilities B.2.1 Best practice for establishing supplemental response capabilities

5. Identification of readily-available, pre-staged B.2.g Best practice for use of plant equipment - portable equipment generator and transformer (Included in Phase 3 strategies)

B.2.j Best practice involving reliance on portable and offsite equipment (Included in Phase 3 strategies) ff ýý2 Aý 1&1r'PrUM Aý10%-

81 1

7-7ILUJE3J~OOflT lLTD H ~ A m~

6. Training on integrated fire response strategy B.2.n Training considerations
7. Spent fuel pool mitigation measures B.2.m.1 Dispersal of Fuel B.2.m.2 Hot fuel over rack feet B.2.m.3 Downcomer area B.2.m.4 Enhanced air circulation (Included in Phase 2 strategies)

B.2.m.5 Emergency pool makeup, leak reduction/repair (Included in Phase 2 strategies)

C. Actions to minimize release to include considerations of:

1. Water spray scrubbing B.3.a Water spray scrubbing B.3.b Prestaging of equipment
2. Dose to onsite responders B.3.c Dose projection models (Included in Phase 3 strategies)
Retrieved from "https://kanterella.com/w/index.php?title=ML071270287&oldid=2577287"