ML071710148

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Conforming License Amendments to Incorporate the Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (Tac Nos. MD4496 and MD4497)
ML071710148
Person / Time
Site: Beaver Valley
Issue date: 06/27/2007
From: Nadiyah Morgan
NRC/NRR/ADRO/DORL/LPLI-1
To: Lash J
FirstEnergy Nuclear Operating Co
Morgan N, NRR/DORL, 415-3650
Shared Package
ML071710144 List:
References
EA-02-026, TAC MD4496, TAC MD4497
Download: ML071710148 (20)
v • d • e


Text

June 27, 2007 J. H. Lash 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.

The enclosed Safety Evaluation (SE) details the interactions between the NRC staff and the FirstEnergy Nuclear Operating 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 plant's licensing basis.

This proposed license condition was transmitted by the NRC to the FirstEnergy Nuclear Operating Company in a letter dated October 13, 2006. By letter dated January 26, 2007, the FirstEnergy Nuclear Operating 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, administrative license changes to Facility Operating License No. DPR-66 for the Beaver Valley Power Station, Unit No. 1, and to Facility Operating License No. NPF-73 for the Beaver Valley Power Station Unit No. 2, are being made to incorporate the agreed upon license condition. These changes comply 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 FederalRegulations (10 CFR) Chapter I. Please replace the affected pages of the Facility Operating Licenses with the enclosed pages (Enclosure 1).

The attachments to the SE are designated exempt frorn 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) 415-1016.

Sincerely,

/RA/

Nadiyah IS>. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Revised Pages of Facility Operating License Nos. DPR-66 and NPF-73
2. Safety Evaluation cc w/o atts to Encl. 2: See next page DISTRIBUTION (w/o attachments to Safety Evaluation)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2007 Mr. James H. Lash Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2- CONFORMING LICENSE AMENDMENTS TO INCORPORATE THE MITIGATION STRATEGIES REQUIRED BY SECTION B.5.b. OF COMMISSION ORDER EA-02-026 (TAC NOS. MD4496 AND MD4497)

Dear Mr. Lash:

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 FirstEnergy Nuclear Operating Company for the Beaver Valley Power Station, Unit Nos. 1 and 2, 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 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.

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16R/r J. H. Lash 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.

The enclosed Safety Evaluation (SE) details the interactions between the NRC staff and the FirstEnergy Nuclear Operating 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 licenses. 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 FirstEnergy Nuclear:

Operating Company in a letter dated October 13, 2006. By letter dated January 26, 2007, the FirstEnergy Nuclear Operating 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, administrative license changes to Facility Operating License No. DPR-66 for the Beaver Valley Power Station, Unit No. 1, and to Facility Operating License No. NPF-73 for the Beaver Valley Power Station Unit No. 2, are being made to incorporate the agreed upon license condition. These changes comply 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 FederalRegulations (10 CFR) Chapter I. Please replace the affected pages of the Facility Operating Licenses 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) 415-1016.

Sincerely, Nadiyah S. Morgan, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412

Enclosures:

1. Revised Pages of Facility Operating License Nos. DPR-66 and NPF-73
2. Safety Evaluation cc w/o atts to Encl. 2: See next page XE ZA.L...

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Beaver Valley Power Station, Unit Nos. 1 and 2 cc w/o atts to Encl. 2:

Joseph J. Hagan . James H. Lash President and Chief Nuclear Officer Site Vice President FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Beaver Valley Power Station 76 South Main Street Mail Stop A-BV-SEB1 Akron, OH 44308 P.O. Box 4, Route 168 Shippingport, PA 15077 James H. Lash -

Senior Vice President of Operations Director, Fleet Regulatory Affairs and Chief Operating Officer FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Mail Stop A-GO-14 76 South Main Street 76 South Main Street Akron, Ohio 44308 Akron, OH 44308 Manager, Site Regulatory Compliance Darnny L. Pace FirstEnergy Nuclear Operating Company Senior Vice President, Fleet Engineering Beaver Valley Power Station FirstEnergy Nuclear Operating Company Mail Stop A-BV-A Mail Stop A-GO-14 P.O. Box 4, Route 168 76 South Main Street Shippingport, PA 15077 Akron, OH 44308 Richard Anderson Jeannie M. Rinckel Vice President, Nuclear Support Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Mail Stop A-GO-14 Akron, Ohio 44308 76 South Main Street Akron, OH 44308 Commissioner James R. Lewis West Virginia Division of Labor David W. Jenkins, Attorney 749-B, Building No. 6 FirstEnergy Corporation Capitol Complex Mail Stop A-GO-15 Charleston, WV 25305 76 South Main Street Akron, OH 44308 Director, Utilities Department Public Utilities Commission Manager, Fleet Licensing 180 East Broad Street FirstEnergy Nuclear Operating Company Columbus, OH 43266-0573 Mail Stop A-GO-2 76 South Main Street Director, Pennsylvania Emergency Akron, OH 44308 Management Agency 2605 Interstate Dr.

Ohio EPA-DERR Harrisburg, PA 17110-9364 ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OiH 43266-0149

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc w/o atts to Encl. 2:

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077

ENCLOSURE 1 REVISED PAGES OF FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 DOCKET NOS. 50-334 AND 50-412 BEAVER VALLEY POWER STATION. UNITS 1 AND 2 Replace the following pages of the Facility Operating Licenses. The revised pages are identified by the date of the letter issuing these pages and contain marginal lines indicating the areas of change.

REMOVE INSERT License DPR-66 License DPR-66 Page 6a Page 7 Page 8 License NPF-73 License NPF-73 Page 5 Page 5 Page 5a

(10) Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 278, are hereby incorporated into this license. FENOC shall operate the facility in accordance with the Additional Conditions.

(11) Mitication StrateQy License Condition The licensee shall 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 Amendment No. 278 Revised by letter dated June 27, 2007

D. Physical Protection FENOC 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 10CFR 50.90 and 10 CFR 50.5-4 p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 is entitled: "Beaver Valley Power Station (BVPS) Physical Security Plan" submitted by letter September 9, 2004, and supplemented September 30, 2004, October 14, 2004, and May 12, 2006.

E. All work and activities in connection with this project shall be performed pursuant to the provisions of the Commonwealth of Pennsylvania Clean Streams Acts of June 24, 1913, as amended and of June 22, 1937, as amended, and in accordance with all permits issued by the Department of Environmental Resources of the Commonwealth of Pennsylvania.

F. This amended license is effective as of the date of issuance and shall expire at midnight on January 29, 2016.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIIGNED BY R. S. BOYD Roger S. Boyd, Director Division of Project Management Office of Nuclear Reactor Regulation Date of Issuance: July 2, 1976 Amendment No. 278 Revised by letter date( 1 June 27, 2007

(8) Detailed Control Room Design Review (DCRDR)

Deleted (9) Safety Parameter Display System (SPDS)

Deleted (10) Fire Protection Modifications (Section 9.5.1 of SER Supplement 6)

Deleted (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. 161, are hereby incorporated into this license. FENOC shall operate the facility in accordance with the Additional Conditions.

(12) Steam Generator Surveillance Interval Extension Deleted (13) Mitigation Strategy License Condition The licensee shall 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 Amendment No. 161 Revised by letter dated June 27, 2007

- 5a -

D. Exemptions The following exemptions are authorized by law and will not endanger life or property or the common defense and security, and certain special circumstances are present. With the granting of these exemptions, 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.

(1) The facility requires an exemption from the requirements of General Design Criterion (GDC) 4, Appendix A to 10 CFR 50. The staff has described in detail in Supplement 4 and Supplement 5 to the Safety Evaluation Report the technical basis and "special circumstances" associated with this exemption. The staffs environmental assessment was published on March 27, 1987 (52 FR 9979).

Therefore, pursuant to 10 CFR 50.12(a)(1), 10 CFR 50.12(a)(2)(ii) and (iv),

Beaver Valley Power Station, Unit 2 is exempt from the requirements of GDC 4, Appendix A to 10 CFR 50 with respect to the dynamic loading effects associated with the postulated pipe breaks described in detail in Section 3.6.3 of Supplement 4 to the Safety Evaluation Report. These dynamic loading effects include pipe whip, jet impingement, and break-associated dynamic transients.

Specifically, this eliminates the need to install jet impingement barriers and pipe whip restraints associated with postulated pipe breaks in the pressurizer surge line, reactor coolant bypass system, Amendment No. 161 Revised by letter dated June 27, 2007 I

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,*IV *GP'% UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER NO. EA-02-026 FIRSTENERGY NUCLEAR OPERATING COMPANY FIRSTENERGY NUCLEAR GENERATION CORP.

OHIO EDISON COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412

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 FirstEnergy Nuclear Operating 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 NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this Safety Evaluation is DECONTROLLED.

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 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 Q........ .... ...... .................... l :r -" """"or 1/"

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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.

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 (NE--I) 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.

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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.

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 26, 2007 (ADAMS Accession No. ML070300068), and April 19, 2007 (ADAMS Accession No. ML071140191). 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 or~oALUG OIL' EOn~! llATP fl~fr1T0

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r'% (41A -0 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.

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 amendments 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. ML071720306):

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 QFirliglAN 11^1- -%KID %/ I!1rrII6&r 117^MRII A-rlrhl

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 V At"%I It, 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.1.i Communications enhancements
5. Training of response personnel B.1 e. Training considerations OIOa L Q 1:--QErmr:fEATDlarfrIAII

orrIo:AL UOE or:L'.' OEOUflIT.' flELATED llironr.1ATIorJ 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)

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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) orrIZiAL up: c[:L: DEDUIlIT.' flELATE~ lr:rOflF.1.~.TIOlI
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