ML120950064
| ML120950064 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 04/19/2012 |
| From: | Beltz T Plant Licensing Branch III |
| To: | Meyer L Point Beach |
| beltz T, NRR/DORL/LPL3-1, 301-415-3049 | |
| References | |
| TAC ME6469, TAC ME6470, BL-11-001 | |
| Download: ML120950064 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 19, 2012 Mr. Larry Meyer Site Vice President NextEra Energy Point Beach, LLC Point Beach Nuclear Plant 6610 Nuclear Road Two Rivers, WI 54241
SUBJECT:
CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. ME6469 AND ME6470)
Dear Mr. Meyer:
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of NRC Bulletin 2011-01 (the bulletin) was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f).
NextEra Energy Point Beach, LLC (NextEra) provided its responses to the bulletin by letters dated June 7, June 10, and July 8, 2011. By letter dated November 15, 2011, the NRC sent a request for additional information (RAI) associated with the July 8, 2011, response. NextEra responded to the RAlin a letter dated December 12, 2011.
The NRC staff has reviewed the information submitted by NextEra and concludes that its response to the bulletin is acceptable. Our safety evaluation is enclosed. No further information or actions under the bulletin are requested.
L. Meyer
- 2 Please feel free to contact me at (301) 415-3049 if you have any questions.
Sincerely,
~~
Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NRC BULLETIN 2011-01, "MITIGATING STRATEGIES" NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. SO-266 AND SO-301
1.0 INTRODUCTION
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML 1112S0360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel.Bulletin 2011-01 (the bulletin) required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section SO.S4(f). The first response was due 30 days after issuance of the bulletin. By letters dated June 7, and June 10, 2011 (ADAMS Accession Nos. ML 111S90721 and ML111610S12, respectively), NextEra Energy Point Beach, LLC (NextEra, the licensee) provided its response to the first set of questions. The second response was due 60 days after issuance of the bulletin. By letter dated July 8, 2011 (ADAMS Accession No. ML111920320), the licensee provided its response to this second set of questions. By letter dated November 1S, 2011 (ADAMS Accession No. ML113130071), the NRC staff sent a request for additional information (RAI) associated with the July 8, 2011, response. The licensee responded to the RAI by letter dated December 12, 2011 (ADAMS Accession No. ML113460076). As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin.
2.0 BACKGROUND
On February 2S, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.S.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 readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire.
By letter dated August 16, 2007 (ADAMS Accession No. ML072270007), the NRC staff issued its Safety Evaluation (SE) to document the final dispOSition of information submitted by the licensee regarding Section B.S.b of the ICM Order. Along with the SE, the staff issued a conforming license condition to incorporate the B.S.b mitigating strategies into the licensing basis.
Enclosure
- 2 On March 27, 2009, the NRC issued 10 CFR 50.54(hh)(2) as a new rule (74 FR 13926), in order to capture the B.5.b mitigating strategies and related license conditions as regulatory requirements for both current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR 50.54(hh)(2), so no further actions were required on the part of current licensees.
3.0 TECHNICAL EVALUATION
3.1 30-Day Request In order to confirm continued compliance with 10 CFR 50.54(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin:
- 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?
- 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?
The NRC staff reviewed the licensee's first response to determine if it had adequately addressed these questions.
3.1.1 Question 1: Availability and Capability of Equipment In its June 7,2011, response, the licensee confirmed that the equipment it needs to execute Phases 2 and 3 of the B.5.b mitigating strategies is available and capable of performing its intended function. Following a teleconference with the NRC, the licensee provided a revised response on June 10, 2011, confirming that the equipment it needs to execute Phases 1, 2, and 3 of the B.5.b mitigating strategies is available and capable of performing its intended function.
Since this confirmation covered equipment needed for each of the three phases of B.5.b mitigation strategies, the NRC staff concludes that the licensee has adequately responded to Question 1.
3.1.2 Question 2: Guidance and Strategies Can Be Executed In its June 7,2011, response, the licensee confirmed that the guidance and strategies it has implemented for 10 CFR 50.54(hh)(2) are capable of being executed conSidering the current facility configuration, staffing levels, and staffing skills. However, the NRC staff found that this response only referred to the Phase 2 and 3 B.5.b mitigation strategies. Following a teleconference between the NRC and licensee staff, the licensee submitted a revised response on June 10, 2011, which provided a reference for all three phases.
Since the licensee considered its current facility configuration, staffing levels, and staffing skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff concludes that the licensee has adequately responded to Question 2.
- 3 3.2 60-Day Request The bulletin required a response to the following five questions within 60 days of issuing the bulletin:
- 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed.
- 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it will function when needed.
- 3. Describe in detail the controls for ensuring that the equipment is available when needed.
- 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible.
S. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed the licensee's submittals to determine if it had adequately addressed these questions. The NRC staff also reviewed the August 16, 2007, SE to determine what equipment, training, and offsite resources at the Point Beach Nuclear Plant were relied upon by NRC staff to conclude that the licensee's actions would ensure compliance with Section B.S.b of the ICM Order and the conforming license condition.
3.2.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that the portable pump, hoses, and communications equipment receive maintenance or testing. The licensee did not identify maintenance, testing, or controls on monitor nozzles, spray nozzles, or similar devices in its second response. In its RAI response, the licensee stated that its equipment inventory includes nozzles and that its inventory process includes a visual inspection of the equipment.
The NRC staff noted that refueling of the portable pump is a maintenance activity. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. The licensee stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
- 4 Based upon the information above, the NRC staff concludes that the licensee has provided the information requested by Questions 1 and 2.
3.2.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment, such as inventory requirements, to ensure that the equipment is available when needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested.
The NRC staff verified that the licensee described its process for ensuring that B.S.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity and location. The licensee also stated that it checks the condition of many items as part of its inventory and that some specific items had additional verifications. The licensee states that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable.
The NRC staff verified that the licensee inventoried equipment which was relied upon to make conclusions in the SE or commonly. needed to implement the mitigating strategies. In its second response, the licensee stated that procured non-permanently installed B.S.b equipment is inventoried at least annually in accordance with station procedures. However, the NRC staff noted that all equipment specifically listed, except dosimetry, was inventoried quarterly and the licensee stated in its RAI response that it performs quarterly equipment inventory of B.S.b equipment. The licensee responses specifically state that the following items are included in the inventory: portable pump; tow vehicle; hoses; communications equipment; spray nozzles; and adapters. The licensee also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff concludes that the licensee has provided the information requested by Question 3.
3.2.3 Question 4: Configuration and Guidance Management Question 4 of the 60-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible.
The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current.
In its second response, the licensee stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. The licensee states that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.S.b mitigating strategies remain viable.
The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, the licensee identified testing in response to Question 2 that demonstrated the ability to execute
- 5 some strategies. The licensee also states that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011.
The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, the licensee identified the training provided to its operations personnel, emergency response organization key decision makers, security personnel, fire brigade, and other personnel. The licensee also identified the frequency with which each type of training is provided and the methods for training evaluating.
Based upon the information above, the NRC staff concludes that the licensee has provided the information requested by Question 4.
3.2.4 Question 5: Offsite Support Question 5 of the 60-day request required licensees to describe in detail how offsite support availability is assured.
The NRC staff verified that the licensee listed the offsite organizations it relies upon for emergency response, including a description of agreements and related training. The NRC staff compared the list of offsite organizations that the licensee provided in its second response with the information relied upon to make conclusions in the SE. The NRC staff noted that the licensee did not identify any local law enforcement agencies in its second response. In its RAI response, the licensee described how it assures the availability of two local law enforcement agencies to respond to a B.5.b event. The licensee stated that it maintains letters of agreement or contracts with these offsite organizations, which are reviewed annually, and that these agreements were current at the time of its second response. The licensee also described the training and site familiarization it provides to these offsite organizations. The licensee stated that it reviewed its corrective action program back to 2008 and found no issues involving lapsed agreements related to offsite support for B.5.b events.
Based upon the information above, the NRC staff concludes that the licensee has provided the information requested by Question 5.
4.0 CONCLUSION
As described above, the NRC staff verified that the licensee has provided the information requested in Bulletin 2011-01. Specifically, the licensee responded to each of the questions in the bulletin as requested. The NRC staff concludes that the licensee has completed all of the requirements of the bulletin and that no further information or actions under the bulletin are needed.
Principal Contributor: B. Purnell, NRR Date: April 19, 2012.
L. Meyer
- 2 Please feel free to contact me at (301) 415-3049 if you have any questions.
Sincerely, IRAJ Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-266 and 50-301
Enclosure:
Safety Evaluation cc: Distribution via Listserv DISTRIBUTION:
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