ML12125A021
| ML12125A021 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/15/2012 |
| From: | Feintuch K Plant Licensing Branch III |
| To: | Heacock D Dominion Energy Kewaunee |
| Feintuch K | |
| References | |
| BL-11-001, TAC ME6443 | |
| Download: ML12125A021 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 15, 2012 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center SOOO Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
KEWAUNEE POWER STATION - CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. ME6443)
Dear Mr. Heacock:
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. 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 SO.S4(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR SO.S4(f).
Dominion Energy Kewaunee, Inc. (DEK) provided its responses to the bulletin by letters dated June 9 and July 11, 2011.
The NRC staff has reviewed the information submitted by DEK and concludes that its response to the bulletin is acceptable. The NRC staff summary of NRC Bulletin 2011-01 response review is enclosed. No further information or actions under the bulletin are requested.
D. Heacock -2 Please feel free to contact me at (301) 415-3079 if you have any questions.
Sincerely, Kar . Feintuch, proiectCger Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305
Enclosure:
As stated cc: Distribution via Listserv
SUMMARY
OF NRC BULLETIN 2011-01. "MITIGATING STRATEGIES" RESPONSE REVIEW BY THE OFFICE OF NUCLEAR REACTOR REGULATION DOMINION ENERGY KEWAUNEE. INC.
KEWAUNEE POWER STATION DOCKET NO. 50-305
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. 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. 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 50.54(f). The first response was due 30 days after issuance of the bulletin. By letter dated June 9,2011 (ADAMS Accession No. ML11165A092), Dominion Energy Kewaunee, Inc. (DEK, 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 11, 2011 (ADAMS Accession No. ML11194A013), DEK provided its response to this second set of questions. As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin.
2.0 BACKGROUND
On February 25, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). 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 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 2,2007 (ADAMS Accession No. ML072120003), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by the licensee regarding Section B.5.b of the ICM Order. Along with the SE, the staff issued a conforming license condition to incorporate the B.5.b mitigating strategies into the licensing basis.
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.
Enclosure
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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 (i.e., letter dated June 9,2011) to determine if it had adequately addressed these questions.
3.1.1 Question 1: Availability and Capability of Equipment In its first response, the licensee confirmed that the equipment it needs to execute the 10 CFR 50.54(hh)(2) mitigating strategies is available and capable of performing its intended function.
The NRC staff verified that this confirmation covered equipment need for each of the three phases of B.5.b mitigating strategies.
Based on the above, the NRC staff concludes that the licensee has adequately responded to Question 1.
3.1.2 Question 2: Capability to Execute Guidance and Strategies In its first 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.
Since the licensee has 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.
3.2 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 50.54(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 50.54(hh)(2) in order to ensure that it will function when needed.
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- 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.
- 5. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed the licensee's second response (i.e., letter dated July 11, 2011) to determine if it had adequately addressed these questions. The NRC staff also reviewed the August 2,2007, SE to determine what equipment, training, and offsite resources at the Kewaunee Power Station were relied upon by NRC staff to conclude that the licensee's actions would ensure compliance with Section B.5.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 50.54(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 50.54(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, portable power supplies, hoses, and communications equipment receive maintenance or testing. The licensee also stated that the condition of fire nozzles and devices is verified as part of the inventory. 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 50, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
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.
-4 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, locations, and accessibility of equipment; calibrations; equipment shelf lives; and controls on storage. 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 licensee identified one inventory deficiency that it found and corrected.
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 once per calendar quarter in accordance with station procedures; however the licensee did identify some items that are inventoried less frequently. The licensee's response specifically states that the following items are included in the inventory: portable pump; portable power supplies; hoses; communications equipment; tow vehicle; spray nozzles; adapters, connections, and fittings; tools; instruments; and firefighter turnout gear. 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 some strategies. The licensee also states that "initially, mitigating strategies were validated by walk-through, engineering evaluations, and table top reviews," and they were revalidated by walk-throughs 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.
- 5 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 licensee stated that it maintains letters of agreement with these 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.
D. Heacock -2 Please feel free to contact me at (301) 415-3079 if you have any questions.
Sincerely, IRAJ Terry Beltz for Karl D. Feintuch, Project Manager Plant licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-305
Enclosure:
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PUBLIC RidsNrrPMKewaunee Resource RidsOgcRp Resource LPL3-1 rtf RidsNrrLABTully Resource BPurnell, NRR RidsAcrsAcnw_MailCTR Resource RidsRgn3MailCenter Resource EBowman, NRR RidsNrrDorlLpl3-1 Resource RidsNrrDorlDpr Resource RidsNrrDssStsb Resourc RidsNrrDprPgcb Resource ADAMS Accession No.: ML12125A021
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