ML12125A241

Closeout of Bulletin 2011-01, Mitigating Strategies

ML12125A241
Person / Time
Site:	Farley
Issue date:	05/25/2012
From:	Martin R Plant Licensing Branch II
To:	Ajluni M Southern Nuclear Operating Co
Martin R
References
TAC ME6430, TAC ME6431, BL-11-001
Download: ML12125A241 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 25,2012 Mr. M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295, Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 - CLOSEOUT OF BULLETIN 2011-01. "MITIGATING STRATEGIES" (TAC NOS. ME6430 AND ME6431)

Dear Mr. Ajluni:

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 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). The licensee for the Joseph M. Farley Nuclear Plant. Units 1 and 2 (FNP). provided its responses to the bulletin by letters dated June 10 and July 7,2011 (ADAMS Accession Nos. ML11165A009 and ML11196A093. respectively). By letter dated November 21, 2011 (ADAMS Accession No. ML11312A186). the NRC sent the licensee a request for additional information (RAI) on its July 7, 2011, response. The licensee responded to the RAI by letter dated December 15. 2011 (ADAMS Accession No. ML113530202).

M. Ajluni

-2 The NRC staff has reviewed the information submitted by the licensee for the FNP, and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the staff verified that the licensee provided the information requested in the bulletin. We find that no further information or actions under the bulletin are requested.

Sincerely,

&K&n=Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364

Enclosure:

Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv

SUMMARY

OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. SO-348 AND SO-364 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 bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code ofFederal Regulations (10 CFR) Section SO.S4(f). The first responses were due 30 days after issuance of the bulletin. By letter dated June 10,2011 (ADAMS Accession No. ML 1116SA009), Joseph M. Farley Nuclear Plant, Units 1 and 2, (Farley) provided its response to this first set of questions (first response). The second responses were due 60 days after issuance of the bulletin. By letter dated July 7, 2011 (ADAMS Accession No. ML11196A093), Farley provided its response to this second set of questions (second response). By letter dated November 21, 2011 (ADAMS Accession No. ML11312A186), the NRC sent a request for additional information (RAI) on the second response. Farley responded to the RAI by letter dated December 1S, 2011 (ADAMS Accession No. ML 113S30202). As summarized below, the NRC staff has verified that Farley provided the information requested in the bulletin.

1.0

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 2,2007 (ADAMS Accession No. ML072060014), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by Farley 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.

On March 27, 2009, the NRC issued 10 CFR SO.S4(hh}(2) as a new rule, in order to capture the B.S.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 SO.S4(hh)(2) (74 FR 13926) so no further actions were required on the part of current licensees.

Enclosure

- 2 2.0 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 Farley's first response to determine if it had adequately addressed these questions.

2.1 Question 1: Availability and Capability of Equipment In its first response, Farley confirmed that 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 needed for each of the three phases of B.5.b mitigation strategies. Therefore, the NRC staff finds that Farley has adequately responded to Question 1.

2.2 Question 2: Guidance and Strategies Can Be Executed In its first response, Farley 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 staff' skills. Since Farley has considered its current facility configuration, staffing levels, and staff' skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that Farley has adequately responded to Question 2.

3.0 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.

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.

- 3 The NRC staff reviewed Farley's submittals 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 Farley were relied upon by NRC staff to conclude that Farley's actions would ensure compliance with Section B.S.b of the ICM Order and the conforming license condition.

3.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 50-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, Farley listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, Farley described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.

The NRC staff verified that Farley listed equipment which (1) was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies, and (2) typically requires maintenance or testing. In its second response, Farley stated that the portable pump, portable power supply, hoses, spray nozzles, and communications equipment receive maintenance or testing. The NRC staff noted that the fuel level for the portable pump is checked after testing. Farley also identified other items that support the mitigating strategies that receive maintenance or testing.

The NRC staff verified that Farley described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. Farley 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.

Based upon the information above, the NRC staff finds that Farley has provided the information requested by Questions 1 and 2.

3.2 Question 3: Controls on Equipment Question 3 of the 50-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 Farley described its process for ensuring that B.S.b equipment will be available when needed. In its second response, Farley identified equipment included in its inventory, the inventory frequency. storage requirements, and items verified. Items verified include proper quantity and location. Farley states that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable. Farley reviewed its condition reports written since September 2008 and found three instances where inventory deficiencies were noted. These deficiencies were corrected and the licensee took additional actions to prevent recurrence.

-4 The NRC staff verified that Farley inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, Farley stated that procured non-permanently installed B.S.b equipment is inventoried at least annually in accordance with station procedures. The NRC staff noted that all items, except one, specifically listed in the second response, are inventoried on a quarterly basis. The second response specifically states that the following items are included in the inventory:

portable pump; portable power supply; hoses; communications equipment; nozzles; and connectors. In its RAI response, Farley described how it ensures that a vehicle will be available to move the B.S.b portable pump and other equipment when needed. Farley also identified other items that support the mitigating strategies that are inventoried.

Based upon the information above, the NRC staff finds that Farley has provided the information requested by Question 3.

3.3 Question 4: Configuration and Guidance Management Question 4 of the 50-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 Farley 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, Farley stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. Farley stated 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 Farley described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, Farley identified testing in response to Question 2 that demonstrated the ability to execute some strategies. Farley also stated that procedure changes affecting the mitigating strategies are "validated by walkdowns, engineering evaluations and/or table top reviews" and the B.S.b mitigating strategies were similarly revalidated in 2011.

The NRC staff verified that Farley described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, Farley identified the training provided to its operations personnel, emergency response organization, and fire brigade. Farley 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 finds that Farley has provided the information requested by Question 4.

3.4 Question 5: Offsite Support Question S of the 50-day request required licensees to describe in detail how offsite support availability is assured.

- 5 The NRC staff verified that Farley 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 Farley provided in its second response with the information relied upon to make conclusions in the SE. Farley stated that it maintains letters of agreement or other types of agreements with these offsite organizations and that these agreements were current at the time of its second response. Farley reviews and renews these agreements as necessary; however, most are validated on an annual basis. Farley also described the training and site familiarization it provides to these offsite organizations. Farley 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 finds that Farley has provided the information requested by Question 5.

4.0 CONCLUSION

As described above, the NRC staff has verified that Farley has provided the information requested in Bulletin 2011-01. Specifically, Farley responded to each of the questions in the bulletin as requested. The NRC staff concludes that Farley has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.

Principal Contributor: Blake Purnell, NRRIDPR Date: May 25, 2012

M. Ajluni

- 2 The NRC staff has reviewed the information submitted by the licensee for the FNP, and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the staff verified that the licensee provided the information requested in the bulletin. We find that no further information or actions under the bulletin are requested.

Sincerely, IRA!

Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364

Enclosure:

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