ML12129A414
| ML12129A414 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/11/2012 |
| From: | V Sreenivas Plant Licensing Branch II |
| To: | Heacock D Virginia Electric & Power Co (VEPCO) |
| Sreenivas V | |
| References | |
| TAC ME6453, TAC ME6454, BL-11-001 | |
| Download: ML12129A414 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 i'-:ay 11, 2012 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. ME6453 AND ME6454)
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. 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).
North Anna Power Station, Units 1 and 2, provided its responses to the bulletin by letters dated June 7 and July 11. 2011 (ADAMS Accession Nos. ML11164A020 and ML11194A011). By letter dated November 17,2011 (ADAMS Accession No. ML11314A189). the NRC sent the licensee a request for additional information (RAI) on its July 11, 2011, response. The licensee responded to the RAI by letter dated December 15. 2011 (ADAMS Accession No. ML11355A154).
The NRC staff has reviewed the information submitted by North Anna Power Station and concludes that its response to the bulletin is acceptable. The NRC staff Summary of NRC Bulletin 2011-01 Response Review is enclosed.
D. Heacock
-2 Please feel free to contact me at 301-415-2597 if you have any questions.
Sincerely,
. V. Sreenivas, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339
Enclosures:
As Stated cc w/encls: Distribution via Listserv
SUMMARY
OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW NORTH ANNA POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339 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 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 7,2011 (ADAMS Accession No. ML11164A020), North Anna Power Station, Units 1 and 2 (NAPS),
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 11, 2011 (ADAMS Accession No. ML11194A011), NAPS provided its response to this second set of questions (second response). By letter dated November 17, 2011 (ADAMS Accession No. ML11314A189), the NRC sent a request for additional information (RAJ) on the second response. NAPS responded to the RAI by letter dated December 15, 2011 (ADAMS Accession No. ML 113SSA 154). As summarized below, the NRC staff has verified that NAPS provided the information requested in the bulletin.
1.0
Background
On February 25, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (lCM 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 Jetter dated August 2,2007 (ADAMS Accession No. ML072120264), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by NAPS 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.54(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.
- 2 2.0 30-Day Request In order to confirm continued compliance with 10 CFR SO.S4(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 NAPS'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, NAPS confirmed that the equipment it needs to execute the 10 CFR SO.S4(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.S.b mitigation strategies. Therefore, the NRC staff finds that NAPS has adequately responded to Question 1.
2.2 Question 2: Guidance and Strategies Can Be Executed In its first response, NAPS confirmed that the guidance and strategies it has implemented for 10 CFR SO.S4(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staff's skills. Since NAPS has considered its current facility configuration, staffing levels, and staff's skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that NAPS has adequately responded to Question 2.
3.0 SO-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.
- 3
- 5. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed NAPS'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 NAPS were relied upon by NRC staff to conclude that NAPS's actions would ensure compliance with Section B.5.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 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, NAPS listed the equipment used to support the 10 CFR 50.54(hh)(2) mitigating strategies which receives maintenance or testing. For each item, NAPS described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that NAPS 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, NAPS stated that the portable pump, fire truck, portable power supply, hoses, and communications equipment receive maintenance or testing.
In response to the RAI, NAPS described its testing of oscillating monitor nozzles and stated that they are verified to be in good condition on a three year frequency. The NRC staff noted that the fuel level for the portable pump is verified during maintenance. NAPS also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that NAPS described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. NAPS 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 finds that NAPS has provided the information requested by Questions 1 and 2.
3.2 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 NAPS described its process for ensuring that B.5.b equipment will be available when needed. In its second response, NAPS identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified. Items verified include proper quantity, location, and accessibility of equipment; compressed gas bottle pressures; calibrations; equipment shelf lives; and controls on storage locations. NAPS stated
-4 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 NAPS inventories equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, NAPS states that procured non-permanently installed B.S.b equipment is inventoried at least every three years in accordance with station procedures. The second response specifically states that the following items are included in the inventory: portable pump; fire truck; portable power supplies; hoses; communications equipment; nozzles; connectors; and firefighter turnout gear. NAPS also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that NAPS has provided the information requested by Question 3.
3.3 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 NAPS 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, NAPS stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. NAPS 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 NAPS described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, NAPS identified testing in response to Question 2 that demonstrated the ability to execute some strategies. NAPS 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 NAPS described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, NAPS identified the training provided to its operations personnel, emergency response organization key decision makers, security personnel, fire brigade, and other personnel. NAPS also identified the frequency with which each type of training is provided and the methods for training evaluation.
Based upon the information above. the NRC staff finds that NAPS has provided the information requested by Question 4.
3.4 Question 5: Offsite Support Question 5 of the 60-day request required licensees to describe in detail how offsite support availability is assured.
- 5 The NRC staff verified that NAPS 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 NAPS provided in its second response with the information relied upon to make conclusions in the SE. NAPS stated that it maintains letters of agreement (LOAs), memoranda of understanding (MOUs), or other types of agreements with these offsite organizations, and that these agreements were current at the time of its second response. The LOAs and MOUs are review annually and renegotiated every two years; the other agreements are renewed as needed. NAPS also described the training and site familiarization it provides to these offsite organizations.
Based upon the information above, the NRC staff finds that NAPS has provided the information requested by Question 5.
4.0 CONCLUSION
As described above, the NRC staff has verified that NAPS has provided the information requested in Bulletin 2011-01. Specifically, NAPS responded to each of the questions in the bulletin as requested. The NRC staff concludes that NAPS has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.
D. Heacock
- 2 Please feel free to contact me at 301-415-2597 if you have any questions.
Docket Nos. 50-338 and 50-339
Enclosures:
As Stated cc w/encls: Distribution via Listserv DISTRIBUTION:
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