ML12171A431

Closeout of Bulletin 2011-01, Mitigating Strategies

ML12171A431
Person / Time
Site:	Seabrook
Issue date:	06/27/2012
From:	John Lamb Plant Licensing Branch 1
To:	Walsh K NextEra Energy Seabrook
Lamb J
References
TAC ME6483, BL-11-001
Download: ML12171A431 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 June 27,2012 Mr. Kevin Walsh Site Vice President c/o Michael O'Keefe Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION, UNIT 1 - CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NO. ME6483)

Dear Mr. Walsh:

On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin (BL) 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 BL 2011-01 was to obtain a comprehensive verification that the licensee's mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment, following a large explosion or fire are in compliance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).

BL 2011-01 required two sets of responses pursuant to the provisions of 10 CFR 50. 54(f).

Seabrook Station, Unit 1 (Seabrook) provided its responses to BL 2011-01 by letters dated June 10 and July 11, 2011 (ADAMS Accession Nos. ML11166A254 and ML11199A047). By letter dated December 8,2011 (ADAMS Accession No. ML113330085), the NRC staff sent the licensee a request for additional information (RAI) regarding its July 11, 2011, response. The licensee responded to the RAI by letter dated January 5, 2012 (ADAMS Accession No. ML12012A063).

The NRC staff has reviewed the information submitted by Seabrook, and concludes that its response to BL 2011-01 is acceptable. As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in BL 2011-01.

K. Walsh -2 If you have any questions, please contact me at (301) 415-3100.

Jo n G. Lamb, Senior Project Manager PI Licensing Branch 1-2 Di sion of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

As stated cc: Distribution via Listserv

SUMMARY

OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW NEXTERA ENERGY SEABROOK LLC I SEBROOK STATION, UNIT 1 DOCKET NO. 50-443

1.0 INTRODUCTION

On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin (BL) 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.

BL 2011-01 required two sets of responses pursuant to the provisions of with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(f). The first set of responses were due 30 days after issuance of BL 2011-01.

By letter dated June 10, 2011 (ADAMS Accession No. ML11166A254), Seabrook Station, Unit 1 (Seabrook) provided its response to this first set of questions (first response). The second set of responses were due 60 days after issuance of BL 2011-01. By letter dated July ii, 2011 (ADAMS Accession No. ML11199A047), Seabrook provided its response to this second set of questions (second response). By letter dated December 8,2011 (ADAMS Accession No. ML113330085), the NRC staff sent a request for additional information (RAI) regarding the second response. Seabrook responded to the RAI by letter dated January 5, 2012 (ADAMS Accession No. ML12012A063). As summarized below, the NRC staff has verified that Seabrook 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" (lCM 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 9, 2007 (ADAMS Accession No. ML072120088), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by Seabrook regarding Section B.5.b of the ICM Order. Along with the SE, the NRC staff issued a conforming license condition to incorporate the B.5.b mitigating strategies into the licensing basis.

- 2 On March 27, 2009, the NRC issued 10 CFR 50.54(hh}(2} as a new rule, 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} (74 FR 13926);

therefore, 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}, BL 2011-01 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 Seabrook's first response to determine if it had adequately addressed these questions, as summarized below.

3.1.1 Question 1: Availability and Capability of Equipment In its first response, Seabrook 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 the B.5.b mitigation strategies. Therefore, the NRC staff finds that Seabrook has adequately responded to Question 1.

3.1.2 Question 2: Guidance and Strategies Can Be Executed In its first response, Seabrook 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 staffs skills. Since Seabrook 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 Seabrook has adequately responded to Question 2.

-3 3.2 60-Day Request Bl2011-01 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.

The NRC staff reviewed Seabrook's submittals to determine if it had adequately addressed these questions, as summarized below. This was accomplished by verifying that the submittals listed equipment, training, and offsite resources which were relied upon to make conclusions in the August 9,2007, SE or are commonly needed to implement the mitigating strategies.

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, Seabrook listed the equipment used to support the 10 CFR 50.54(hh)(2) mitigating strategies which receives maintenance or testing. For each item, Seabrook described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.

The NRC staff verified that Seabrook listed the 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, Seabrook stated that the portable pump.

hoses, and communications equipment receive maintenance or testing. Seabrook did not identify maintenance or testing of monitor nozzles, spray nozzles, or similar devices in its second response. In its RAI response, Seabrook stated that monitor and spray nozzles are visually inspected during inventory. The NRC staff noted that the refueling of the portable pump is a maintenance activity and that the adequacy of the fuel supply is verified weekly. Seabrook also identified other items that support the mitigating strategies that receive maintenance or testing.

-4 The NRC staff verified that Seabrook described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. Seabrook 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 Seabrook 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 Seabrook described its process for ensuring that B.S.b equipment will be available when needed. In its second response, Seabrook identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified. Items verified include proper quantity, location, and accessibility of equipment and controls on storage locations. Seabrook stated 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 Seabrook inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, Seabrook stated that procured non-permanently installed B.S.b equipment is inventoried at least annually in accordance with station procedures. The second response specifically stated that the following items are included in the inventory: portable pump; hoses; communications equipment; nozzles; connectors; and firefighter turnout gear. In its RAI response, Seabrook described how it ensures the availability of a vehicle to move the portable pump and other B.S.b equipment. Seabrook also identified other items that support the mitigating strategies that are inventoried.

Based upon the information above, the NRC staff finds that Seabrook 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 Seabrook 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, Seabrook stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. Seabrook stated that it performs a B.S.b equipment surveillance every 18 months and a B.S.b procedure review at least every 3 years to ensure that procedures are current.

-5 The NRC staff verified that Seabrook described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, Seabrook identified testing in response to Question 2 that demonstrated the ability to execute some of the strategies. Seabrook also stated that it performed a comprehensive review and walkdowns of B.5.b procedures, including verifying the fit up to flanges in March 2011.

The NRC staff verified that Seabrook described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, Seabrook identified the training provided to its operations personnel, emergency response organization key decision makers, security personnel, and fire brigade. Seabrook also identified the frequency of when each type of training is provided and the methods for the evaluation of the training.

Based upon the information above, the NRC staff finds that Seabrook has provided the information requested by Question 4.

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

The NRC staff verified that Seabrook 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 Seabrook provided in its second response with the information relied upon to make conclusions in the SE. Seabrook stated that it maintains letters of agreement or other types of agreements with these offsite organizations, which are reviewed annually, and that these agreements were current at the time of its second response. Seabrook also described the training and site familiarization it provides to these offsite organizations.

Seabrook 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 Seabrook has provided the information requested by Question 5.

4.0 CONCLUSION

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

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