ML12172A268
| ML12172A268 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/26/2012 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Entergy Operations, "G" Force |
| Kalyanam N | |
| References | |
| TAC ME6499, BL-11-001 | |
| Download: ML12172A268 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 June 26. 2012 Vice President, Operations Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NUCLEAR REGULATORY COMMISSION BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NO. ME6499)
Dear Sir or Madam:
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). By letters dated June 10 and July 11, 2011, and supplemented by letter dated January 5, 2012 (ADAMS Accession Nos. ML111610519, ML111930167, and ML120060156, respectively),
Entergy Operations, Inc., the licensee for Waterford Steam Electric Station, Unit 3, provided its responses to the bulletin. Portions of the letter dated July 11, 2011, contain sensitive unclassified non-safeguards information (security-related) and have been withheld from public disclosure.
The NRC staff has reviewed the information submitted by the licensee and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in the bulletin and no further information or actions under the bulletin are requested.
- 2 If you have any questions, please contact me at 301-415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely,
- ~/"
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/encl: Distribution via Listserv
SUMMARY
OF REVIEW OF LICENSEE'S RESPONSES TO NRC BULLETIN 2011-01, "MITIGATING STRATEGIES" ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382
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. 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 responses were due 30 days after issuance of the bulletin. By letter dated June 10, 2011 (ADAMS Accession No. ML111610519), Entergy Operations Inc., the licensee for Waterford Steam Electric Station, Unit 3 (Waterford 3), 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. ML111930167), the licensee provided its response to this second set of questions (second response). Portions of the letter dated July 11,2011, contain sensitive unclassified non-safeguards information (security-related) and have been withheld from public disclosure. In response to an NRC staff request for additional information (RAI) dated November 23,2011 (ADAMS Accession No. ML113110674), the licensee, by letter dated January 5,2012 (ADAMS Accession No. ML120060156), provided additional information. 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) (ADAMS Accession No. ML020510635). 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 July 26, 2007 (ADAMS Accession No. ML072050003), 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.
Enclosure
-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; March 27, 2009) so no further actions were required on the part of current licensees.
3.0 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 the licensee's first response to determine if it had adequately addressed these questions.
3.1 Question 1: Availability and Capability of Equipment In its first response, the licensee 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 concludes that the licensee has adequately responded to Question 1.
3.2 Question 2: Guidance and Strategies Can Be Executed In its first response, the licensee 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 skills. Since the licensee 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 concludes that the licensee has adequately responded to Question 2.
4.0 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.
- 3
- 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 licensee's submittals to determine if it had adequately addressed these questions. This was accomplished by verifying that the submittals listed equipment, training, and offsite resources that were relied upon to make conclusions in the July 26, 2007, SE are commonly needed to implement the mitigating strategies.
4.1 Questions 1 and 2: Maintenance and Testing of Eguipment 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 and hoses receive maintenance and testing. In its second response, the licensee did not identify maintenance or testing of monitor nozzles, spray nozzles, or similar devices. In its RAI response, the license stated that it only procured monitor nozzles to support the mitigating strategies and that it was developing a preventative maintenance task for monitor nozzles using vendor recommendations. The NRC staff noted that, in its second response, the licensee did not identify any testing or inventory of its communications equipment. The licensee, in its RAI response, described the testing and inventory of its communications equipment. The NRC staff noted that the 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.
Based on the above, the NRC staff concludes that the licensee has provided the information requested by Questions 1 and 2.
-4 4.2 Question 3: Controls on Equipment Question 3 of the eO-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.5.b equipment will be available when needed. In its second response, the licensee identified the equipment included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity, location, and accessibility of equipment. The licensee also stated that 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.5.b equipment is inventoried in accordance with station procedures. The response specifically stated that the following items are included in the inventory: portable pump, hoses, spray nozzles, and connectors. In its RAI response, the licensee described how it ensures that a vehicle is available to move the portable pump and other B.5.b equipment. The NRC staff noted in the RAI that the second response did not clearly include all firefighter turnout gear, tools, and instruments needed to implement the mitigating strategies, and it did not specify a minimum inventory frequency for B.5.b equipment which would cover equipment not specifically listed. In response to an RAI about this issue, the licensee described its inventory of firefighter turnout gear and did not identify any additional tools or instruments. The licensee also identified other inventoried items in its second response that support the mitigating strategies.
Based on the above, the NRC staff concludes that the licensee has provided the information requested by Question 3.
4.3 Question 4: Configuration and Guidance Management Question 4 of the eO-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.5.b mitigating strategies. The licensee stated that the design change process requires a review of affected procedures.
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 stated that the mitigating strategies were developed by
- 5 walkdowns, engineering evaluations, and table top reviews, and they were similarly revalidated in2011.
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; fire brigade; and other personnel. In its RAI response, the licensee stated that heavy equipment training is provided to its maintenance personnel. The licensee also identified the frequency with which each type of training is provided and the methods for training evaluating.
Based on the above, the NRC staff concludes that the licensee has provided the information requested by Question 4.
4.4 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 and 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. 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 two condition reports documenting missing letters of agreement. However, the affected support organizations continued to acknowledge their role in responding to an emergency at Waterford 3. The licensee has taken corrective action to document when a support organization, such as the U.S. Department of Energy, does not provide a confirmation letter and why this is acceptable.
Based on the above, the NRC staff concludes that the licensee has provided the information requested by Question 5.
5.0 CONCLUSION
As described above, the NRC staff has 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 no further information or actions under the bulletin are needed.
- 2 If you have any questions, please contact me at 301-415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, IRA!
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMWaterford Resource RidsOgcRp Resource RidsRgn4MailCenter Resource BPurnell, NRR/DPR/PGCB ADAMS Accession No ML12172A268 *SE memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRRIDPR/PGCB/BC NRR/LPL4/BC NRR/LPL4/PM NAME NKalyanam JBurkhardt KMorgan Butler* MMarkley NKalyanam DATE 6/22112 6/21/12 6/18/12 6/26/12 6/26/12 OFFICIAL RECORD COpy