ML12188A480
| ML12188A480 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 07/12/2012 |
| From: | Billoch-Colon A Plant Licensing Branch II |
| To: | William Gideon Carolina Power & Light Co |
| Billoch-Colon, A T | |
| References | |
| TAC ME6476, BL-11-001 | |
| Download: ML12188A480 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 12, 2012 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NO. ME6476)
Dear Mr. Gideon:
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 (ADAMS Accession Nos. ML11165A094 and ML11195A210, respectively), as supplemented by letter dated January 18, 2012 (ADAMS Accession No. ML12032A154), Carolina Power and Light (the licensee) doing business as Progress Energy Carolinas, Inc., provided its responses to the bulletin for H.B. Robinson Steam Electric Plant, Unit 2. Portions of the letters dated July 11, 2011, and January 3, 2012, contain sensitive unclassified non-safeguards information and, accordingly, those portions have been withheld from public disclosure.
The NRC has reviewed the information submitted by the licensee and concludes that the 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. No further information or actions under the bulletin are requested.
- w. Gideon -2 Should you have any questions regarding this matter, please call me at (301) 415-3302.
Sincerely, Araceli T. Billoch Colon, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
NRC BL 2011-01 Response Summary cc w/enclosure: Distribution via ListServ
SUMMARY
OF NRC BULLETIN 2011-01, "MITIGATING STRATEGIES" RESPONSE REVIEW H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NO. 50-261 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 (ADAMS Accession Nos. ML11165A094 and ML11195A210, respectively), as supplemented by letter dated January 18, 2012 (ADAMS Accession No. ML12032A154), Carolina Power and Light (the licensee) doing business as Progress Energy Carolinas, Inc., provided its responses to the bulletin for H.B. Robinson Steam Electric Plant, Unit 2. Portions of the letters dated July 11, 2011, and January 18, 2012, contain sensitive unclassified non-safeguards information and, accordingly, those portions have been withheld from public disclosure. As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin.
1.0 INTRODUCTION
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 July 26, 2007 (ADAMS Accession No. ML072050064), the NRC staff issued its safety evaluation (SE) to document the final disposition of information submitted by HBRSEP 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, 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) so no further actions were required on the part of current licensees.
Enclosure
-2 2.0 THIRTY-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 the issuance of 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.
2.1 Question 1: Availability and Capability of Eguipment 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 finds that the licensee has adequately responded to Question 1.
2.2 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 50.54(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staffs skills. Since the licensee has considered its current facility configuration, staffing levels, and staffs skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that the licensee has adequately responded to Question 2.
3.0 SIXTY-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.
-3 S. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed the licensee's submittals to determine if the questions were addressed adequately. 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 or are commonly needed to implement the mitigating strategies.
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 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.54(hh)(2) mitigating strategies that receive 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 the equipment that typically requires maintenance or testing that 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, hoses, and communications equipment receive maintenance or testing. The NRC staff noted that the fuel level for the B.S.b portable pump is verified during maintenance.
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 in HBRSEP 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 upon the information above, the NRC staff finds that the licensee 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 the licensee described the process for ensuring that B.S.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. The items verified include proper quantity, location, condition, and accessibility of equipment and controls on storage locations. The licensee 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 the licensee inventoried equipment in HBRSEP that was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In
-4 its second response, the licensee stated that procured nonpermanently installed B.5.b equipment is inventoried at least annually in accordance with HBRSEP procedures. The second response specifically states that the following items are included in the inventory:
portable power supplies; hoses; communications equipment; spray nozzles; connectors; and firefighter turnout gear. The licensee described how it ensures that a vehicle will be available to move the portable pump or other B.5.b equipment if needed. The licensee also described its inventory of nitrogen gas bottles and regulators. The licensee also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that the licensee 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 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 design changes are reviewed against 10 CFR 50.59, "Changes, tests, and experiments," and this review includes changes that impact the mitigating strategies. The licensee stated that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.5.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 stated that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were revalidated 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, including 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.
Based upon the information above, the NRC staff finds that the licensee 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.
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
-5 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 memorandum of understanding 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. 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 one issue involving lapsed agreements related to offsite support for B.5.b events. This issue has been resolved.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 5.
4.0 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 for HBRSEP and no further information or actions under the bulletin are needed.
C. Burton -2 Should you have any questions regarding this matter, please call me at (301) 415-3302.
Sincerely, IRA!
Araceli T. Billoch Col6n, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
NRC BL 2011-01 Response Summary cc w/enclosure: Distribution via ListServ DISTRIBUTION:
PUBLIC LPL2-2 Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl2-2 Resource RidsNrrPMRobinson Resource RidsNrrLABClayton Resource RidsNrrDprPgcb Resource RidsOgcRp Resource RidsRgn2MailCenter Resource BPurnell, NRR/DPR/PGCB FleE ADAMS Accession No'..
ME ML12188A480 LPL2-2/PM ABiliochCol6n LPL2-2/LA BClayton DPR/PGCB/BC(A)
KMorgan-Butfer LPL2-2/BC DBroaddus (EBrown for)
LPL2-2/PM ABiliochCol6n II DATE 07/05/12 07/09/12 06/28/12 07/12/12 07/12/12 OFFICIAL RECORD COpy