ML12193A499
| ML12193A499 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/17/2012 |
| From: | Jacqueline Thompson Plant Licensing Branch II |
| To: | Morris J Duke Energy Carolinas |
| Sreenivas, V | |
| References | |
| TAC ME6414, TAC ME6415, BL-11-001 | |
| Download: ML12193A499 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 17, 2012 Mr. J. R. Morris Site Vice President Catawba Nuclear Station Duke Energy Carolinas, LLC 4800 Concord Road York, SC 29745
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2 - CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. ME6414 AND ME6415)
Dear Mr. Morris:
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).
Catawba Nuclear Station, Units 1 and 2, provided its responses to the bulletin by letters dated June 8 and July 11, 2011 (ADAMS Accession Nos. ML11165A008 and ML11195A069, respectively). By letter dated December 21, 2011 (ADAMS Accession No. ML11335A054), 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 January 19, 2012 (ADAMS Accession No. ML12023A075).
The NRC staff has reviewed the information submitted by Catawba Nuclear Station, Units 1 and 2, 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. No further information or actions under the bulletin are requested.
Sincerely,
./7..-J'A-..V ~ f.r n Thompson, Project Manager lant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414
Enclosure:
Summary of NRC Bulletin 2011-01 Response Review cc wI encl: Distribution via Listserv
SUMMARY
OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 and 50-414 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 8, 2011 (ADAMS Accession No. ML11165A008), Catawba Nuclear Station, Units 1 and 2 (Catawba), 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. ML11195A069), Catawba provided its response to this second set of questions (second response). By letter dated December 21, 2011 (ADAMS Accession No. ML11335A054), the NRC sent a request for additional information (RAI) on the second response. Catawba responded to the RAI by letter dated January 19, 2012 (ADAMS Accession No. ML12023A075). As summarized below, the NRC staff has verified that Catawba 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" (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 August 16, 2007 (ADAMS Accession No. ML072270076), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by Catawba 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 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 Catawba'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, Catawba 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 Catawba has adequately responded to Question 1.
2.2 Question 2: Guidance and Strategies Can Be Executed In its first response, Catawba 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 Catawba 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 Catawba has adequately responded to Question 2.
3.0 60-DA Y 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 Catawba'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 which were relied upon to make conclusions in the August 16, 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, Catawba listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, Catawba described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that Catawba 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, Catawba stated that the portable pump, portable power supply, hoses, and communications equipment receive maintenance or testing.
Catawba also stated that during inventory it verifies that its master stream spray monitor and other firefighting equipment are in usable condition. Catawba clarified the frequency with which it tests communications equipment in its RAI response. The NRC staff noted that the fuel level for the portable pump is verified during maintenance. Catawba also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that Catawba described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. Catawba 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 Catawba 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 Catawba described its process for ensuring that B.S.b equipment will be available when needed. In its second response, Catawba 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 shelflives; and controls on storage locations. Catawba states that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable.
- 4 The NRC staff verified that Catawba inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, Catawba stated that procured non-permanently installed B.5.b equipment is inventoried at least annually in accordance with station procedures. The second response specifically states that the following items are included in the inventory: portable pump; hoses; communications equipment; master stream spray monitor; connectors; and firefighter turnout gear. In its RAI response, Catawba described how it ensures the availability of a vehicle to move the portable pump and other B.5.b equipment. Catawba also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that Catawba 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 Catawba 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, Catawba stated that plant configuration changes are procedurally required to be evaluated against the licensing basis, which includes the B.5.b mitigating strategies.
Catawba states that the design change process requires a review of affected procedures which will ensure that the B.5.b mitigating strategies remain viable.
The NRC staff verified that Catawba described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, Catawba identified testing in response to Question 2 that demonstrated the ability to execute some strategies. Catawba also states that "initially, mitigating strategies were validated by walk downs, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011.
The NRC staff verified that Catawba described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, Catawba identified the training provided to its operations personnel; emergency response organization, including key decision makers; fire brigade; security personnel; and other personnel. Catawba 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 Catawba has provided the information requested by Question 4.
3.4 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 Catawba 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 Catawba provided in its second response with the information
- 5 relied upon to make conclusions in the SE. Catawba stated that it maintains agreement letters with these offsite organizations, which are reviewed monthly. and that these agreements were current at the time of its second response. Catawba also described the training and site familiarization it provides to these offsite organizations. Catawba stated that it reviewed its corrective action program back to 2008 and found two agreements which were not renewed on time. These agreements were renewed in 2010 to correct the issue, and no period of lapsed agreement occurred.
Based upon the information above, the NRC staff finds that Catawba has provided the information requested by Question 5.
4.0 CONCLUSION
As described above. the NRC staff has verified that Catawba has provided the information requested in Bulletin 2011-01. Specifically. Catawba responded to each of the questions in the bulletin as requested. The NRC staff concludes that Catawba has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.
ML11165A008 and ML11195A069, respectively). By letter dated December 21, 2011 (ADAMS Accession No. ML11335A054), 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 January 19, 2012 (ADAMS Accession No. ML12023A075).
The NRC staff has reviewed the information submitted by Catawba Nuclear Station, Units 1 and 2, 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. No further information or actions under the bulletin are requested.
Sincerely, IRA by John P. Boska fori Jon Thompson, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-413 and 50-414
Enclosure:
Summary of NRC Bulletin 2011-01 Response Review cc wI encl: Distribution via Listserv DISTRIBUTION:
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- By Memo Date OFFICE NRRlLPL2-1/PM NRRlLPL2-1/PM NRRlLPL2-1/LA DPRlPGCB/BC(A)*
NRRlLPL2-1/BC NRRlLPL2-1/PM NAME VSreenivas JThompson VSreenivas for SFigueroa KMogan-Butier NSalgado JThompson JBoska for DATE 07/11112 07/11/12 07/12/12 06/28/12 07/12/12 07/17/12