NG-13-0328, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)

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First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)
ML13242A007
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 08/27/2013
From: Richard Anderson
NextEra Energy Duane Arnold
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
EA-12-049, NG-13-0328
Download: ML13242A007 (8)


Text

NEXTera ENERGY

,_ý;ýA RNOLD August 27, 2013 NG-13-0328 10 CFR 2.202 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 NextEra Energy Duane Arnold Energy Center, LLC's First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1) Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12056A045)
2) Letter, R. Anderson (NextEra Ener-gy Duane Arnold, LLC) to U. S. NRC, "NextEra Energy Duane Arnold, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," NG-13-0084, dated February 28, 2013 (ML13063A148)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1, an immediately effective Order to all licensees including NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold). In Reference 2, NextEra Energy Duane Arnold submitted an Overall Integrated Plan for the implementation of this Order. The Order required Licensee's to provide periodic status reports for the Overall Integrated Plan. The purpose of this letter is to provide the first six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosure to this letter provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-1 3-0328 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 27, 2013 Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region III Resident Inspector, USNRC, Duane Arnold Energy Center Project Manager, USNRC, Duane Arnold Energy Center

Attachment to NG-13-0328 NextEra Energy Duane Arnold, LLC's First Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 5 pages follow

NextEra Energy Duane Arnold, LLC's first Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

1. Introduction NextEra Energy Duane Arnold, LLC (hereafter, NextEra Energy Duane Arnold) developed an Overall Integrated Plan (Reference 1), documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.
2. Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of July 31, 2013.
  • Submit 6 month status report
3. Milestone Schedule Status The following provides an update to Attachment 4 of the Overall Integrated Plan (Reference 1). It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The following milestone target completion dates have been adjusted or added:

  • Complete Regional Response Center Arrangements has a revised target date of December 2015. This change reflects the industry schedule for when "Playbooks" for plants with fall 2016 refuel outages are schedule for completion.
  • Based on industry feedback, a new milestone was added to reflect plans to validate that time sensitive actions can be completed consistent with the time limitations of the strategies.

The revised milestone target completion dates do not impact the order implementation date.

Target ARevised Milestone Completion Activity Target Date Status Completion Date Submit Overall Integrated Complete N/A Implementation Plan February 2013 Submit 6 Month Status Report August 2013 Complete N/A Complete Revision to Emergency Started N/A Operating Procedures to Extend December 2013 1 1 Page 1 of 5

Revised Target Activity Target Milestone Completion Status Completion Date Date Operation of Steam Driven Pumps Submit 6 Month Status Report February 2014 Not Started N/A Complete Regional Response Center Started December Arrangements August 2014 2015 Submit 6 Month Status Report August 2014 Not Started N/A First Refueling Outage of RFO 24 Not Started N/A Implementation Period (Fall 2014)

Complete Site Specific Analysis of Started N/A NEDC-33771P Rev. 1 January 2015 Submit 6 Month Status Report February 2015 Not Started N/A FLEX Storage Buildings Completed March 2015 Started N/A Identified Portable Equipment Stored on Started N/A Site May 2015 Submit 6 Month Status Report August 2015 Not Started N/A Issue Modification Packages December 2015 Started N/A Submit 6 Month Status Report February 2016 Not Started N/A Complete Staffing Study for Flex Not Started N/A Implementation May 2016 Validate that time sensitive actions can Not Started August 2016 be completed consistent with the Flex Strategies New Complete Implementing Procedure Started N/A Development and Validation August 2016 Submit 6 Month Status Report August 2016 Not Started N/A Complete Required Training September 2016 Not Started N/A Final Implementation Outage for RFO 25 Not Started N/A Modifications (Fall 2016)

Submit Completion Report December 2016 Not Started N/A

4. Changes to Compliance Method The NextEra Energy Duane Arnold integrated plan (Reference 1) indicated compliance with the subject order would include implementation of NRC EA-12-050 dated March 12, 2012, "Issuance of Order to Modify License with Regard to Reliable Hardened Containment Vents." Subsequent to the submittal of the integrated plan, the NRC rescinded Order EA-1 2-050 and issued Order EA-1 3-109 "Issuance of Order to Modify Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (Reference 3). NextEra Energy Duane Arnold will implement requirements of Phase 1 of Order EA-13-109 instead of Order EA-12-050.

Phase 1 of Order EA-13-109 currently requires implementation in 2016 and thus, no change in schedule for compliance is currently contemplated.

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5. Need for Relief/Relaxation and Basis for the Relief/Relaxation NextEra Energy Duane Arnold expects to comply with the order implementation date and no relief/relaxation is required at this time.
6. Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Draft Safety Evaluation (SE) and the status of each item.

Overall Integrated Plan Open Item (Pending Status Actions) 1 Seismic re-evaluations pursuant to the 10 CFR Started 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action process and addressed.

2 Flood re-evaluations pursuant to the 10 CFR Started 50.54(f) letter of March 12, 2012 are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action process and addressed.

3 Implement revisions to emergency operating Started procedures (EOP's) identified by the BWROG to extend operation of steam driven pumps for core cooling during ELAP.

4 Validate implementing procedures can be Not Started

.performed in a timely manner.

5 Final plant specific analysis for an ELAP will be Started performed with equivalent acceptance criteria with the exception of Condensate Storage Tank (CST) inventory and suppression pool level which will be altered in recognition of the external hazards and revised duration of the mitigating strategies.

6 Phase 3 activities will ensure adequate inventory of Not started water can be provided directly from the Cedar River or other sources independent of the normal River Water Supply pumps.

7 Implement new and revised plant procedures for Started FLEX Strategies.

8 Implement administrative controls for the FLEX Started Program.

9 Procure FLEX portable equipment. Started 10 Establish preventive maintenance and testing of Started FLEX portable equipment.

11 Revise UFSAR and TRM as needed to reflect FLEX Not started program.

12 Complete training of applicable personnel. Not started Page 3 of 5

Overall Integrated Plan Open Item (Pending Status Actions) 13 Establish "Playbook" for Regional Response Center Generic work on "Playbook" interface with the NextEra Energy Duane Arnold. development is in progress. Site specific development is not scheduled until 2015 due to industry prioritization by plant outage schedules.

14 Review generic BWROG analysis of FLEX Started implementation and perform a detailed review of suppression pool temperature to support FLEX strategies.

15 Perform analysis of final load shedding strategy for Started. The strategy has been essential station batteries and implement in plant developed and analysis of the effect procedures. on likely battery survival time has been initiated. Procedure improvements to incorporate the strategy have been initiated.

16 Modify the plant to establish a flood staging area for Started portable equipment.

17 Evaluate deployment routes for portable equipment. Not started 18 Modify the plant to facilitate connection of portable Started power supplies. This will include connection points for a 480 volt generator to essential battery chargers and 480 volt distribution panel 1 B03.

Quick connection points will be established for 120 volt AC power to instrument power supplies.

19 Modify the plant to add suction and injection Started connection points for portable pump. The portable pump suction will allow access to the circulating water pit (Pump House) from a protected area (Turbine Building) during a design bases flood. The injection point will provide a redundant connection point for RPV makeup located in a protected area (Reactor Building).

20 Construct two FLEX portable equipment storage Not Started buildings. The buildings will be separated to minimize the potential for a single tornado path to interact with both buildings.

21 Phase 3 activities will ensure essential bus can be Started re-powered using a portable 4160 V Generator.

This will include a modification that establishes a transfer panel (disconnect switch) installed in the turbine building that provides a location for connection during a design bases flood and procedures for mobilization.

22 Procedures will provide for opening containment Procedures currently exist but will be vent valves using portable pneumatic supply. reviewed in association with modification development under Order EA-1 3-109.

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23 Modify the plant to establish a manual vent Started capability for the reactor building near the spent fuel pool.

24 Update analysis of room heat-up during an ELAP. Not started 25 Screen BWROG RCIC Durability Study for Started extending RCIC operation during an ELAP and make applicable improvements.

26 Establish methods to recharge communications Complete equipment.

27 Establish methods to re-fuel portable equipment. Started 28 Review generic BWROG analysis of FLEX Started implementation and perform a detailed review of limitations on SRV operation to support FLEX strategies.

29 If FLEX transport paths are over previously un- Not started excavated ground, review path for potential soil liquefaction during a seismic event.

Draft Safety Evaluation Open Item Status Draft Safety Evaluation has not been received yet. N/A

7. Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.
8. References The following references support the updates to the Overall Integrated Plan described in this enclosure.
1. Letter, R. Anderson (NextEra Energy Duane Arnold, LLC) to U. S. NRC, "NextEra Energy Duane Arnold, LLC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," NG-13-0084, dated February 28, 2013 (ML13063A148)
2. NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.
3. NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013.

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