SBK-L-13157, 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

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

ML13247A178
Person / Time
Site:	Seabrook
Issue date:	08/28/2013
From:	Vehec T NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, SBK-L-13157
Download: ML13247A178 (10)

Text

NEXTera ENERGYP,0 August 28, 2013 SBK-L-13157 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, 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. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012

4. NextEra Energy Seabrook, LLC Initial 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-I 2-049), dated October 26, 2012

5. NextEra Energy Seabrook, LLC 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), dated February 26, 2013 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra Energy Seabrook). Reference 1 was immediately effective and directs NextEra Energy Seabrook to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-13157/Page 2 capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the NextEra Energy Seabrook initial status report regarding mitigation strategies. Reference 5 provided the NextEra Energy Seabrook overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. 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 enclosed report 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.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 91?., ,2013.

Sincerely Thomas Vehec Plant General Manager NextEra Energy Seabrook, LLC cc: NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratchmann, NRR/JLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB

U.S. Nuclear Regulatory Commission SBK-L-13157/Page 3 Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Enclosure to SBK-L-13157 NextEra Energy Seabrook, 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)

Enclosure NextEra Energy Seabrook, 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 Seabrook LLC (henceforth Seabrook) developed and submitted an Overall Integrated Plan (Reference 1) in response to NRC Order EA-12-049. The Integrated Plan describes Seabrook's proposed diverse and flexible coping strategies (FLEX). This status report 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, if any.

2 Milestone Accomplishments The following milestone has been completed since the submittal of the Overall Integrated Plan:

0 Submit first 6 month status report 3 Milestone Schedule Status The following provides an update to Attachment 2 of the Seabrook Overall Integrated Plan (Reference 1).

The table includes the current status of each item and whether the expected completion date has changed.

As noted in the original station submittal these dates are planning dates which are subject to change as design and implementation details are developed.

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

" Since submittal of the Overall Integrated Plan in February 2013, Seabrook has selected Westinghouse SHIELD low leakage RCP seals in all 4 RCPs as a backup strategy against significant RCS leakage to Containment. In June of 2013 a SHIELD seal removed from a reactor coolant pump at Beaver Valley failed to actuate as designed. The Westinghouse root cause evaluation determined that a complete seal re-design and follow-tip testing program was required to resolve the actuation failure problem. Seabrook is re-evaluating the SHIELD seal technology as a result of the test failures at Beaver Valley.

• RRC Operational has a revised target date of June 2015. This change reflects the Industry schedule for when the Regional Response centers will be in service for plants with Fall 2015 refuel outages.

• A new milestone has been added to conduct walkthroughs / demonstrations of portable equipment connection points.

Revised milestone target completion dates do not currently impact Seabrook's full compliance date.

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NextEra Energy Seabrook - First Six Month Status Report for Implementation of NRC Order EA-12-049 August 28, 2013 Target Revised Target Milestone Completion Activity Status Completion Date Date Submit Overall Integrated Implementation February 2013 Complete Plan N/A Submit 6 Month Status Report August 2013 Complete N/A Prepare engineering change packages for RCP low leakage seals and SEPS missile December 2013 Not started N/A barrier (if necessary)

Prepare bid for construction of SEPS missile February 2014 Not started N/A barrier (if necessary)

Submit 2 nd 6-month status report to NRC February 2014 Not started N/A Install RCP shutdown seals in two pumps in Re-evaluating April 2014 SHIELD seal N/A refueling outage #16 technology Submit 3 rd 6-month status report to NRC August 2014 Not started N/A Construct SEPS missile barrier (if December 2014 Not started N/A necessary)

Revise / develop procedures based upon approved strategies and engineering December 2014 Not started N/A implementation packages Develop required training for station staff based upon draft procedure changes and December 2014 Not started N/A engineering change packages.

Procure SEPS / portable equipment December 2014 Not started N/A refueling trailer Submit 4 th 6-month status report to NRC February 2015 Not started N/A Develop PMs for refueling trailer March 2015 *Not started N/A Store refueling trailer in Service Water June 2015 Not started N/A Pumphouse Fall 2015 implementation Sites - RRC July 2015 Not started June 2015 Operational 5 th and final 6-month status report to NRC August 2015 Not started N/A Conduct walkthroughs / demonstrations of August 2015 New N/A portable equipment connection points Implement training for station staff September 2015 Not started N/A Page 2 of 6

NextEra Energy Seabrook - First Six Month Status Report for Implementation of NRC Order EA-12-049 August 28, 2013 Install remaining two RCP shutdown seals October 2015 Not started N/A in Refueling Outage # 17 Final implementation - Order full November 2015 Not started compliance letter to NRC 4 Changes to Compliance Method Seabrook has identified no changes to the Order compliance method described in the Overall Integrated Plan submitted in February 2013.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation Seabrook currently expects to comply with the order implementation date and no relief/relaxation is required at this time. However, at the time of this submittal Seabrook has not received any questions, comments, or Requests for Additional Information letters from the NRC staff regarding the Overall Integrated Plan submitted in February 2013. Consequently, Seabrook is proceeding 'at risk' towards implementation of the strategies as described. Should the NRC staff require significant changes to the strategies defined in the Integrated Plan, it may be necessary for Seabrook to request relief/relaxation at some time in the future.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following Table provides a summary of the Open Items documented in the Overall Integrated Plan:

Overall Integrated Plan Open Item (Pending Actions) Status 1 Revise ECA-0.0 to include a step to determine if an Not extended loss of offsite power event is in progress. This started determination will delineate future procedural strategies and transitions.

2 Revise ECA-0.0, Attachment 'A' to include a Table of loads for an extended loss of offsite power event or create a new Attachment with this information.

A seismic evaluation will be conducted on the connections that penetrate the upper half of the CST to determine if Seabrook can take credit for the entire tank volune for Phase 1 & 2 event coping.

4 Revise ECA-0.0 or ES-0.1 to add a step to manually Not started shutdown the motor-driven EFW pump if the TDEFW pump is running satisfactorily.

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NextEra Energy Seabrook - First Six Month Status Report for Implementation of NRC Order EA-12-049 August 28, 2013 Add an Attachment to ES-0.2, ES-0.3 and ES-0.4 that provides a Table of electrical loads for responding to an extended loss of offsite power event.

6 Develop a SEPS genset refuieling strategy from 1) an offsite supplier outside a 25 mile radius from the station Not started (primary strategy), and 2) the EDG fuel oil storage tanks using a refueling trailer stored in the SW Pumphouse (backup strategy).

Revise ES-0.2, ES-0.3, and ES-0.4 to include a step for implementation of a SEPS genset refueling strategy.

8 Develop~a FSG for refueling SEPS from the EDG fuel oil storage tanks using a portable refueling trailer. Utilize the Not started information contained in existing procedure OS 1061.02,

'Receipt of SEPS Fuel Oil', for development of the FSG.

9 Revise ES-0.2, ES-0.3, and ES-0.4 to include direction for connecting the backup diesel-driven air compressor to the Service Air system to restore Instrument Air system pressure.

10 Develop required Preventive Maintenance actions and Surveillance test procedures for the refueling trailer to be Not started procured and stored in the Service Water Pumphouse.

11 Revise OS1246.01, 'Loss of Offsite Power - Plant Shutdown', to address a reactor de-fueled condition Not started

('Mode 7'). In that case restoration of spent fuel pool cooling is paramount as opposed to restoration of RHR cooling.

12 Conduct an Engineering Evaluation to determine if the existing hurricane enclosures for the SEPS gensets provide adequate missile protection. If protection is not adequate, develop a design change (EC) to add missile protection for the SEPS gensets.

13 Evaluate the 'seismic robustness' of SEPS and determine if enhancements are needed with respect to the new Ground Motion Response Spectrum (GMRS) data for the site. This data will not be available until the seismic hazard re-evaluation is conducted in accordance Recommendation 2.1 of the RFI letter.

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NextEra Energy Seabrook - First Six Month Status Report for Implementation of NRC Order EA-12-049 August 28, 2013 15 Formalize the Engineering assessment of ELAP load capacity for a single SEPS genset and modify procedural In progress guidance in the applicable EOPs and AOPs, as necessary.

16 Evaluate the impact of missile protection barriers that may be installed to protect the SEPS gensets on the Not started capability to implement the snow removal plan and revise the plan as necessary.

17 Determine if a quantity of diesel fuel will be provided Not started from the Regional Response Centers along with requested Phase 3 portable equipment. If not, establish a contract with a fuel supplier outside a 25 mile radius from the plant to provide fuel within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of a BDBEE.

18 Develop a FSG for staging and deployment of Phase 3 equipment from the RRCs into the Protected Area. Not started 19 Develop a FSG for connecting the 2MW generators from the RRC to 4.16 KV Emergency Busses E5 and E6. Not started 20 Develop a FSG for refueling the RRC generators or incorporate this action into the SEPS refueling FSG. Not started

21. Implement low leakage RCP seals on all four RCPs as a backup strategy to minimize RCS leakage into asrnot previousyin thi repo r Containment. Seabrook is re-evaluating the SHIELD seal technology as a result of the test failures at Beaver Valley.

22 Based on PWROG guidance, determine if new FSGs are required that incorporate the existing guidance provided Not started in SAG-I, 'Inject to the SGs', and SAG-3, 'Inject to the RCS' or whether transition points to these two SAMGs should be added to the applicable EOPs.

7 Potential Draft Safety Evaluation Impacts Draft Safety Evaluation Open Item Status A draft Safety Evaluation has not yet been received. N/A Consequently, 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.

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NextEra Energy Seabrook - First Six Month Status Report for Implementation of NRC Order EA-12-049 August 28, 2013

1. NextEra Energy Seabrook LLC - SBK-L-13038 - 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)," dated February 26, 2013.

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.

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