NG-14-0061, NextEra Energy Duane Arnold Energy Center, Llc'S 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 (Orde

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NextEra Energy Duane Arnold Energy Center, Llc'S 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
ML14063A065
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 02/24/2014
From: Richard Anderson
NextEra Energy Duane Arnold
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NG-14-0061
Download: ML14063A065 (9)


Text

NExTera" ARNOLD February 24, 2014 NG-14-0061 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 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 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12056A045)
2) 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)
3) Letter, R. Anderson (NextEra Energy Duane Arnold, LLC) to U. S. NRC, "NextEra Energy Duane Arnold, 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)," NG-13-0328, dated August 27, 2013 (ML13242A007)

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. In Reference 3, NextEra NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-14-0061 Page 2 of 2 Energy Duane Arnold provided 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 purpose of this letter is to provide the next 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.

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

Executed on February 24, 2014 Rc~hard L. Andersko 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-14-0061 NextEra Energy Duane Arnold, LLC's 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 6 pages follow

NextEra Energy Duane Arnold, LLC's 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 2), documenting the diverse and flexible strategies (FLEX), in response to Reference 1. 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 submittal of the first six month update (Reference 3), and are current as of January 31, 2014.
  • Submit 6 month status report
  • Complete revision to Emergency Operating Procedures to extend operation of steam driven pumps
3. Milestone Schedule Status The following provides an update to Attachment 4 of the Overall Integrated Plan (Reference 2) as modified by Reference 3. 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 revised milestone target completion dates do not impact the order implementation date.

Target Revised Milestone Completion Activity Target Date Status Completion Date_ _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 Completed Operating Procedures to Extend January 2014 N/A Operation of Steam Driven Pumps December 2013 Submit 6 Month Status Report February 2014 Completed N/A Complete Regional Response Center Started N/A Arrangements December 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)

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Target Revised Milestone Completion Activity Target M tC e Status Completion Date Date 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 N/A be completed consistent with the Flex Strategies August 2016 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 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 2) indicated compliance with the subject order would include implementation of Order EA-1 2-050 dated March 12, 2012, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents." Subsequent to the submittal of the integrated plan, Order EA-12-050 was rescinded by Order EA-13-109 "Order Modifying Licenses With Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (Reference 4). 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.

On page 16 of the integrated plan, NextEra Energy Duane Arnold indicated a modification to support Phase 2 Core Cooling would include installing a branch connection on existing piping GBC-005. Detailed design of this modification has concluded a preferred connection location on the RHR piping at GBB-004. This does not change the function of the alternate injection path for core cooling.

Action 18 of the integrated plan included modifying the plant to provide an electrical connection point for a portable generator to the 480 volt distribution panel 1 B003.

Detailed design of this modification concluded the preferred connection to power this Page 2 of 6

electrical equipment was via 1B032. This does not change the function of providing electrical power to the same plant equipment.

Action 21 of the integrated plan indicated a modification would install a transfer panel for connection of a 4160 volt generator in Phase 3. Detailed design work has concluded a more flexible option would be the use of a portable device that can be inserted into an existing breaker to allow ready connection of the portable generator to station 4160 Volt distribution. This does not change the function of providing a connection point for portable 4160 volt generation in Phase 3. of the integrated plan provides a list of required instruments. Reactor water level indication was inadvertently omitted from this list and is a required indication for the strategies.

NextEra Energy Duane Arnold will incorporate the supplemental guidance provided in the NEI position paper entitled "Shutdown / Refueling Modes" to enhance the shutdown risk process and procedures.

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 Interim Staff Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan or the Interim Staff 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 Completed 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 Page 3 of 6

Overall Integrated Plan Open Item (Pending Status Actions) 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. Started 13 Establish "Playbook" for Regional Response Center Not started interface with the NextEra Energy Duane Arnold.

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.

essential station batteries and implement in plant procedures.

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. Detail design has concluded power supplies. This will include connection points the preferred connection point is at for a 480 volt generator to essential battery 1 B032.

chargers and 480 volt distribution panel 1B03.

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 Page 4 of 6

Overall Integrated Plan Open Item (Pending Status Actions) interact with both buildings.

21 Phase 3 activities will ensure essential bus can be Started. Detail design has concluded re-powered using a portable 4160 V Generator. a portable device that can be inserted This will include a modification that establishes a into an existing breaker to allow ready transfer panel (disconnect switch) installed in the connection of the portable generator turbine building that provides a location for to station 4160 Volt distribution connection during a design bases flood and provides a more flexible option.

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.

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 Completed 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- Completed. Transport paths will be excavated ground, review path for potential soil improved to ensure availability.

liquefaction during a seismic event.

Interim Staff Evaluation Open and Confirmatory Status Items Interim Staff Evaluation has not been received N/A

7. Potential Interim Staff Evaluation Impacts There are no potential impacts to the Interim Staff Evaluation identified at this time.
8. References
1) Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 (ML12056A045)
2) 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 Page 5 of 6

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," NG-1 3-0084, dated February 28, 2013 (ML13063A148)

3) Letter, R. Anderson (NextEra Energy Duane Arnold, LLC) to U. S. NRC, "NextEra Energy Duane Arnold, 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)," NG-1 3-0328, dated August 27, 2013 (ML13242A007)
4) NRC Order EA-13-109, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013. (ML13143A321)

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