SBK-L-14041, Second Six-Month Status Report in Response to the 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)

Second Six-Month Status Report in Response to the 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)

ML14064A188
Person / Time
Site:	Seabrook
Issue date:	02/27/2014
From:	Walsh K NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, SBK-L-14041
Download: ML14064A188 (11)

Text

NExTera ENERGY

',dýý =ABOOK February 27, 2014 SBK-L-14041 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, LLC's Second Six-Month Status Report in Response to the 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 (ML12054A736)

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 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12242A378)

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- 12-049), dated October 26, 2012 (ML12311A013)

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 (ML13063A438)

6. NextEra Energy Seabrook, LLC 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 049), dated August 28, 2013 (ML13247A178)

• 1-7/s NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-14041/Page 2 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 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. Reference 6 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 second 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 February $2*¶.11 ,2014.

Sincerely, Kevin T. Walsh Site Vice President NextEra Energy Seabrook, LLC

U.S. Nuclear Regulatory Commission SBK-L-14041/Page 3 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 Mr. Perry Plummer, 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-14041 NextEra Energy Seabrook, LLC's Second 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)

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Enclosure NextEra Energy Seabrook, LLC's Second 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 (NextEra Energy Seabrook) developed and submitted an Overall Integrated Plan (OIP) (Reference 1) in response to NRC Order EA-12-049. The OIP describes Seabrook's proposed diverse and flexible coping strategies (FLEX). This status report provides an update of milestone accomplishments since submittal of the OIP, including any changes to the compliance method, schedule, or need for relief/relaxation, if any.

2 Milestone Accomplishments With the submittal of this report the following milestones have been completed since the submittal of the OIP:

" Submit first 6 month status report

" Submit second 6 month status report 3 Milestone Schedule Status The following table provides an update to Attachment 2 of the Seabrook OIP (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:

• In the submittal of the OIP in February 2013, Seabrook included Westinghouse SHIELD low leakage RCP seals in all 4 RCPs as a backup strategy against significant RCS leakage to Containment. Seabrook continues to monitor the progress of the SHIELD seal technology as a result of the test failures at Beaver Valley. The SHIELD seals will not be installed at Seabrook Station in April 2014 during refueling outage 16, as the low leakage seals are not required for the backup strategy.

" The start of installation of the Supplemental Emergency Power System (SEPS) missile shield has been extended to March 2015.

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

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Target Activity Revised Milestone Completion Date Status Target Completion Date Submit Overall Integrated February 2013 Complete Implementation Plan Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Conceptual December 2014 Prepare engineering change packages for December 2013 missile for RCP low SEPS missile barrier and RCP low barrier design leakage seals (if leakage seals (if necessary) completed necessary)

Prepare bid for construction of SEPS In progress missile barrier February 2014 March2014 Re-evaluating April 2014 SHIELD seal TBD Install RCP shutdown seals in two pumps technology in refueling outage # 16 Submit 3rd 6-month status report to NRC August 2014 Not started N/A 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 4t" 6-month status report to NRC February 2015 Not started N/A Construct SEPS missile barrier March 2015 Not started N/A Develop PMs for refueling trailer March 2015 Not started N/A Page 3 of 8

Milestone Target Activity Revised Completion Date Status Target Completion Date Store refueling trailer in Service Water June 2015 Working N/A Pump house Fall 2015 implementation Sites - RRC June 2015 Not started N/A Operational 5th and final 6-month status report to AustNot started N/A NRC Conduct walkthroughs / demonstrations of portable equipment connection points Implement training for station staff September 2015 Not started N/A Install two RCP shutdown seals in October 2015 Not started N/A Refueling Outage #17 Final implementation - Order full November 2015 Not started N/A compliance letter to NRC 4 Changes to Compliance Method NextEra Energy Seabrook has received feedback in the form of NRC audit questions and subsequent teleconferences with NRC Staff reviewers. The NRC's Interim Safety Evaluation (ISE) was received just prior to the due date of this letter. Changes to the Order compliance method described in the OIP submitted in February 2013 that are required to address open items and confirmatory items in the ISE, will be submitted by separate transmittal or no later than the next 6 month status report.

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. Should the NRC staff ISE require significant changes to the strategies defined in the OIP, it may be necessary for NextEra Energy Seabrook to request relief/relaxation at some time in the future.

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6 Open Items from Overall Integrated Plan and NRC Interim Staff Evaluation /TER The following Table provides a summary of the Pending Items documented in the Overall Integrated Plan:

Overall Integrated Plan Pending Actions Status Revise ECA-0.0 to include a step to determine if an Not started extended loss of offsite power event is in progress.

This determination will delineate future procedural strategies and transitions.

Revise ECA-0.0, Attachment 'A' to include a Table Not started 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 NextEra Energy Seabrook can take credit for the entire tank volume 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.

Add an Attachment to ES-0.2, ES-0.3 and ES-0.4 Not started that provides a Table of electrical loads for responding to an extended loss of offsite power event.

6 Develop a Supplemental Emergency Power System In Progress (SEPS) generator set (genset) refueling strategy from 1) an offsite supplier outside a 25 mile radius from the station (primary strategy), and 2) the Emergency Diesel Generator (EDG) fuel oil storage tanks using a refueling trailer stored in the Service Water Pumphouse (backup strategy). This strategy will include provisions for refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event that only a single SEPS is functional.

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Overall Integrated Plan Pending Actions Status Revise ES-0.2, ES-0.3, and ES-0.4 to include a step Not started for implementation of a SEPS genset refueling strategy.

8 Develop a Flexible Strategy Guideline (FSG) for Not started refueling SEPS from the EDG fuel oil storage tanks using a portable refueling trailer. Utilize the information contained in existing procedure OS 1061.02, 'Receipt of SEPS Fuel Oil', for development of the FSG.

Revise ES-0.2, ES-0.3, and ES-0.4 to include Not started 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 Not started and surveillance test procedures for the refueling trailer that will be 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

('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 In progress 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 In progress 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 10 CFR 50.54(f) RFI letter.

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Overall Integrated Plan Pending Actions Status 15 Formalize the engineering assessment of ELAP load In progress capacity for a single SEPS genset and modify procedural guidance in the applicable EOPs and AOPs, as necessary.

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

17 Determine if a quantity of diesel fuel will be provided from the Regional Response Centers (RRCs) 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 Not started 3 equipment from the RRCs into the protected area.

19 Develop a FSG for connecting the 2MW generators Not started from the RRC to 4.16 KV Emergency Busses E5 and E6.

20 Develop a FSG for refueling the RRC generators or incorporate this action into the SEPS refueling FSG.

21 Implement low leakage RCP seals on all four RCPs As noted previously in this report as a backup strategy to minimize RCS leakage into Seabrook is re-evaluating the containment.

SHIELD seal technology as a result of the test failures at Beaver Valley.

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

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Overall Integrated Plan Pending Actions Status 23 Develop a method for obtaining local readings for Not Started the 12 critical parameters identified on page 12 of 60 of the OIP and include in site procedures as appropriate.

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.

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 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.

3. NextEra Energy Seabrook, LLC 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), dated August 28, 2013 Page 8 of 8