ML16193A383

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Relaxation of the Schedule Requirements for Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
ML16193A383
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 07/25/2016
From: Bill Dean
Office of Nuclear Reactor Regulation
To: Boles B
FirstEnergy Nuclear Operating Co
Hughey J, NRR/JLD, 301- 415-3204
References
CAC MF0961
Download: ML16193A383 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Brian D. Boles Site Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760 July 25, 2016

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 -RELAXATION OF THE SCHEDULE REQUIREMENTS FOR ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" (CAC NO.

MF0961)

Dear Mr. Boles:

By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A735), the U.S. Nuclear Regulatory Commission (NRC) issued order EA-12-049 to FirstEnergy Nuclear Operating Company (FENOC, the licensee),

requiring certain actions at Davis-Besse Nuclear Power Station (DBNPS), Unit 1, associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by Title 10 of the Code of Federal Regulations Part 50 licensees to develop and implement strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external events (BDBEEs). Condition IV.A.2 of Order EA-12-049 requires full implementation of the order requirements no later than two refueling cycles after submittal of the overall integrated plan, or by December 31, 2016, whichever comes first.

Section IV of the order states that the Director, Office of Nuclear Reactor Regulation, may relax or rescind certain conditions of the order upon demonstration of good cause. By letter dated March 11, 2016 (ADAMS Accession No. ML16071A296), FENOC submitted a request for an extension of the Order EA-12-049 full-compliance date to August 1, 2016, which is after startup from the spring-2016 refueling outage. The NRC staff determined that the licensee demonstrated good cause for relaxation of the order implementation date and granted the requested relaxation on April 6, 2016 (ADAMS Accession No. ML16077A370).

By letter dated July 11, 2016 (ADAMS Accession No. ML16193A487), FENOC submitted a request for an additional extension of the Order EA-12-049 full compliance date to December 31, 2016. The licensee's request states that FENOC has experienced unanticipated failures of newly-installed equipment that have delayed the completion of plant modifications such that order compliance by the previously relaxed date of August 1, 2016, is challenged.

The licensee's request indicates that the method chosen to implement the requirements of Order EA-12-049 includes the use of a new emergency feedwater (EFW) system for the DBNPS Phase 1 mitigating strategies that is housed in a newly constructed, robust EFW facility (EFWF) designed to withstand all applicable BDBEEs. In addition, selected portable diverse and flexible coping strategies (FLEX) equipment will also be stored in the EFWF to provide reasonable protection from a postulated BDBEE.

The design and construction of the new EFW system and EFWF was scheduled to be completed in time to achieve full compliance with Order EA-12-049 by the relaxed compliance date of August 1, 2016. However, implementation of the EFW system plant modification has been further delayed by unanticipated challenges associated with newly installed EFW system components. Specifically, the EFW pump malfunctioned during system testing, requiring the pump to be removed and shipped off site for repair. In addition, the EFW system flow control valve also exhibited performance irregularities, which are under investigation and may require removal and shipment to an off-site facility for repair.

The licensee requested an extension of the DBNPS, Unit 1, order implementation date from August 1, 2016, to no later than December 31, 2016, to allow inspection and repair or replacement of the newly-purchased pump and flow control valve and completion of the EFW system installation. As detailed in the request dated July 11, 2016, the licensee notes that all other aspects of the DBNPS mitigating strategies will be implemented by the previous August 1, 2016, compliance date. This will provide some mitigation capabilities until the full FLEX capability is installed. The licensee also notes that DBNPS will work to achieve full FLEX mitigating strategy capability as early as possible and before the end of December 2016.

In light of the facts presented in the licensee's letter dated July 11, 2016, the NRC staff has determined that the licensee has demonstrated good cause for relaxation of the order implementation date. Implementation of the EFW system plant modification involves complex activities that must be integrated with safe plant operations at the DBNPS site. In addition, unanticipated failure of newly-purchased and installed equipment will require vendor involvement and additional time to repair or replace the affected components. The NRC staff also considered the partial FLEX capability that will be in place at DBNPS, Unit 1, during the relaxation period. Further, the NRC staff notes that following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima Dai-ichi accident is unlikely to occur in the United States based on the current regulatory requirements and existing plant capabilities. Given the plant-specific circumstances at DBNPS and that completion by the proposed date does not extend past December 31, 2016, the ultimate implementation date established by the order, the NRC staff approves the requested relaxation.

Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of Order EA-12-049 for full-order implementation for DBNPS, Unit 1, is relaxed until December 31, 2016, to allow the licensee sufficient time to complete EFW system component repairs and installation, and fully implement the required strategies.

If you have any questions, please contact John Hughey, at 301-415-3204.

Sincerely, William M. Dean, Director Office of Nuclear Reactor Regulation Docket No. 50-346 cc: Listserv

ML16193A383 OFFICE NRR/JLD/JOMB/PM NRR/JLD /LA OE OGC, NLO NAME JHughey SLent RFretz DCylkowski DATE 07/12/2016 07/12/2016 07/12/2016 07/18/2016 OFFICE NRR/JLD/JOMB/BC (A) NRR/JLD/D NRR/D NAME MHalter JDavis (MShams for)

WDean (MEvans for)

DATE 07/20/2016 07/21/2016 07/25/2016