ML17220A328
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 The Operating Boiling-Water Reactor Mark I and Mark 11 Licensees on the Enclosed List August 10, 2017
SUBJECT:
NUCLEAR REGULATORY COMMISSION AUDITS OF LICENSEE RESPONSES TO PHASE 2 OF ORDER EA-13-109 TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF OPERATION UNDER SEVERE ACCIDENT CONDITIONS The U.S. Nuclear Regulatory Commission (NRC) staff will perform a review of licensee responses to Phase 2 (severe accident capable drywell venting system or reliable alternative) of Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13143A334). The NRC staff will complete the ongoing review by conducting audits of pertinent additional information, which will typically include documents, calculations and drawings referenced in the respective plant submittals. This audit activity will focus and streamline obtaining information needed to conduct the Order EA-13-109 Phase 2 reviews by using the ePortal system previously set up by licensees. This audit activity may also be performed concurrent with ongoing Phase I audits (ADAMS Accession No. ML14126A545). Audits of licensee's* responses will be performed in accordance with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111,
"Regulatory Audits" (ADAMS Accession No. ML082900195). Enclosure 2 to this document provides the associated audit plan for this activity.
As part of the audit process, NRC staff members will contact licensees to discuss topics relevant to the existing docketed submittals, as well as information that may be contained in the ePortal system. The NRC staff considers licensee participation in the audit process for the Order EA-13-109 Phase 2 review to be voluntary. For those licensees who do not wish to participate in the audit process, the NRC staff will request the information needed to support the Order EA-13-109 Phase 2 review by an alternate mechanism.
If you have any questions about this matter, please contact Raj Auluck at (301) 415-1025 or Rajender.Auluck@nrc.gov.
Enclosures:
- 1. List of Boiling-Water Reactor Mark I and Mark II Operating Reactor Licensees
- 2. Audit Plan cc w/encl: Distribution via listserv NEI h I, irector Japan Lessons-Learned Division Office of Nuclear Reactor Regulation
OPERATING BOILING-WATER REACTOR LICENSEES WITH MARK I AND MARK II CONTAINMENTS Browns Ferry Nuclear Plant Tennessee Valley Authority Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, DPR-52 and DPR-68 Mr. Joseph W. Shea Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801 Brunswick Steam Electric Plant Duke Energy Progress, LLC Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 Mr. William R. Giddeon Site Vice President Brunswick Steam Electric Plant 8470 River Rd. SE (M/C BNP001)
Southport, NC 28461 Columbia Generating Station Energy Northwest Docket No. 50-397 License No. NPF-21 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest MD 1023 North Power Plant Loop P.O. Box 968 Richland, WA 99352 Cooper Nuclear Station Nebraska Public Power District Docket No. 50-298 License No. DPR-46 Mr. John Dent, Jr.
Vice President-Nuclear and CNO Nebraska Public Power District Cooper Nuclear Station 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 Dresden Nuclear Power Station Exelon Generation Company, LLC Docket Nos. 50-237 and 50-249 License Nos. DPR-19 and DPR-25 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Docket No. 50-331 License No. DPR-49 Mr. Dean Curtlan Site Director NextEra Energy Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324-9785
Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Co., Inc.
Docket Nos. 50-321 and 50-366 License Nos. DPR-57 and NPF-5 Mr. James J. Hutto Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
P.O. Box 1295, BIN 038 Birmingham, AL 35201-1295 Fermi DTE Electric Co.
Docket No. 50-341 License No. NPF-43 Mr. Paul Fessler, Senior Vice President and Chief Nuclear Officer DTE Electric Company Fermi 2 - 210 NOC 6400 North Dixie Highway Newport, Ml 48166 Hope Creek Generating Station PSEG Nuclear, LLC Docket No. 50-354 License No. NPF-57 Mr. Peter P. Sena, Ill President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P. 0. Box 236 Hancocks Bridge, NJ 08038 James A. FitzPatrick Nuclear Power Plant Exelon Generation Company, LLC Docket No. 50-333 License No. DPR-59 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 LaSalle County Station Exelon Generation Co., LLC Docket Nos. 50-373 and 50-37 4 License Nos. NPF-11 and NPF-18 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Limerick Generating Station Exelon Generation Co., LLC Docket Nos. 50-352 and 50-353 License Nos. NPF-39 and NPF-85 Mr. Bryan C. Hanson Senior Vice President Exelon Nuclear Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd.
Warrenville, IL 60555 Monticello Nuclear Generating Plant Northern States Power Company -
Minnesota Docket No. 50-263 License No. DPR-22 Mr. Peter A. Gardner Site Vice President Northern States Power Company -
Minnesota Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362-9637
Nine Mile Point Nuclear Station Nine Mile Point Nuclear Station, LLC Docket Nos. 50-220 and 50-41 O License Nos. DPR-63 and NPF-69 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd Warrenville, IL 60555 Peach Bottom Atomic Power Station Exelon Generation Co., LLC Docket Nos. 50-277 and 50-278 License Nos. DPR-44 and DPR-56 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd Warrenville, IL 60555 Quad Cities Nuclear Power Station Exelon Generation Co., LLC Docket Nos. 50-254 and 50-265 License Nos. DPR-29 and DPR-30 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd Warrenville, IL 60555 Susquehanna Steam Electric Station Susquehanna Nuclear, LLC Docket Nos. 50-387 and 50-388 License Nos. NPF-14 and NPF-22 Mr. Brad Berryman Site Vice President Susquehanna Nuclear, LLC 769 Salem Boulevard NUCSB3 Berwick, PA 18603-0467 Audit Plan
NRC OFFICE OF NUCLEAR REACTOR REGULATION AUDIT PLAN TO REVIEW PHASE 2 LICENSEE SUBMITTALS IN RESPONSE TO ORDER EA-13-109 "ISSUANCE OF ORDER TO MODIFY LICENSES WITH REGARD TO RELIABLE HARDENED CONTAINMENT VENTS CAPABLE OF*OPERATION UNDER SEVERE ACCIDENT CONDITIONS" BACKGROUND On June 6, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13143A334), the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-13-109, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions", to all Boiling Water Reactor (BWR) licensees with Mark I and Mark II primary containments. Order EA-13-109 rescinds the requirements imposed by Order EA-12-050 "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents" (ADAMS Accession No. ML12054A694) and replaces them with the requirements contained in Order EA-13-109. Licensees are no longer expected to comply with the requirements of Order EA-12-050, including applicable schedule deadlines for additional submittals or implementation. Likewise, the NRC staff does not plan to issue safety evaluations related to the integrated plans submitted in accordance with Order EA 050 or take any additional actions related to that order.
Phase 2 of Order EA-13-109 requires license holders of BWRs with Mark I and Mark II primary containments to design and install a venting system that provides venting capability from the drywell under severe accident conditions, or, alternatively, those licensees shall develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions. The order required all applicable licensees, by December 31, 2015, to submit to the Commission for review an overall integrated plan (OIP) including a description of how compliance with the Phase 2 requirements described in Order EA-13-109 Attachment 2 will be achieved.
The NRC staff will conduct audits of licensee OIP submittals per NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit activity will promote the ability of the NRC staff to focus and streamline obtaining the information needed to conduct the Order EA-13-109 Phase 2 reviews by utilizing the ePortal system previously set up by licensees. If necessary, onsite audits will be conducted. In conducting these audits, the NRC staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The ongoing audit process allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation.
AUDIT BASIS The NRC staff will review the information contained in licensee's submittals in response to Phase 2 of Commission Order EA-13-109 dated June 6, 2013, modifying licenses with regard to requirements Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions order.
The Nuclear Energy Institute (NEI) developed "Industry Guidance for Compliance with Order EA-13-109," NEI 13-02, Revision 1, dated April 23, 2015 (ADAMS Accession No. ML15113B318). The methodologies described in this guide were endorsed, with exceptions and clarifications, by NRC Japan Lessons-Learned (JLD) interim staff guidance (ISG) JLD-ISG-2015-01 "Compliance with Phase 2 of Order EA-13-109, 'Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions"' (ADAMS Accession No. ML15104A118) as providing one acceptable means of meeting the order requirements. Other methods that deviate from the guidance may be found acceptable, but will require additional staff review and attention.
AUDIT PURPOSE AND SCOPE The audit's purpose and scope is to review the OIP, 6-month status reports and supporting information via the ePortal, and/or onsite audit visits. The purpose of the audit is to obtain and review information responsive to NRC staff questions, and to observe and gain a better understanding of the basis for the site's overall strategy to ensure the licensee is on the correct path for compliance with the Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions order.
INFORMATION NECESSARY FOR THE AUDIT AND PROCESS The NRC staff will review the information contained in licensees' Phase 2 OIPs in response to Order EA-13-109 and the information provided via this audit review process using the respective licensee ePortals in-office and/or from onsite audit visits.
STAFF ASSIGNMENTS Staff in the Office of Nuclear Reactor Regulation will perform this audit.
LOGISTICS Continuing Review and Development of Further Questions:
The submitted OIPs will be reviewed in batches by NRC staff. Priority is determined by when a plant needs to be in compliance with Phase 2 of Order EA-13-109. During these reviews, staff will develop questions to better understand how a licensee plans to fully comply with the order.
These questions will be provided by e-mail to licensees. Because these questions may not be fully reflective of information that is necessary for the staff to make a determination regarding the OIPs, they should be considered pre-decisional.
Teleconferences with Licensees Audit questions will be discussed in telephone conferences with licensees, supported by management and staff from the Office of Nuclear Reactor Regulation. The purpose of these calls is for the NRG staff and the licensees to have a common understanding of the issue raised by the reviewers. Many of the issues are complex, and the goal is to ensure that the NRG staff understands what the licensee submitted, and, if necessary, for the licensee to understand what supplemental information may be necessary to explain how the requirements of the order are met.
Subsequently, licensees should provide the NRG with the necessary supplemental information that was agreed upon during the teleconference. To facilitate the audit schedule, this information should be provided to the NRG via the ePortal.
Periodic Updates Due to the iterative and ongoing nature of the development of the licensee OIPs, the NRG staff evaluation of these plans will be based on the information available at the time of review. This will include information contained in the ePortals, information submitted under oath or affirmation as part of the formal periodic status report updates required by the order or as a supplement to the licensee's OIP.
DELIVERABLES The staff will consider the information reviewed during the audit as part of its overall review of licensees OIPs. The staff's evaluations and audit reports will be issued in batches to support licensees' compliance schedules.
The NRG plans to hold public meetings to discuss the results of the staff's reviews.
REFERENCES U.S. Nuclear Regulatory Commission, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Order EA-13-109, June 6, 2013 (ADAMS Accession No. ML13130A067)
Nuclear Energy Institute, "Industry Guidance for Compliance with Order EA-13-109," NEI 13-02, Revision 1, April 23, 2015, Washington, DC (ADAMS Accession No. ML151138318)
JLD-ISG-2013-02 "Compliance with Order EA-13-109, 'Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions,"' November 14, 2013 (ADAMS Accession No. ML133048836)
JLD-ISG-2015-01 "Compliance with Phase 2 of Order EA-13-109, Severe Accident Reliable Hardened Containment Vents," April 29, 2015 (ADAMS Accession No. ML15104A118)
HCVS Phase 1 and 2 OIP Template, September 28, 2015 (ADAMS Accession No. ML15273A141)
Individual licensee submittals in response to Phase 2 of N RC Order EA-13-109
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