ML17227A236

Presentation Slides from February 18, 2016, Meeting with Duke Energy Regarding Crystal River Unit 3, Cyber Security Plan Implementation Schedule Milestone 8

ML17227A236
Person / Time
Site:	Crystal River
Issue date:	02/18/2016
From:	Duke Energy Corp
To:	Office of Nuclear Material Safety and Safeguards
References
Download: ML17227A236 (14)

Text

Cyber Security Plan Implementation Schedule Milestone 8 r..

• ~ DUKE February 18, 2016 ENERGY@

Current Cyber M-8 NRC completion date acknowledged Last day of permanent Established (Plant Security SFP certified critical reactor cessation of Nuclear remediation to be clean operation power ops Island complete) of SNM/SF Sept26, 2009 Mar 23, 2013 Oct 30, 2014 Dec 31 , 2017 June, 2018 Dec 31 , 2012 Sept26, 2013 Mar31 , 2015

• Feb, 2018 Dec 31, 2018 Cyber M 1-7 Spent Fuel Permanently ISFSI Complete, REQUESTED completion Pool Defueled all SF stored in Cyber M-8 calculations Emergency ISFSI completion date Plan (PDEP)

• - Completed Milestones * - In Progress Milestone * - Future Milestone - Requested Change

• On February 20, 2013, Duke Energy submitted a certification of permanent cessation of power operations pursuant to 10 CFR 50.82(a)(1 )(i).

• By letter dated March 13, 2013, the NRC acknowledged CR-3's certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel.

• Accordingly, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for CR-3 no longer authorizes power operation of the reactor or emplacement or retention of fuel in the reactor vessel.

• The CR-3 reactor was last critical on September 26, 2009. Most radioactive sources are in the SFPs, and decay heat and source term continue to diminish.

• CR-3 determined that the only remaining credible design basis accident in the permanently defueled condition is the fuel handling accident (FHA).

• Accident source terms no longer contain particulates (alkali metals) or halogens (iodines), the only source term is from noble gas KR-85 that contribute to dose consequences.

• ISFSI construction project is ongoing and planned completion of SFP offload is currently scheduled for February 2018.

• Based on analysis, with no ventilation across the SFP, the time to boil after loss of all cooling is approximately 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> (10 Days).

• Based on this analysis, the time to uncover fuel in the Spent Fuel Pool (SFP) on a complete loss of forced cooling is estimated at 34 days with an estimated average heat-up rate of the SFP of 0.43°F/hr and an estimated boil off rate of approximately 6 gpm.

• It should be noted the SFP temperature is maintained at approximately 80°F year round and the aforementioned analysis assumes the event begins at a SFP temperature of 110°F, this provides an additional 3 days of margin until the SFPs would boil.

• Based on analysis for the Fuel Handling Accident shows the following dose consequences compared to the limits (in brackets):

Control Room 1.3E-04 rem TEDE [5 rem TEDE]

Exclusion Area Boundary 5.9E-05 rem TEDE [6.3 rem TEDE]

Low Population Zone 1.0E-05 rem TEDE [6.3 rem TEDE]

• These results show that the licensing basis accident scenario generates very low doses. The Exclusion Area Boundary (EAB) and Low Population Zone (LPZ) limit of 6.3 rem TEDE is taken from Regulatory Guide 1.183 and is 25°/o of the 25 rem offsite dose limits of 10 CFR 50.67. The 5 rem TEDE Control Room dose limit is also established in 10 CFR 50.67.

• Based on analysis for the Fuel Handling Accident determined that the most limiting of the spent fuel assembly stored in the SFP would net a release of 537 curies of Kr-85 as of 9/26/2013.

• Using the EAB dose and dose limit, it can be estimated that as of 9/26/2013, if all 1243 spent fuel assemblies failed and contained the same amount of curies as the most limiting spent fuel assembly, the dose at the EAB would be - .0733 rem, as compared to the dose limit at the EAB of 6.3 rem TEDE.

• There is no design basis accident scenario or credible accident that could cause damage to this amount of fuel.

• Based on analysis of a complete SFP rapid drain down event. As of 9/26/2013 (conservative data by more than two years), the analysis determined that clad failure would not occur and therefore the only dose at the EAB would be from gamma shine, which would only be a small fraction of the dose limits.

• This analysis demonstrates that on a rapid drain down event, the fuel clad would not catch fire in the empty pool.

• Hypothetically even if the clad failure did occur, the resultant dose would result in a dose of 0.178 rem at the EAB.

• The analysis shows that at four years post reactor operation, cladding failure would not occur.

Crystal River is currently 6.3 years post operation, therefore providing additional margin.

• Crystal River is currently a nuclear island and has modified the Spent Fuel Cooling System to be cooled by a system independently from original plant design.

• All connections to originally designed plant cooling system have been severed and those systems are now abandoned.

• To date, all safety related systems and most of systems important to safety for cooling the spent fuel are abandoned.

• Milestones 1 through 7 are complete.

• The Cyber Security Program is established and periodic Cyber Security Assessment Team (CSAT) meetings occur and evaluate changes.

• The Portable Mobile Media Device (PMMD) Program is established at Crystal River.

• The Plant Security System was chosen first to assess and determine remediations.

• Crystal River is focused on the security remediations of the Plant Security System that are scheduled to be completed on or before 12/2017.

• Crystal River is requesting an extension from 12/31/2017 to 12/31/2018 to complete the Cyber Security Plan Milestone 8.

• We will fully comply with Milestone 8 for the Security System and complete all remediations.

• We will transition from wet to dry storage early in 2018.

• Duke Energy feels that it would be undo burden to exhaust the resources and expense to comply with the remaining portions of the cyber security rule for the remaining few months to transition from wet to dry spent fuel storage.

• This would impose minimal risk to the public based on the age of the fuel and results of the calculations discussed previously.

• Crystal River was still an operating plant when Milestones 1-7 were completed.

• The status and configuration of Crystal River has significantly changed.

• Nearly all of the Safety Related and Systems Important to Safety have been abandoned and can no longer affect reactivity, the Spent Fuel Systems or Emergency Planning.

• The PDEP has been approved which further reduces the scope of Cyber Security.

• The Plant Security System remediations will be completed on or before the end of 2017, which reduces Cyber Security vulnerabilities.

• A new Plant Security System will be installed as part of the ISFSI project permitting a majority of the existing Plant Security System to be abandoned.

• Duke Energy believes that extending the completion date for Milestone 8 by 1 year poses a very low risk to the health and safety of the public.

• The extension would allow CR3 to remain in compliance with the cyber rule through the transition to an ISFSl-only site whereas the cyber security requirements for an operating facility will no longer be applicable.

• CR3 intends to submit a LAR to remove the cyber security license condition for ISFSl-only.

• The requested 12/31 /18 date provides for additional time to allow the spent fuel pools to be certified free of license materials, allow for any emerging items in the ISFSI project and allow time for the site to prepare for and implement ISFSl-only Security and Emergency plans.