ML20311A127
| ML20311A127 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/29/2020 |
| From: | Dean Curtland NextEra Energy Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Sl-20-002 | |
| Download: ML20311A127 (9) | |
Text
NEXTeraM ENERGY~
DUANE ARNOLD SAFEGUARDS INFORMATION October 29, 2020 Sl-20-002 10 CFR 50.90 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 License Amendment Request (TSCR-188): Proposed Change to the Physical Security Plan for the Post-Shutdown and Permanently Defueled Condition
References:
- 1. D. Curtland (NextEra Energy Duane Arnold, LLC) to USNRC, "Certification of Permanent Cessation of Power Operations," NG-20-0074, dated August 27, 2020 (M L20240A067)
- 2. D. Curtland (NextEra Energy Duane Arnold, LLC) to USNRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center," NG-20-0090, dated October 12, 2020 (ML20286A317)
Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold, LLC (NEDA) requests an amendment to the Facility License for the Duane Arnold Energy Center (DAEC) . The proposed amendment would revise the DAEC Physical Security Plan (PSP) to align the defensive strategy with the post-shutdown and permanently defueled condition .
In Reference 1, NEDA provided formal notification to the U.S. Nuclear Regulatory Commission (NRC), pursuant to 10 CFR 50.82(a)(1 )(i) and 10 CFR 50.4(b)(8), of the permanent cessation of power operations at the DAEC on August 10, 2020. In Reference 2, NEDA provided formal notification to the U.S. NRG of the permanent removal of fuel from the DAEC reactor vessel. In accordance with 10 CFR 50.82(a)(1 )(i) and (ii) respectively, and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license no longer authorizes reactor operation or emplacement or retention of fuel in the reactor vessel.
Attachment 1 to this letter provides NEDA's evaluation of the proposed change. Attachment 2 contains the No Significant Hazards Consideration determination. Attachment 3 provides a markup of the Facility License showing the proposed change, and Attachment 4 provides the clean-typed Facility License page . Attachment 5 provides a change synopsis describing NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions.
Upon separation, this page is "DECONTROLLED. "
SAFEGUARDS INFORMATION NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324
Sl-20-002 Page 2 of 2 SAFEGUARDS INFORMATION the PSP Revision D1 changes, and Attachment 6 provides the proposed PSP Revision D1. Attachment 7 provides a copy of PSP Revision DO. NEDA requests that Attachments 1, 5, 6 and 7 to this letter, which contain Safeguards Information, be withheld from public disclosure pursuant to 10 CFR 73 .22.
NEDA requests approval of the proposed license amendment by August 31, 2021, and implementation within 30 days of the approved amendment effective date.
In accordance with 10 CFR 50.91, a copy of this request without attachments is being provided to the designated State of Iowa official.
As discussed in Attachment 2, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. The DAEC Onsite Review Group has reviewed and concurred with the proposed license amendment.
This letter contains no new or revised regulatory commitments .
If you have any questions or require additional information, please contact John Schwertfeger at (319) 851-7504.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 29, 2020.
Dean Curtland Site Director NextEra Energy Duane Arnold, LLC Attachments: As stated cc: Regional Administrator, USNRC, Region Ill w/o Attachments 1, 5, 6 and 7 Project Manager, USNRC, DAEC w/o Attachments 1, 5, 6 and 7 Resident Inspector, USNRC, DAEC w/o Attachments 1, 5, 6 and 7 Angela Leek (State of Iowa) w/o Attachments NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED".
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION Sl-20-002 License Amendment Request (TSCR-188)
Attachment 2 No Significant Hazards Consideration 2 pages follow NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED."
SAFEGUARDS INFORMATION
Duane Arnold Energy Center to Sl-20-002 Page 1 of 2 SAFEGUARDS INFORMATION 4.3 No Significant Hazards Consideration NEDA has evaluated whether a significant hazards consideration is involved with the proposed amendment using the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Security events, in and of themselves, are not initiators of any accidents previously evaluated in the Safety Analysis, nor are they considered in the evaluation of the consequences of any accident previously evaluated .
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .
- 2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
\
The proposed changes to the DAEC Physical Security Plan do not impact the function of facility Structures, Systems, or Components (SSCs). The proposed changes do not involve the modification of any facility equipment or affect facility operation . The proposed changes do not affect accident initiators or precursors, nor do the proposed changes alter design assumptions.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) Does the proposed amendment involve a significant reduction in a margin of safety?
Response : No.
NOTE SAFEGUARDS INFORMATION
Duane Arnold Energy Center to Sl-20-002 Page 2 of 2 SAFEGUARDS INFORMATION Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED. "
Margin of safety is associated with confidence in the ability of the fission product barriers to limit the level of radiation dose to the public. The proposed changes do not adversely affect existing facility safety margins or the reliability of the equipment assumed to operate in the safety analyses . There are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect facility safety as a result of the proposed changes . The proposed changes are associated with the DAEC Physical Security Plan and do not impact operation of the facility or its response to transients or accidents . The proposed changes do not affect the Technical Specifications. The proposed changes do not involve a change in the method of facility operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes and margins of safety are maintained.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, NEDA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50 .92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED."
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION Sl-20-002 License Amendment Request (TSCR-188)
Attachment 3 Facility License (Markup) 1 page follows NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED. "
SAFEGUARDS INFORMATION
Sl-20-002 Page 1 of 1 SAFEGUARDS INFORMATION and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the auttlority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards lnfom,ation protected under 10 CFR 73.21, is entitled: "Duane Arnold Energy Center Physical Security Plan," submitted by letter dated May 16, 2006. October 29, 2020. I NextEra Energy Duarne Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Duane Arnold Energy Center/Ne:xtEra Energy Duane Arnold, ll:C Cyber Security Plan (CSP), including changes m ade pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Duane Arnold Energy Center/Ne:xtEra Energy Duane Arnold, LLC CSP was approved by License Amendment No. 278, as supplemented by changes approved by license Amendment No. 284and Amendment 291.
(6) Deleted (7) Addilional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 279, are hereby incorporated irnto this license. NextEra Energy Duane Arnold, LLC shall operate the facility in accordance with the Additional Conditions.
(8) The licensee is authorized to revise the Updated Final Safety Analysis Report by deleting the footnote for Section 9.1.4.4.5 which states: ""The NRC has not endorsed the reactor building crane as single-failure proof (Reference 9)." and by deleting Reference 9 of the references for Section 9.1 .
(9) Mitigation Strategy License Condition Develop and maintain strategi es tor addressing large fires and explosions and 1h31 include t he following key areas:
(a) Fire fighting response slmtegy with the following elen1ents:
- 1. Pre-defined coordinated fire response strategy and guidance
- 2. Assessment of mulu3l aid fire ilighlirng assets
- 3. Desigriated staging areas for equipment and materials
- 4. Command and control
- 5. Training of iresponse personnel (b) Operations to mitigate fuel damage considering the following:
- 1. Protection 3nd use of personnel assets
- 2. Cornmunicatior.s
- 3. Minimizing fire spread
- 4. Procedures for implementing integrated fire response strategy
- 5. ldenlific3tion of readily-available pre-staged equipment
- 6. Training on i ntegrated fire response strategy
- 7. Spent fuel poof l'ritigation measures (c} Actions to minimize release to include consideration of:
- 1. Waler spray scrubbing
- 2. Dose to onsite responders (10) The licensee shall implement and maintain all Actions required !by Att3chmernt 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
Renewed License No. DPR-49 Amendment -342-NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED".
SAFEGUARDS INFORMATION
SAFEGUARDS INFORMATION Sl-20-002 License Amendment Request (TSCR-188)
Attachment 4 Facility License (Clean-Typed)
-1 page follows NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED."
SAFEGUARDS INFORMATION
Sl-20-002 Page 1 of 1 SAFEGUARDS INFORMATION and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revi!lions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21 , is entitled: "Duane Arnold Energy Center Physic.ii Security Plan; submitted by letter dated October 29, 2020.
NextEra Energy Duane Arnold, LLC shall fully implement and maintain in effect all provisions of the Commission-approved Duane Arnold Energy Center/NextEra Energy Duane Arnold, LLC Cyber Security Plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Duane Arnold Energy CenterJNextEra Energy Duane Arnold, LLC CSP was approved by License Amendment No. 278, as supplemented by changes approved by license Amendment No. 284 and Amendment 291.
(6) Deleted (7) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 279, are hereby incorporated into this license. NextEra Energy Duane Arnold, LLC shall operate the facility in accordance with the Additional Conditions.
(8) The licensee is _authorized to revi!le the Updated Final Safety Analysis Report by deleting the footnote for Section 9.1.4.4.5 which otates: "'The NRC has not endorsed the reactor building crane as single-failure proof (Reference 9)," and by deleting Reference 9 of the references for Section 9.1.
(9) MitigaUon Strategy Licernse Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key a reas:
(a) Fire fighting response strategy wilh the following elements:
- 1. Pre-defined coordinated fire response strategy and guidance
- 2. Assessment of mutual aid fire fighting assets
- 3. Desi~ated staging areao for equipment and materials
- 4. Command and control
- 5. Training of response pemonnel (b) Operations to mitig3te fuel d3mage considering the following:
- 1. Proteclion and use of personnel assets
- 2. Communic.itions
- 3. Minimizing fire spread
- 4. Procedures for implementirng integrated fire response strategy
- 5. Identification of readily-available pre-staged equipment
- 6. Training on integrated fire response strategy
- 7. Spent fuel pool n vtigation meaoores (c) Actions to minimize release to include consideration of:
- 1. Water spray scrubbing
- 2. Dose to onsite responders (1 0) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued june 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan ,
emergency plan and/or guard training and qualification plarn, as appropriate.
Renewed License No. DPR-49 Amendment NOTE Attachments 1, 5, 6 and 7 to this Jetter contain "SAFEGUARDS INFORMATION" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED ".
SAFEGUARDS INFORMATION