NG-20-0017, License Amendment Request (TSCR-184) Non-SGI Document Retransmittal

License Amendment Request (TSCR-184) Non-SGI Document Retransmittal

ML20055D286
Person / Time
Site:	Duane Arnold
Issue date:	02/24/2020
From:	Dean Curtland NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-20-0017, TSCR-184
Download: ML20055D286 (8)

Text

NEXTera" ENERGY~

DUANE ARNOLD February 24, 2020 NG-20-0017 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-184) Non-SGI Document Retransmittal

Reference:

D. Curtland (NextEra Energy Duane Arnold, LLC) to USNRC, "License Amendment Request (TSCR-184): Proposed Change to the Physical Security Plan for the Post-Shutdown and Permanently Defueled Condition," Sl-20-001, dated February 13, 2020 (ML20049A822)

This retransmittal provides the non-SGI Attachments to the referenced letter, which were originally provided via a Safeguards CD. Attachment 2 contains the No Significant Hazards Consideration determination. Attachment 3 provides a markup of the Operating License showing the proposed change, and Attachment 4 provides the clean-typed Operating License page. There are no changes in any of these attachments.

Attachments 1, 5, 6 and 7 of the referenced letter contain SGI and are not included in this retransmittal.

This letter contains no new or revised regulatory commitments .

If you have any questions or require additional information, please contact Mike Davis at (319) 851-7032.

Dean Curtland Site Director NextEra Energy Duane Arnold , LLC Attachments : As stated cc: Regional Administrator, USNRC, Region Ill Project Manager, USNRC, Duane Arnold Energy Center NextEra En ergy Duane Arn old, LLC , 3277 DAEC Road, Palo , IA 5232 4

SAFEGUARDS INFORMATION Sl-20-001 License Amendment Request (TSCR-184)

Attachment 2 No Significant Hazards Consideration 2 pages follow NOTE Attachments 1, 5, 6 and 7 to this Jetter contain "SAFEGUARDS !NFORMAT!Ot\1" 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-20-001 Page 2 of 3 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 plant Structures, Systems, or Components (SSCs) . The proposed changes do not involve the modification of any plant equipment or affect plant 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 Attachments 1, 5, 6 and 7 to this letter contain "S/l,FEGUARDS !NFORMA TJON" 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-20-001 Page 3 of 3 SAFEGUARDS INFORMATION 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 plant 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 plant 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 plant 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 plant 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 iNFORMAT!ON" 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-20-001 License Amendment Request (TSCR-184)

Attachment 3 License Page (Markup) 1 page follows NOTE Attachments 1, 5, 6 and 7 to this letter contain "S/l,FEGUAROS !."IFOR."AAT!ON" and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED."

SAFEGUARDS INFORMATION

Sl 001 Page 2 of 2 SAFEGUARDS INFORMATION and safeguards contingency plans includ ing amendments made pursuant to pro~is.ions of tile Miscellaneous Am endments and Search Requirements revislorns to 10 CFR 73 .55 (51 FR 27817 and 27822} a nd to the authority of 10 CFR 50.90 and 10 CFR 50. 54 ~p). The c ombine d set of plans, v.iflich contai ns Safeguards ilnfom1ation prolected under 10 CFR 73.2 1, is ernlitled: "Duane Arnold Energy Center Physical Security Plan,~ submitted by letter da!ed May 1 g 21:ll'.J9 .February 13, 2020. J Ne;dEra Energy Duane Arnold , UC shal I fully imp!emenl and maintain in effect all provisions of the Commission-approved Du ane Arnold Energy Cente.rlNex:IEra Energy Duane Arnold, LLC Cyller Security Plan ~CSP}, including changes m ade pursuant to t he aulhority of 10 CFR 50.90 a nd 10 CFR 50.54(p). T.he Du ane Arnold Ernergy Cente rl'Nex!Era Energy Duane Arnold, LLC C SP was approved by License Amendment No. 278, as supplemented by cbanges approved by license '}

AmeOO!nent No. 284 and Amendment 291.

(6) Deleted (7~ Additio nal Condit ions Tile Addlfion al Conditions co ntained in Appen.>dix B, as re**ised through Amendment No. 279, a re hereby incorporated into till s licerioo. Nel!Era Energy Drmrne Arnold, lLC shall operate file facility in accordance v.ilh ttie Additiornal Coooioons.

(8) Tlile licensee is authorized to revise the Updated FEnal Safer/ Anal ysis Report by deleting the footnote for Section 9.1.4.4.5 which smtes: "*Tlile NRC h as not endorsed tile reactor building crane as single-faITTure proof (Referen ce 9),

• aoo by deleting Reference 9 of the references for Seclion 9.1.

(9) Mitigation Strategy License Coooilion De*.relop and .maintain strategies for addressing large fires and explosions arnd that include the following key areas:

(a} Fire fighting res ponse strategy with the fol!ov.~ng el emenls:

1. Rre-delined coordinated fire 1respo111se slrategy .amt guDclance

2. Assessment of mutual aid fire fighting assels

3. Designated staging areas for eq uipment .'.!Ind materials

4. Comm and and control

5. Trainirng *of response personnel (b) Operalf.ons to m iiigate fuel dam age considering ttie folloviiing:

1. Rrotection arnd use of personne'I assets

2. Communications

3. Minimizing lire spread

4. Proc edures for implementing integrated fire response strategy

5. Identification of readily-avai!ttble pre-staged equipment

6. Traini ng on integrated fire response strategy

7. Spent fuel pool m itigation measures (c) Actions to 1rninimize release to in clude considera1i.on of:

• 1. Water spray scrubbing

2. Dose to onsite responders (10) The licensee shall implement and maintairn all Actions required by .Allachmeril 2 to NRC Order EA-06-137, issued June 20, 2006, except thie last action that requires incorporation of the s.t rategies into the site secunty plan, contingency plan, emergency plan andtor guard train ing and qualification plan, as a ppropriate.

Reniev.'ed License No. DPR-49 Amendmen t No. Xh..,"'{

NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS Jl\JFORMA TION" 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-20-001 License Amendment Request (TSCR-184)

Attachment 4 License Page (Clean-Typed) 1 page follows NOTE Attachments 1, 5, 6 and 7 to this letter contain "SAFEGUARDS !f'.'FORMA T!O."."'

and must be protected accordingly. Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED. "

SAFEGUARDS INFORMATION

Sl 001 Page 2 of 2 SAFEGUARDS INFORMATION 311d safeguards contingency plans including amendments made pursuant to provisions of the Mi>scel!aneol!ls Amendments and Search Requirements re\lisio ris to *m 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, wfli ch contains Safeguards lnfom1ation protected under 10 CFR 73.2 1, is entitled : "Duane Arnold Energy Center Physical Security Plan," submitted by *Jetter dated February 13, 2020.

NextEra Energy Dua ne Arnold , LL C shall fully implement and maintain in effect all provisjons of the Commission-approved Duane Arnold Energy Center/Nex!Era Energy Duan*e Arnold, LLC Cyber Security Plan {C SP), including changes made pursuant to the aulhority of 10 CFR 50.90 and 10 CFR 50.54(p}. Th-e Duane Arnold Energy Center/Nex!Era Energy Duane Arnold, LLC CSP was appro*1ed by License Amend ment No. 278, as supplemented by changes approved by license Ame nidrnent No. 284 and Amendment 291 .

(6) Deleted (7 ) Additio nal Conditions The Adcfllion al CoildLtions co ntained in Appendix B, as revised through Amendment No_279, are hereby incorporated into th is license. NexlEra E nergy Duarae Arnold, lLC shall operate the facirity *in accordance with the />,dditional Condioons.

(8) The li censee is au01orized to revise the Updated Final Safety A:nalysis Report by dele1ing the footnote for Section 9.1.4.4.5 v.'hich states: ""The NRC !has. not endorsed

!hie re.actor building crane as sin gle-fatll!lre proof (Reference 9)," and by deleting Reference 9 of Ute references for Section 9.1.

{9) MitigalDon Slra!egy license Condition Develop and m aintain strategies. tor addressing large fires arid explosions and Uiat iriclude the following key areas:

(a) Fire fighting response strategy with the folfov,i ng e.lemen!s:

1_ Rre-deful ed coord inated fire response strategy and guidance

2. Assessment of m utual aid fire fighting assets 3_ Designated staging areas for equipment and materiat<S 4_ Command and comtrol 5_ Training of response personnel (b) Operations to m itigate fuel damage considering Uie follo\'li ng:

• 1. Prnteclion a nd use of personnel assets 2_ Communicalions

3. Minimizing ilire spread

4. Prncedures for implementing integrated fire response s!rategy 5_ ldenti!ica1iom of readi ly-available pre-staged equipmen t 6_ Trainimg on integrated fire response strategy 7_ ~-:Pent fuel pool mitigation measures (c) Actions to m inimize release to include considera!fon of:

1_ Wafer spray scrubbfng

2. Dose lo onsite reiiponders

{10} The 5censee shall implement and maintain a!I Actions required by Attachment 2 to NRC Order EA-()6-137, issued June 20, 2006, except the last action that requires iricorporation of the strategies into !he site security pl an, co ntir.igency pl an, emergency plan andfor guard training and qualification p!an, as. .appropriate.

Renewed license No. DPR-49 Amendment N o.

NOTE Attachments 1, 5, 6 and 7 to this letter contain "Sl',FEGUARDS !NFORMAT/0,"J" and must be protected accordingly_Unauthorized disclosure could result in civil and/or criminal sanctions. Upon separation, this page is "DECONTROLLED".

SAFEGUARDS INFORMATION