SBK-L-15137, Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events...

Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events...

ML15245A531
Person / Time
Site:	Seabrook
Issue date:	08/26/2015
From:	Dean Curtland NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, SBK-L-15137
Download: ML15245A531 (15)

Text

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August 26, 2015 SBK-L-15 137 Docket No. 50-443 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station NextEra Energy Seabrook, LLC's Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA- 12-049)

References:

1. NRC Order Number EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, March 12, 2012 (ML12054A736)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA- 12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, August 29, 2012 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012 (ML12242A378)

4. NextEra Energy Seabrook, LLC Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA- 12-049),

October 26, 2012 (ML12311A013)

5. NextEra Energy Seabrook, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA-12-049),

February 26, 2013 (ML13063A438)

6. NextEra Energy Seabrook, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), August 28, 2013 (ML13247A178)

7. NextEra Energy Seabrook, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), February 27, 2014 (ML14064A188) j151 NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBKi-L- 15137/Page 2

8. NextEra Energy Seabrook, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), August 26, 2014 (ML14246A193)

9. NextEra Energy Seabrook, LLC Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, (Order Number EA 049), February 27, 2015 (ML15068A021)

10. SBK-L-15 152, NextEra Energy Seabrook LLC's Request for Schedule Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, July 23, 2015 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to NextEra Energy Seabrook, LLC (NextEra Energy Seabrook). Reference 1 was immediately effective and directs NextEra Energy Seabrook to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the NextEra Energy Seabrook initial status report regarding mitigation strategies. Reference 5 provided the NextEra Energy Seabrook overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6 through 9 provided the six-month status reports pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. Reference 9 also included the revised FLEX Integrated Plan. The Attachment to this letter provides the fifth six-month update report required by Reference 1 (Attachment 1), that detineates progress made in implementing the requirements of Reference 1 and an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis.

This letter contains no new regulatory commitments.

U.S. Nuclear Regulatory Commission SBK-L- 15 137/Page 3 If you have any questions regarding this report, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 4*' , 2015.

Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President cc: D. Dorman, NRC Region I Administrator J.G. Lamb, NRC Project Manager, Project Directorate 1-2 P. Cataldo, NRC Senior Resident Inspector Director, Office of Nuclear Reactor Regulation Ms. Jessica A. Kratchmann, NRRIJLDiPMB, NRC Mr. Eric E. Bowman, NRRhIDPRJPGCB Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Attachment to SBK-L- 15137 NextEra Energy Seabrook, LLC's Fifth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

NextEra Energy Seabrook, LLC's Fifth Six Month Status Report for the Implementation of Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events' 1 Introduction NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) developed and submitted an Overall Integrated Plan (Reference 1) in response to NRC Order EA-12-049. The Integrated Plan has been revised to describe Seabrook' s current proposed diverse and flexible coping strategies (FLEX). This status report provides an update of milestone accomplishments since submittal of the Overall Integrated Plan, and an update of the pending and open/confirmatory actions.

2 Milestone Accomplishments The following milestones have been completed since the submittal of the Overall Integrated Plan:

• Submit first 6 month status report.

• Submit second 6 month status report.

• Submit third 6 month status report.

• Submit fourth 6 month status report.

• Submit fifth 6 month status report.

• Prepare engineering change package for RCP low leakage seals.

• Develop required training for station staff based upon draft procedure changes and engineering change packages.

• Procure SEPS/portable equipment refueling trailer.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Seabrook Overall Integrated Plan (OIP)

(Reference 1). The table includes the current status of each item and whether the expected completion date has changed. As noted in the original station submittal these dates are planning dates which are subject to change as design and implementation details are developed.

The following milestone target completion dates have been adjusted or added:

In the original submittal of the OIP in February 2013, NextEra Energy Seabrook included Westinghouse SHIELD low leakage Reactor Coolant Pump (RCP) seals in all 4 RCPs as a backup strategy against significant Reactor Coolant System (RCS) leakage to Containment. The revised Integrated Plan credits the replacement of all 4 RCP seals with the SHIELD seal technology in October 2015 during refueling outage 17. The original OIP included a missile shield for the Supplemental Emergency Power System (SEPS). While SEPS remains NextEra Energy Seabrook's primary strategy during all events with the exception of a wind-driven missile event, the missile shield is being deleted in the revised OIP. NextEra Energy Seabrook

will employ a full set of portable FLEX equipment protected from all hazards for events in which SEPS is not available. Revised milestone target completion dates do not currently support NextEra Energy Seabrook's full compliance date. NextEra Energy Seabrook has requested that the full compliance date be extended from November 2015 to May 30, 2016.

Target Revised Milestone Completion Activity Status Target Date Completion Submit Overall Integrated Fbur 03Cmlt /

Implementation Plan Fbur 03Cmlt Submit 6 Month Updates:

Update 1 Aug 2013 Complete N/A Update 2 Feb 2014 Complete N/A Update 3 Aug 2014 Complete N/A Update 4 Feb 2015 Complete N/A UpdateS5 Aug 2015 Complete N/A Update 6 Feb 2016 Not Started N/A Prepare engineering change December Cancelled N/A packages for SEPS missile barrier 2014 Prepare engineering change package December Complete N/A for RCP low leakage seals 2014 Prepare bid for construction of March 2015 Cancelled N/A SEPS missile barrier Install RCP shutdown seals in four April 2014 Contract for RCP low October 2015 pumps in refueling outage #17 leakage seals awarded Construct SEPS missile barrier December Cancelled N/A 2014 Revise / develop procedures based December Working October 2015 upon approved strategies and 2014 engineering implementation

Target Revised Milestone Completion Activity Status Target Date Completion Date packages Develop required training for station December Complete N/A staff based upon draft procedure 2014 changes and engineering change packages.

Procure SEPS / portable equipment December Complete N/A refueling trailer 2014 Submit 4t 6-month status report to February 2015 Complete N/A NRC Develop PMs for refueling trailer March 2015 Working October 2015 Store refueling trailer in Service June 2015 On Hold March 2016 Water Pump house Off-site resources implementation June 2015 Working October 2015 site - RRC operational fall 2015 5th 6-month status report to NRC August 2015 Complete N/A Conduct walkthroughs / August 2015 Working October 2015 demonstrations of portable equipment connection points Implement training for station staff September Working N/A 2015 Final implementation - Order full November Not Started May 2016 compliance letter to NRC 2015

4 Changes to Compliance Method NextEra Energy Seabrook has received feedback in the form of NRC audit questions and subsequent teleconferences with NRC Staff reviewers. The NRC' s Interim Staff Evaluation (ISE) was also received. A revised Integrated Plan and list of pending actions was uploaded to ePortal for NRC staff review on February 6, 2015. The onsite NRC FLEX audit was conducted the week of July 27, 2015. Items were reviewed by NRC Staff reviewers, audit questions responded to, and Staff Evaluation items closed or statused as open/pending.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation On July 23, 2015, NextEra Energy Seabrook submitted Reference 10 requesting schedule relaxation from the Order requirements for completion of full implementation from November 2015 to May 30, 2016. The request for relaxation was based on the development of a second set of strategies. These strategies were submitted in Reference 9. The request for schedule relaxation will allow more than the current 9 months allowed in the existing schedule to implement the new strategies.

6 Open Items from Overall Integrated Plan and NRC Interim Staff Evaluation /TER The following Table provides a summary of the Pending Items documented in the Overall Integrated Plan:

Overall Integrated Plan Pending Actions Status 1 Revise ECA-0.0 to include steps to transition to In Progress FLEX Support Guidelines (FSGs) when an extended loss of offsite power event is in progress. This determination will delineate future procedural strategies and transitions.

2 Develop FSG-0.0 attachments to include a SEPS Complete. FSG-0.0 Attachments A load reduction method for an extended loss of offsite and B provide for maintaining loads power event to control SEPS loading within the within the capacity of one SEPS capacity of one engine, engine.

3 A seismic evaluation will be conducted on the Complete, no credit will be taken for connections that penetrate the upper half of the the non-seismic volume in the CST.

Condensate Storage Tank (CST) to determine if NextEra Energy Seabrook can take credit for the entire tank volume for Phase 1 & 2 event coping.

4 Develop FSG-0.0 to add a step to manually Complete shutdown the motor-driven Emergency Feedwater (EFW) pump if the Turbine Driven (TD)EFW pump is running satisfactorily.

Overall Integrated Plan Pending Actions Status 5 Add an Attachment to ES-0.2, ES-0.3 and ES-0.4 Complete that provides a table of electrical loads for responding to an extended loss of offsite power event.

6 Develop a SEPS generator set (genset) refueling In Progress. FSG-5 provides strategy from 1) an offsite supplier outside a 25 mile refueling strategies, offsite supplier radius from the station (primary strategy), and 2) the contract is in progress.

Emergency Diesel Generator (EDG) fuel oil storage tanks using a refueling trailer stored in the Service Water (SW) Pumphouse (backup strategy). This strategy will include provisions for refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the event that only a single SEPS is functional.

7 Develop FSG-5 and FSG-5.1 to include a step for Complete. FSG-5.1.1 implementation of a SEPS genset refueling strategy.

8 Develop a FSG for refueling SEPS from the EDG Complete. FSG-5.1.1 fuel oil storage tanks using a portable refueling trailer. Utilize the information contained in existing procedure 0S 1061.02, 'Receipt of SEPS Fuel Oil',

for development of the FSG.

9 Develop FSG-5 to include direction for connecting Complete. FSG-5 step 24 the backup diesel-driven air compressor to the Service Air system to restore Instrument Air system pressure.

10 Develop required preventive maintenance actions In Progress and surveillance test procedures for the refueling trailer to be procured and stored in the SW Pumphouse.

11 Revise AOPs to include transitions to FSG-1 1 and In Progress FSG-14 when Extended Loss of all AC Power (ELAP) is in progress for shutdown mode strategies.

12 Conduct an engineering evaluation to determine if Complete. SEPS missile protection the existing hurricane enclosures for the SEPS will not be added. Other missile gensets provide adequate missile protection. If protected strategies are being added protection is not adequate, develop a design change (EC) to add missile protection for the SEPS gensets.

Overall Integrated Plan Pending Actions Status 13 Evaluate the 'seismic robustness' of SEPS and Complete. EC 282774 Fukushima determine if enhancements are needed with respect SEPS Foundations and Exhaust to the new Ground Motion Response Spectrum Seismic Upgrade and EC 282825 (GMRS) data for the site. Fukushima SEPS components Seismic Upgrades.

14 Once the site flooding re-evaluation is completed in In Progress. Extension granted by accordance with Recommendation 2.1 of the RFI NRC for completion of analysis by letter, determine if additional flood protection is 9/30/15.

necessary for SEPS.

15 Formalize the Engineering assessment of ELAP load Complete. FSG-4 and FSG-4. 1 capacity for a single SEPS genset and modify procedural guidance in the applicable Emergency Operating Procedures (EOPs) and FSGs, as necessary.

16 Evaluate SEPS snow removal plan and revise the Complete. SEPS missile protection plan as necessary. will not be added.

17 Determine if a quantity of diesel fuel will be In Progress. Contract bids pending for provided from the National SAFER Response a fuel contract with supplier outside Centers (NSRCs) along with requested Phase 3 the 25 mile radius.

portable equipment. If not, establish a contract with a fuel supplier outside a 25 mile radius from the plant to provide fuel within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of a Beyond Design Basis External Event (BDBEE).

18 Develop a FSG for staging and deployment of Phase Complete. FSG-5.1 3 equipment from the RRCs into the Protected Area (PA).

19 Develop a FSG for connecting the two 1MW Complete. FSG-5. 1 generators from the NSRC to 4.16 KV Emergency Buses E5 and E6 and a 1MW generator from the NSRC to 480V Buses E53 and E63.

20 Develop a FSG for refueling the NSRC generators Complete. FSG-5.1 or incorporate this action into the SEPS refueling FSG.

21 Install low leakage RCP seals on all four RCPs to In Progress. All four seals are planned minimize RCS leakage into Containment, to be replaced with the low leakage

Overall Integrated Plan Pending Actions Status seal design in October 2015.

22 Based on PWROG guidance, determine if new FSGs Complete, new FSGs are being are required that incorporate the existing guidance developed for Steam Generator (SG) provided in SAG-i, 'Inject to the SGs', and SAG-3, and RCS injection in the event SEPS

'Inject to the RCS' or whether transition points to is unavailable using alternate FLEX these two Severe Accident Management Guidelines RCS makeup connections.

(SAMGs) should be added to the applicable EOPs.

23 Develop a method for obtaining local readings for Complete. FSG-7 and FSG-7. 1.1 the 12 critical parameters identified in the Integrated Plan and include in site procedures as appropriate.

24 Develop Westinghouse FSGs to support ELAP Complete. FSG-0.1 directs the strategies with SEPS unavailable, response to ELAP with SEPS unavailable.

25 Develop BC to use existing below grade Unit 2 Complete. BC 282982 modifies the Circulating Water (CW) abandoned piping section below grade unit 2 Circ water piping as a holding tank for credited makeup in SG to be used as a cistern for injection injection strategies. water.

26 Perform analysis to qualifyr Unit 2 CW piping as a Complete. Documented in BC 282982 credited makeup source in seismic and missile Fukushima FLEX Unit 2 CW Pipe related events Water Storage.

27 Perform analysis for containment pressure & Complete. C-X-1-28 141 Containment temperature response after installation of RCP Response During BLAP - Gothic shutdown seals to ensure containment integrity is not challenged without containment cooling.

28 Perform analysis for SG feedwater quality Complete. C-X-1-20720-CALC, S/G requirements to ensure continued SG heat sink Water Quality Analysis Through 72 capability for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following loss of AC power. Hours 29 Perform analysis for RCS boration and cooldown Complete. CN-SEE-II-15-3-Revision strategies to support FSG development 1 30 Complete SG, Spent Fuel Pool (SFP), and RCS Complete. C-X-l-20718-CALC makeup hydraulic analysis for FLEX strategies in Diverse and Flexible Coping Strategy modes 1-6. Hydraulic Analysis 31JComplete FSG setpoint calculations and basis.InPors In Progress

Overall Integrated Plan Pending Actions Status 32 Complete FLEX equipment storage building Complete. EC 282582 FLEX Portable analysis and develop EC for SW pumphouse Equipment Storage.

building mods.

33 Complete site flooding analysis and add any interim In Progress. Extension granted by actions to OS 1200.03, Severe Weather Conditions. NRC for completion of analysis by 9/30/15.

34 Procure site FLEX portable equipment to augment In Progress Seabrook BDBEE response strategies.

35 Complete ECs for plant system FLEX connections Complete. EC 282580 for Fire Tanks, EFW pumphouse, Demineralized Water Storage Tanks (DWSTs), and Positive Displacement Charging pump.

36 Complete Analysis for > 8 hrs heat removal using Complete. C-X-1-20719-.CALC CST. Determination of Water Inventory Required for RCS Heat Removal During ELAP 37 Revise the NextEra Energy Nuclear Training Complete Program to assure personnel proficiency in the mitigation of BDBEE is adequate and maintained.

38 Complete the travel route soil liquefaction study. In Progress 39 Modify the SWPH entrance with a new Barrier I In Progress missile door to allow for rapid deployment with missile protection.

7 Interim Staff Evaluation Open/Confirmatory Item Status Open/Confirmatory Item Status 3.2.4.8.A Verify that the enclosure for the SEPS Closed DGs and switchgear SEPS-SWG-1 provides sufficient protection of the equipment from seismic events and wind driven missiles.

3.1.1.1 .A Protection of FLEX equipment from Closed seismic and high wind hazards - Confirm that the PDDPs and hose trailers will be adequately protected from seismic and high wind hazards.

3.1.1 .2.A Confirm that at least one connection Open point for each use of a PDDP is protected from a seismic event (includes access to the connection point and areas the operators have to access to deploy or control the PDDP).

3.1.1 .2.B Confirm that a tow vehicle for FLEX Closed equipment movement is reasonably protected from a seismic event, flooding event, and high wind event.

3.1.1.3 .A Procedural interface for seismic hazards Closed

-Confirm that operators have procedural guidance and references for the methods of obtaining local readings for critical parameters to support the implementation of the coping strategy, consistent with the guidelines in Section 3.2.1.10 of NEI 12-06.

3.1.1.4.A Off-Site Resources - Confirm the Closed location of the local staging area for the RRC equipment, and that access routes to the site, the method of transportation, and the drop off area have been properly evaluated for all applicable hazards.

3.1.5 High temperature - Confirm that the effects Closed of high temperature have been considered in the procurement, protection, and deployment of FLEX equipment.

3.2.1 .7.A Confirm that portable FLEX equipment Closed is included in the licensee's program to maintain equipment available for deployment in shutdown and refueling modes.

3.2.1.9.A Use of portable pumps - Confirm that Closed appropriate procedural guidance is provided for operation of the PDDPs for SG and RCS injection as part of the FLEX strategies.

3.2.1.9.B Confirm availability of the fire main to Closed provide a suction source for the PDDP for all of the hazards applicable to Seabrook.

3.2.2.A Confirm that the PDDPs and hose trailers Closed are incorporated into the FLEX guidelines for makeup and spray to the SFP.

3.2.4.4.A Confirm that adequate portable lighting Closed is available for operator use during an ELAP event.

3.2.4.4.B The NRC staff has reviewed the Closed licensee communications assessment (ADAMS Accession Nos. ML 1231 1A34 and ML13060A048) and has determined that the assessment and planned upgrades are reasonable (ADAMS Accession No. ML13102A254).

Confirm that the upgrades have been completed.

3.2.4.7.A Confirm the source of water to be used Closed for makeup to the service water cooling basin tower by the portable diesel-driven cooling tower makeup pump.

3.2.4.8.B Confirm that any SEPS missile barrier Closed modifications do not interfere with the ability to remove snow from the SEPS D~s air intake system.

3.2.4.9.A Confirm that the refueling strategy for Closed SEPS has been changed to require refueling to begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the event.

3.3.1 .A Confirm that the PDDPs will be included Closed in the maintenance and testing (M&T) program in conformance with the Electric Power Research Institute report on M&T.

3.3.2.A Confirm that the configuration control of Closed FLEX strategies conforms to the guidance of Section 11.8 of NEI 12-06.

3.4.A Offsite resources - COnfirm that NEI 12-06, Closed Section 12.2 guidelines 2 through 10, regarding minimum capabilities for offsite resources, have been adequately addressed.