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| number = ML12230A115 | | number = ML12230A115 | ||
| issue date = 08/22/2012 | | issue date = 08/22/2012 | ||
| title = Closeout of Bulletin 2011-01, Mitigating Strategies | | title = Closeout of Bulletin 2011-01, Mitigating Strategies | ||
| author name = Morgan N | | author name = Morgan N | ||
| author affiliation = NRC/NRR/DORL/LPLI-1 | | author affiliation = NRC/NRR/DORL/LPLI-1 | ||
| Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 22, 2012 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 22, 2012 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 | ||
==SUBJECT:== | ==SUBJECT:== | ||
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. ME6412 AND ME6413) | CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS. | ||
ME6412 AND ME6413) | |||
==Dear Mr. Gellrich:== | ==Dear Mr. Gellrich:== | ||
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of the bulletin was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2). | On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS) | ||
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of the bulletin was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2). | |||
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f). | The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f). | ||
Calvert Cliffs Nuclear Power Plant, LLC, the licensee, provided its responses to the bulletin by letters dated June 10 and July 11, 2011 (ADAMS Accession Nos. ML11164A262 and ML11194A023, respectively). | Calvert Cliffs Nuclear Power Plant, LLC, the licensee, provided its responses to the bulletin by letters dated June 10 and July 11, 2011 (ADAMS Accession Nos. ML11164A262 and ML11194A023, respectively). By letter dated November 30, 2011 (ADAMS Accession No. ML113110588), the NRC sent the licensee a request for additional information (RAI) on its July 11, 2011, response. The licensee responded to the RAI by letter dated February 3, 2012 (ADAMS Accession No. ML12038A013). | ||
By letter dated November 30, 2011 (ADAMS Accession No. ML113110588), the NRC sent the licensee a request for additional information (RAI) on its July 11, 2011, response. | The NRC staff has reviewed the information submitted by the licensee and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in the bulletin. No further information or actions under the bulletin are requested. | ||
The licensee responded to the RAI by letter dated February 3, 2012 (ADAMS Accession No. ML12038A013). | |||
The NRC staff has reviewed the information submitted by the licensee and concludes that its response to the bulletin is acceptable. | G. Getlrich -2 Please feel free to contact me at 301-415-1016, if you have any questions. | ||
As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in the bulletin. | Sincerely Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 | ||
No further information or actions under the bulletin are requested. | |||
G. Getlrich -2 Please feel free to contact me at 301-415-1016, if you have any questions. | |||
Sincerely Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 | |||
==Enclosure:== | ==Enclosure:== | ||
Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv | Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv | ||
==SUMMARY== | ==SUMMARY== | ||
OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. SO-317 AND SO-318 On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 1112S0360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section SO.S4(f). | OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. SO-317 AND SO-318 On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS) | ||
The first responses were due 30 days after issuance of the bulletin. | Accession No. ML 1112S0360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section SO.S4(f). The first responses were due 30 days after issuance of the bulletin. By letter dated June 10,2011 (ADAMS Accession No. ML11164A262), Calvert Cliffs Nuclear Power Plant, LLC (the licensee) provided its response to the first set of questions (first response) for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. The second responses were due 60 days after issuance of the bulletin. By letter dated JuJy 11,2011 (ADAMS Accession No. ML11194A023), the licensee provided its response to the second set of questions (second response). By letter dated November 30, 2011 (ADAMS Accession No. ML 11311 OS88), the NRC staff sent a request for additional information (RAJ) on the second response. The licensee responded to the RAJ by letter dated February 3,2012 (ADAMS Accession No. ML12038A013). As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin. | ||
By letter dated June 10,2011 (ADAMS Accession No. ML11164A262), Calvert Cliffs Nuclear Power Plant, LLC (the licensee) provided its response to the first set of questions (first response) for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. The second responses were due 60 days after issuance of the bulletin. | |||
By letter dated JuJy 11,2011 (ADAMS Accession No. ML11194A023), the licensee provided its response to the second set of questions (second response). | ==1.0 BACKGROUND== | ||
By letter dated November 30, 2011 (ADAMS Accession No. ML 11311 OS88), the NRC staff sent a request for additional information (RAJ) on the second response. | |||
The licensee responded to the RAJ by letter dated February 3,2012 (ADAMS Accession No. ML12038A013). | On February 2S, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.S.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire. | ||
As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin. | By letter dated July 11, 2007 (ADAMS Accession No. ML0719200S6), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by the licensee regarding Section B.S.b of the ICM Order. Along with the SE, the NRC staff issued a conforming license condition to incorporate the B.S.b mitigating strategies into the licensing basis. | ||
On March 27, 2009, the NRC issued 10 CFR SO.S4(hh)(2) as a new rule, in order to capture the B.S.b mitigating strategies and related license conditions as regulatory requirements for both current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR SO.S4(hh)(2) (74 FR 13926), | |||
therefore, no further actions were required on the part of current licensees. | |||
Enclosure | |||
2.0 30*DAY REQUEST In order to confirm continued compliance with 10 CFR SO.S4(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin: | |||
: 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function? | |||
: 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff? | |||
The NRC staff reviewed the licensee's first response to determine if it had adequately addressed these questions. | |||
2.1 Question 1: Availability and Capability of Equipment In its first response, the licensee confirmed that equipment it needs to execute the 10 CFR SO.S4(hh)(2) mitigating strategies is available and capable of performing its intended function. | |||
The NRC staff verified that this confirmation covered equipment needed for each of the three phases of B.S.b mitigation strategies. Therefore, the NRC staff finds that the licensee has adequately responded to Question 1. | |||
2.2 Question 2: Guidance and Strategies Can Be Executed In its first response, the licensee confirmed that the guidance and strategies it has implemented for 10 CFR SO.S4(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staff's skills. Since the licensee has considered its current facility configuration, staffing levels, and staff's skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that the licensee has adequately responded to Question 2. | |||
3.0 60*DAY REQUEST The bulletin required a response to the following five questions within 60 days of issuing the bulletin: | |||
: 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. | |||
: 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it will function when needed. | |||
-3 | |||
: 3. Describe in detail the controls for ensuring that the equipment is available when needed. | |||
: 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible. | |||
S. Describe in detail how you ensure availability of offsite support. | |||
The NRC staff reviewed the I.icensee's submittals to determine if it had adequately addressed these questions. This was accomplished by verifying that the submittals listed equipment, training, and offsite resources which were relied upon to make conclusions in the July 11,2007, SE or are commonly needed to implement the mitigating strategies. | |||
3.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity. | |||
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that the fire engine, portable pump. hoses, and communications equipment receive maintenance or testing. The licensee did not identify maintenance or testing of monitor nozzles, spray nozzles, or similar devices in its second response. In its RAI response, the licensee stated that these devices are inventoried and that implementation of preventive maintenance for these devices was being evaluated. In its RAI response, the licensee stated that the fuel level for the portable pump is verified on a monthly basis. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing. | |||
The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. The licensee stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending. | |||
This was accomplished by verifying that the submittals listed equipment, training, and offsite resources which were relied upon to make conclusions in the July 11,2007, SE or are commonly needed to implement the mitigating strategies. | Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Questions 1 and 2. | ||
3.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity. | 3.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment. such as inventory reqUirements, to ensure that the equipment is available when | ||
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. | |||
In its second response, the licensee stated that the fire engine, portable pump. hoses, and communications equipment receive maintenance or testing. The licensee did not identify maintenance or testing of monitor nozzles, spray nozzles, or similar devices in its second response. | -4 needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested. | ||
In its RAI response, the licensee stated that these devices are inventoried and that implementation of preventive maintenance for these devices was being evaluated. | |||
In its RAI response, the licensee stated that the fuel level for the portable pump is verified on a monthly basis. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing. The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. | |||
The licensee stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending. | |||
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Questions 1 and 2. 3.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment. | |||
such as inventory reqUirements, to ensure that the equipment is available when | |||
-4 needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested. | |||
The NRC staff verified that the licensee described its process for ensuring that B.S.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified. | The NRC staff verified that the licensee described its process for ensuring that B.S.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified. | ||
Items verified include proper quantity, location, and accessibility of equipment; compressed gas bottle pressures; calibrations; equipment shelf lives; and controls on storage locations. | Items verified include proper quantity, location, and accessibility of equipment; compressed gas bottle pressures; calibrations; equipment shelf lives; and controls on storage locations. The licensee stated that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable. | ||
The licensee stated that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable. The NRC staff verified that the licensee inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. | The NRC staff verified that the licensee inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that procured non-permanently installed B.S.b equipment is inventoried in accordance with station procedures. The NRC staff noted that all items listed are inventoried at least quarterly. The second response specifically stated that the following items are included in the inventory: portable pump; hoses; communications equipment; nozzles; connectors; tools; and instruments. The licensee also identified other items that support the mitigating strategies that are inventoried. | ||
In its second response, the licensee stated that procured non-permanently installed B.S.b equipment is inventoried in accordance with station procedures. | Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 3. | ||
The NRC staff noted that all items listed are inventoried at least quarterly. | 3.3 Question 4: Configuration and Guidance Management Question 4 of the 50-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible. | ||
The second response specifically stated that the following items are included in the inventory: | The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current In its second response, the licensee stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. The licensee stated that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.5.b mitigating strategies remain viable. | ||
portable pump; hoses; communications equipment; nozzles; connectors; tools; and instruments. | The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, the licensee identified testing in response to Question 2 that demonstrated the ability to execute some strategies. The licensee also stated that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011. | ||
The licensee also identified other items that support the mitigating strategies that are inventoried. | The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, the licensee identified the training provided to its operations personnel; emergency response organization, including key decision makers; security personnel; fire brigade; and other | ||
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 3. 3.3 Question 4: Configuration and Guidance Management Question 4 of the 50-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible. | |||
The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current In its second response, the licensee stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. | G. Gellrich -2 Please feel free to contact me at 301-415-1016, if you have any questions. | ||
The licensee stated that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.5.b mitigating strategies remain viable. The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. | Sincerely Ira! | ||
In its second response, the licensee identified testing in response to Question 2 that demonstrated the ability to execute some strategies. | Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 | ||
The licensee also stated that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011. The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. | |||
In its second response, the licensee identified the training provided to its operations personnel; emergency response organization, including key decision makers; security personnel; fire brigade; and other G. Gellrich -2 Please feel free to contact me at 301-415-1016, if you have any questions. | ==Enclosure:== | ||
Sincerely Ira! Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and | |||
RidsOgcRp RidsRgn1 BPurnell, ADAMS ACCESSION NO.: ML12230A115 | Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv DISTRIBUTION: | ||
*See dated Memo LPLI-1/PM LPLI-1/LA PGCB/BC(A)* | PUBLIC LPL1-1 R/F RidsAcrsAcnw_MaiICTR RidsNrrDorlDpr RldsNrrDorlLpl1-1 RidsNrrDraAhpb RidsNrrLAKGoldstein RidsNrrPMCalvertCliffs RidsOgcRp Resource RidsRgn1 MailCenter RidsNrrDprPgcb BPurnell, NRR ADAMS ACCESSION NO.: ML12230A115 *See dated Memo i OFFICE LPLI-1/PM LPLI-1/LA PGCB/BC(A)* LPLI-1/BC i NAME NMorgan KGoldstein KMorgan-Butler GWilson i II DATE I 8/21/2012 18/20/2012 I 612812012 I 8/22/2012 1\ | ||
LPLI-1/BC i NAME | OFFICIAL RECORD COpy}} | ||
Latest revision as of 14:09, 20 March 2020
| ML12230A115 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/22/2012 |
| From: | Nadiyah Morgan Plant Licensing Branch 1 |
| To: | George Gellrich Calvert Cliffs |
| Morgan N | |
| References | |
| BL-11-001, TAC ME6412, TAC ME6413 | |
| Download: ML12230A115 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 22, 2012 Mr. George H. Gellrich, Vice President Calvert Cliffs Nuclear Power Plant, LLC Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 CLOSEOUT OF BULLETIN 2011-01, "MITIGATING STRATEGIES" (TAC NOS.
ME6412 AND ME6413)
Dear Mr. Gellrich:
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies" (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of the bulletin was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f).
Calvert Cliffs Nuclear Power Plant, LLC, the licensee, provided its responses to the bulletin by letters dated June 10 and July 11, 2011 (ADAMS Accession Nos. ML11164A262 and ML11194A023, respectively). By letter dated November 30, 2011 (ADAMS Accession No. ML113110588), the NRC sent the licensee a request for additional information (RAI) on its July 11, 2011, response. The licensee responded to the RAI by letter dated February 3, 2012 (ADAMS Accession No. ML12038A013).
The NRC staff has reviewed the information submitted by the licensee and concludes that its response to the bulletin is acceptable. As summarized in the enclosure, the NRC staff verified that the licensee provided the information requested in the bulletin. No further information or actions under the bulletin are requested.
G. Getlrich -2 Please feel free to contact me at 301-415-1016, if you have any questions.
Sincerely Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
Enclosure:
Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv
SUMMARY
OF NRC BULLETIN 2011-01 "MITIGATING STRATEGIES" RESPONSE REVIEW CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. SO-317 AND SO-318 On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML 1112S0360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section SO.S4(f). The first responses were due 30 days after issuance of the bulletin. By letter dated June 10,2011 (ADAMS Accession No. ML11164A262), Calvert Cliffs Nuclear Power Plant, LLC (the licensee) provided its response to the first set of questions (first response) for the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2. The second responses were due 60 days after issuance of the bulletin. By letter dated JuJy 11,2011 (ADAMS Accession No. ML11194A023), the licensee provided its response to the second set of questions (second response). By letter dated November 30, 2011 (ADAMS Accession No. ML 11311 OS88), the NRC staff sent a request for additional information (RAJ) on the second response. The licensee responded to the RAJ by letter dated February 3,2012 (ADAMS Accession No. ML12038A013). As summarized below, the NRC staff has verified that the licensee provided the information requested in the bulletin.
1.0 BACKGROUND
On February 2S, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.S.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire.
By letter dated July 11, 2007 (ADAMS Accession No. ML0719200S6), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by the licensee regarding Section B.S.b of the ICM Order. Along with the SE, the NRC staff issued a conforming license condition to incorporate the B.S.b mitigating strategies into the licensing basis.
On March 27, 2009, the NRC issued 10 CFR SO.S4(hh)(2) as a new rule, in order to capture the B.S.b mitigating strategies and related license conditions as regulatory requirements for both current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR SO.S4(hh)(2) (74 FR 13926),
therefore, no further actions were required on the part of current licensees.
Enclosure
2.0 30*DAY REQUEST In order to confirm continued compliance with 10 CFR SO.S4(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin:
- 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?
- 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?
The NRC staff reviewed the licensee's first response to determine if it had adequately addressed these questions.
2.1 Question 1: Availability and Capability of Equipment In its first response, the licensee confirmed that equipment it needs to execute the 10 CFR SO.S4(hh)(2) mitigating strategies is available and capable of performing its intended function.
The NRC staff verified that this confirmation covered equipment needed for each of the three phases of B.S.b mitigation strategies. Therefore, the NRC staff finds that the licensee has adequately responded to Question 1.
2.2 Question 2: Guidance and Strategies Can Be Executed In its first response, the licensee confirmed that the guidance and strategies it has implemented for 10 CFR SO.S4(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staff's skills. Since the licensee has considered its current facility configuration, staffing levels, and staff's skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that the licensee has adequately responded to Question 2.
3.0 60*DAY REQUEST The bulletin required a response to the following five questions within 60 days of issuing the bulletin:
- 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed.
- 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it will function when needed.
-3
- 3. Describe in detail the controls for ensuring that the equipment is available when needed.
- 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible.
S. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed the I.icensee's submittals to determine if it had adequately addressed these questions. This was accomplished by verifying that the submittals listed equipment, training, and offsite resources which were relied upon to make conclusions in the July 11,2007, SE or are commonly needed to implement the mitigating strategies.
3.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, the licensee listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, the licensee described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that the licensee listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that the fire engine, portable pump. hoses, and communications equipment receive maintenance or testing. The licensee did not identify maintenance or testing of monitor nozzles, spray nozzles, or similar devices in its second response. In its RAI response, the licensee stated that these devices are inventoried and that implementation of preventive maintenance for these devices was being evaluated. In its RAI response, the licensee stated that the fuel level for the portable pump is verified on a monthly basis. The licensee also identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that the licensee described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. The licensee stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Questions 1 and 2.
3.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment. such as inventory reqUirements, to ensure that the equipment is available when
-4 needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested.
The NRC staff verified that the licensee described its process for ensuring that B.S.b equipment will be available when needed. In its second response, the licensee identified equipment included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity, location, and accessibility of equipment; compressed gas bottle pressures; calibrations; equipment shelf lives; and controls on storage locations. The licensee stated that at the time of its second response there were no outstanding inventory deficiencies that would render the strategies not viable.
The NRC staff verified that the licensee inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, the licensee stated that procured non-permanently installed B.S.b equipment is inventoried in accordance with station procedures. The NRC staff noted that all items listed are inventoried at least quarterly. The second response specifically stated that the following items are included in the inventory: portable pump; hoses; communications equipment; nozzles; connectors; tools; and instruments. The licensee also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that the licensee has provided the information requested by Question 3.
3.3 Question 4: Configuration and Guidance Management Question 4 of the 50-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible.
The NRC staff verified that the licensee described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current In its second response, the licensee stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.S.b mitigating strategies. The licensee stated that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.5.b mitigating strategies remain viable.
The NRC staff verified that the licensee described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, the licensee identified testing in response to Question 2 that demonstrated the ability to execute some strategies. The licensee also stated that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011.
The NRC staff verified that the licensee described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its second response, the licensee identified the training provided to its operations personnel; emergency response organization, including key decision makers; security personnel; fire brigade; and other
G. Gellrich -2 Please feel free to contact me at 301-415-1016, if you have any questions.
Sincerely Ira!
Nadiyah S. Morgan, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318
Enclosure:
Summary of NRC Bulletin 2011-01 Response Review cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL1-1 R/F RidsAcrsAcnw_MaiICTR RidsNrrDorlDpr RldsNrrDorlLpl1-1 RidsNrrDraAhpb RidsNrrLAKGoldstein RidsNrrPMCalvertCliffs RidsOgcRp Resource RidsRgn1 MailCenter RidsNrrDprPgcb BPurnell, NRR ADAMS ACCESSION NO.: ML12230A115 *See dated Memo i OFFICE LPLI-1/PM LPLI-1/LA PGCB/BC(A)* LPLI-1/BC i NAME NMorgan KGoldstein KMorgan-Butler GWilson i II DATE I 8/21/2012 18/20/2012 I 612812012 I 8/22/2012 1\
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