ML21167A186
| ML21167A186 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 06/03/2021 |
| From: | Hansen P NextEra Energy Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Sl-21-005 | |
| Download: ML21167A186 (12) | |
Text
NE XT er aM SAFEGUARDS INFORMATION ENERGY~
DUANE ARNOLD June 3, 2021 Sl-21-005 U. S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Docu men t Control Desk Washington, DC 20555-0001 Duan e Arnold Energy Center Docket Nos. 50-331, 72-32 Renewed Op. License No. DPR-49 License Ame ndm ent Request {TSCR-191): Prop osed Change to the Physical Security Plan for the ISFSl.,.Only Condition
References:
1_. D. Curtland (NextEra Energy Duane Arnold, LLC} to USN RC, "Certification of Permanent Removal of Fuel from the Reactor Vess el for Duane Arnold Energy Center," NG-20-0090, dated October 12, 2020 (ML20286A317)
Pursuant to 1_0 CFR 50.90, NextEra Energy Duan e Arnold, LLC (NEDA) requests an amendment to the Facility License for the Duan e Arnold Energy Cent er (DAEC). The
. proposed ame ndm ent would revise the DAEC Physical Security Plan (PSP) to reflect the requirements associated with the security chan ges for the Independent Spen t Fuel Storage Installation (ISFSI) only configuration, consistent with the permanent removal of all spent fuel from the Spent Fuel Pool (SFP) ..
In Reference 1, NED A provided formal notificatio n to the U.S. NRC of the permanent removal of fuel from the DAEC reactor vessel.
Pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license _no longer authorizes reactor oper ation or emplacement or retention of fuel in the reactor vessel.
Enclosure 1 to this letter provides NEDA's evalu ation of the proposed change. Enclosure 2 to this letter is a CD that contains the following files:
- AM0 2 Search Program DAEC
- AM0 3 Vital Area DAEC
- AM0 4 Illumination DAEC
- AMOS Suspension of Security Measures DAE
So o I
- -Att 1&2 DAEC *tSFSI Orders Response
- vH s 5 ztp
- DAEC 10 CFR ISFS I Cross Reference Review ;J~fc_
- DAEC Programmatic Assumptions for ISFSI-Onl y Site ;JH 5 S SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information.
This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324
NextEra Energy Di.Jane Arnold, LLC Sl-21-005 Page 2 of2 SAFEGUARDS INFORMATION NEDA requests that Enclosure 2, which contains Safeguards Information and Security-Related Information, be withheld from public-disclosure pursuant to 10 CFR 73.22 and 10 CFR 2.390, respectively.
NEDA requests approval of the proposed license amendment by April 1, 2022, and implementation within 90 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 the Enclosure, th_e 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 _June 3, 2021.
Decommissioning Director NextEra Energy Duane Arnold, LLC
Enclosures:
As stated cc: Regional Administrator, USNRC, Region Ill Project Manager, USNRC, DAEC (w/o Enclosure 2)
Resident Inspector, USNRC, DAEC (w/o Enclosure 2)
Angela Leek (State of Iowa) (w/o Enclosure 2)
SAFEGU ARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
- NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1 Page 1 of 6 SAFEGUARDS INFORMATION ENCLOSURE 1 Evaluation of the Proposed Change
Subject:
License Amendment Request (TSCR-191 ): Proposed Change to the Physical Security Plan for the ISFSI-Only Condition
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes 2.2 Reason for the Proposed Changes
- 3. TECHNICAL EVALUATION
- 4. REGULATORY EVALUATION
- 4. 1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions
- 5. ENVIRONMENTAL CONSIDERATION
- 6. REFERENCES ATTACHMENTS:
- 1.
- Proposed Facility License Changes (Mark-up)
- 2. Proposed Facility License Changes (Clean-typed)
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosu re 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1
- Page 2 of6 SAFEGUARDS INFORMATION
- 1.
SUMMARY
DESCRIPTION In accordance with the provisions of 10 CFR 50A and§ 50.90, NextEra Energy Duane Arnold, LLC (NEDA) is requesting an amendment to the Duane Arnold Energy Center (DAEC) F~cility License, License Condition 2.C.(5), Physical Protection. The proposed amendmentrequest is in support of the approval of a new DAEC Physical Security Plan (P.SP).
- 2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes DAEC FL Condition 2.C.(5), Physical Protection, would be modified to remove requirements for 10 CFR 73.55 and adding reference to 10 CFR 72.212(b)(9). Additionally, the DAEC PSP, which contains Safeguards Information protected under 10 CFR 73.21, will be updated accordingly.
2.2 Reason for the Proposed Changes NEDA provided the NRC a certification of permanent removal of the fuel of the DAEC reactor vessel on October 12, 2020 (Reference 1). Therefore, pursuantto 10 CF.R 50.82(a)(2), the 10 CFR 50 license for DAEC no longer a1,.1thorizes operation of the reactor or replacement or retention of fuel into the reactor vessel. Currently, spent fuel is stored in the spent fuel pool *
(SFP) and Independent Spent Fuel Storage Installation (ISFSI). The Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 2) documented NEDA's expectation that all spent fuel would be completely transferred to the ISFSI in 2022.
The current PSP at DAEC contains requirements that provide appropriate protection for the safe storage of spent fuel in the SFP, as well as the ISFSI. As such, the existing Security Plan provides a level of protection in excess of that required after all the spent fuel. is transferred to the ISFSI. The proposed Plan reflects the future site configuration where all the remaining spent fuel has been moved to ISFSI and that there is no requirement to return the spent fuel to the SFP. Transfer of fuel from the SFP to the ISFSI supports the decommissioning of DAEC, which involve*s the eventual dismantlement of the SFP and other remaining plant structures.
Therefore, the proposed Plan will supersede the existing Security Plan after the remaining spent fuel in the SFP has been moved to the ISFSI.
- 3. TECHNICAL EVALUATION The DAEC PSP addresses the protection of material on site that is licensed by the DAEC Facility License. The protection of material subject to the requirements of 10 CFR 37, "Physical Protection of Category 1 and Category 2 Qualities of Radioactive Material," is addressed in a separate Plan. NEDA has a general license ISFSI with security requirements in 10 CFR 72.212(b)(9). These security requirements also provide an appropriate level of protection for other special nuclear material on site. The DAEC PSP reflects the configuration of DAEC with the remaining spent fuel in the SFP moved to the ISFSI and no requirement to return spent fuel to the SFP. The security function for the ISFSI are to detect threats, assess those threats, and call for assistances from the local law enforcement agency (LLEA).
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information~ This page is decontrolled when separated from Enclosure 2.
- NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1 Page 3 of6 SAFEGUARDS INFORMATION 10 CFR 72.212(b)(9) requires licensees to comply with 10 CFR 73.55 and six (6) additional
- conditions and exceptions. The DAEC PSP was based on the NRC endorsed template for Operational Nuclear Plants, NEI 03-12, Revision 7, and modified to incorporate eight (8) additional conditions and exceptions. In addition, other requirements are not applicable for an ISFSI, such as-certain sections of the design basis threat, cyber security, target sets, 10 CFR 26, and portions of the insider mitigation program, and therefore are not included in the DAEC PSP.
Programmatic assumptions used to develop the DAEC PSP are discussed in the Enclosure 2 file "DAEC Programmatic Assumptions for ISFSI-Only Site".
Pursuant to 10 CFR ?3:55(r),_ eight (8) alternative measures have been incorporated in to the DAEC PSP. These alternative measures address the replacement of the Secondary Alarm Station (SAS) with an off-site Security Remote Monitoring Station (SRMS), illumination, searches, vital areas, s~spension of security measures, on-the-job (OJT) hours, owner-controlled area monitoring and Central Alarm Station (CAS) placement. Evaluation of these alternative measures are provided in Enclosure 2 files "AM01" through "AM0B". *
- NEDA has taken a methodical approach to integrating 10 CFR 72.212(b)(9) requirements with various other Code of Federal Regulation requirements. The DAEC PSP complies with these requirements exce.pt where alternative measures have been requested. The DAEC PSP protects against the design basis threat of radiological sabotage and ensures the health ahd safety of public.
- 4. REGULATOR Y EVALUATION 4.1 Applicable Regulatory Requirements/Criteria In accordance with the provisions of 10 CFR 50.4 and § 50.90, NEDA is requesting an amendment to DAEC Facility License, License Condition 2.C.(5), Physical Security. Applicable regulatory requirements are: "'
10 CFR Part 50.82, Termination of License, section (a)(2) states:
"Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."
- 10 CFR Part 72.212, Conditions of general license issued under §72.210, section (b)(9) states:
r .
"Protect the spent fuel against the design basis threat of radiological sabotage in accordance with the same provisions and requirements as are set forth in the licensee's physical security plan pursuant to §73. 55 of this chapter with the following additional conditions and exceptions:" .
- SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Ericlosure 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1 Page 4 of6 -
SAFEGUARDS INFORMATION 4.2 Precedent Several plants currently in the decommissioning process, including Kewaunee (ML17052A591 };
Vermont Yankee (ML18165A423), San Onofre Units 1, 2 and 3 (ML17311A364), and Fort Calhoun Unit 1 (ML20071E104), have revised their Physical Security Plans to reflect requirements for an ISFSl-only configuration.
4.3 No Significant Hazards Consideration Determination The DAEC PSP addresses the protection of material on site that is licensed by the DAEC Facility License. The protection of material subject to the requirements of 10 CFR 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material," is addressed in a separate plan.
The DAEC PSP reflects the configuration of DAEC after all of the spent nuclear fuel is stored at the ISFSI. The 10 CFR Part 50 license for DAEC no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.
NEDA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on 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.
The irradiated fuel at DAEC is currently stored in the SFP and at the ISFSI. In this condition, the number of credible accidents/transients is significantly smaller than for a plant authorized to operate the reactor or emplace of retain fuel in the reactor vessel.
Accidents/transients that are no longer applicable in a permanently defueled condition have been deleted from the DAEC Defueled Safety Analysis Report, as upd;ated (DSAR) Chapter
However, as previously discussed, the DAEC PSP reflects the future site configuration where all the remaining spent fuel in the SFP has been moved to the ISFSI and there are- no requirements to return spent fuel to the _SFP. The FHA will no longer be credible after all fuel has been removed from the SFP.
The casks will continue to be maintained in accordance with the provisions of the general license for the DAEC ISFSI, utilizing the TN Americas LLC, Standardized NUHOMS-61 BT and -61 BTH Systems, Certificate of Compliance (CoC) No. 72.:.1ob4, and in accordance with the associated NUH-003 Updated Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel (UFSAR). The NUH-003 UFSAR, Section 8.2, Accident Analysis, provides the evaluation of accidents for the Standardized NUHOMS-61 BT and -61 BTH Systems, in which accident conditions are analyzed to demonstrate that the requirements of 10 CFR 72.122 are met and that adequate safety margins exist for the NU HOMS system design. *
. SAFEGUARDS INFORMATION Enclosure 2 contains Safeg_uards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1 Page 5 of6 SAFEGUARDS INFORMATION The proposed amendment has no effect on the capability of any facility systems, structures, and components (SSCs) to perform their design function. The modifications associated with these changes do not significantly affect the ability of the DSC and HSM to perform their functions as described in the NUH-003 UFSAR. Hence, the proposed amendment has no effect on the ability of the Cask System to perform its design function nor would it increase the likelihood of an accident previously evaluated. The proposed amendment would not increase the likelihood of the malfunction of any plant SSC.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of a previously evaluated accident.
- 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 amendment does not involve major physical alterations of any facility SSCs or Cask System components required to mitigate or prevent any accident previously evaluated, and does not have a significant effect on the capability of any facility SSC or Cask.System component to perform its design functions. Minor modifications are associated with this proposed amendment (e.g. changes to the Security Control Point building.) The pro~osed license amendmerit would not physically change any SSCs involved in the mitigation of any postulated accident. Thus, no new initiators or precursors of new or different kind of accident are created. Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment failures. The credible events for the ISFSI remain unchanged.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed changes do not impact facility or ISFSI SSCs, or their 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 changes do not involve a significant reduction in a margin of safety.
Based on the above, NEDA concludes that the proposed amendment presents no 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.
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Enclosure 1 Page 6 of6 SAFEGUARDS INFORMATION 4.4
- Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
- 5. ENVIRONMENTAL CONSIDERATION DAEC has evaluated this proposed license amendment against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. NEDA has determined that this proposed license amendment meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(12). The proposed amendment is being submitted under the provisions of 10 CFR Part 50 for approval of a safeguards plan and changes to the DAEC Facility License, and in accordance with 10 CFR Part 72. Activities associated with the proposed amendment do not involve any significant construction impacts, and are consistent with a reduction in the security area that focuses primarily on the storage of spent fuel, described in NUREG-0586, "Generic Environmental Impact Statement on Decommissioning of Nuclear Faculties," as a general activity expected to occur during decommissioning. The propqsed amendment is confined to (i) organizational and procedural matters; (ii) modifications to systems used for security; and (iii) administrative changes. The modifications associated with the proposed amendment include Security Control Point building, which are for security of the facility in the ISFSI configuration. The proposed amendment addresses security organizational changes and describes
. procedural and other administrative changes.
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with the issuance of this amendment.
. 6. REFERENCES
- 1. Letter from 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).
2~ Letter from P. Hansen (NextEra Energy Duane Arn.old, LLC) to USN RC, "Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report," NG-21-0004, dated February 5, 2021 (ML21036A160)
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arriold, LLC SI-21-005, Attachment1 to Enclosure 1 Page 1 of2 SAFEGUARDS INFORMATION License Amendment Request (TSCR-191)
Attachment 1 Facility License (Mark-up)
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Attachment 1 to Enclosure 1 Page 2 of2 SAFEGUARDS INFORMATION and safeguards contingency plans including amendmerris made pursuant to m CFR 72.212(b}(9)pf6'tislons of the Mfseellsnee1:1sAmCfldments ru;d Sear-eh Req1:1iremeflts revisiens te 10 GFR 73.55 {51 FR 27B17aml 27822;andtotl1eauthority of 10 CFR5O.9O and 10 CFR 50.54(p}. The combined set of plans, whlch contains Safeguards Information protected under 10 CFR 73.21, is entilled: ~ouane Arnold Energy Center Physical Security Plan," submitted by letter dated May 1§, 2QOl.t June 3, 2021.
(6) Deleted (7) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 279, are hereby incorporated into thfs 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 Ucerise Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas: *
(a) Fire fighting response strategy with the following elements:
- 1. Pre-defined coordinated fire response strategy and guidance
- 2. Assessment of mutual aid fire fighting assets
- 3. Designated staging areas for equipment and materials
- 4. Command and control
- 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
- 1. Protection and use of personnel assets
- 2. Communications *
- 3. Minimizing fire spread
- 4. Procedures for Implementing integrated fire re.sponse strategy
- 5. Identification of readily-available pre-staged equipment
- 6. Training on integrated fire response strategy
- 7. Spent fuel pool mitigation measures (c) Actions to minimize release to lnciude consideration of:
- 1. Water spray scrubbing
- 2. Dose to onsite responders (10) Deleted Renewed License No. DPR-49 Amendment No.~
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC SI~21-005, Attachment 2 to Enclosure 1 Page 1 of 2 SAFEGUARDS INFORMATION
, License Amendment Request (TSCR-191)
Attachment 2 Facility License (Clean-typed)
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2.
NextEra Energy Duane Arnold, LLC SI-21-005, Attachment 2 to Enclosure 1 Page 2 of 2 SAFEGUARDS INFORMATION and safeguards contingency plans including amendments made pursuant to 10 CFR 72.212(b)(9) 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 enfflied: "Duane Arnold Energy Center Physical Security Plan,"'
submitted by letter dated June 3, 2021.
{6) Deleted (7) Additional Conditions
- The Additional Conditions contained in Appendix B, as revised through Amendment No. 279, are hereby Jncorporated into this license. Nexl:Era Energy Duane Arnold, LLC shall operate tile facility in accordance with the Addruonal Conditions.
(8) The licensee is authorized to revise the Updated Final Safety Anawsis Report by deleting the footnote for Section 9 .1.4.4.5 which states: "'"The NIRC 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 strategies for addressing large fires a111dl expfosi,ons and that include the foi!OWing key areas:
{a} Fire fi.111htin:!ll response strategy with the following elements:
- 1. Pre-defined coordinated fire respons~ strategy and guidance
- 2. Assessment of mutual aid fire fighting assets
- 3. Des~nated staging areas for equipment and materials
- 4. Command and control *
- 5. Training of response personnel (b) Operations to mitigate fuel damage considering the follmving:
- 1. Protection and use of personnel-assets
- 2. Communications
- 3. Minimizing fire spread
- 4. Procedures for implementing integrated fire response strategy
- 5. Identification of readily-available pre-staged equipment
- 6. Training on fnt09rated fire response strategy
- 7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
- 1. Water spray scrubbing
- 2. Dose to onsite responders (1.0) Deleted Renewed License No. DPR-49 Amendment No.
SAFEGUARDS INFORMATION Enclosure 2 contains Safeguards Information. This page is decontrolled when separated from Enclosure 2. *