ML071970002

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Conforming License Amendments to Incorporate the Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (Tac Nos. MD4710 and MD4711)
ML071970002
Person / Time
Site: Mcguire, McGuire  Duke Energy icon.png
Issue date: 07/26/2007
From: Stang J
NRC/NRR/ADRO/DORL/LPLII-1
To: Gordon Peterson
Duke Power Co
Stang, JF, NRR/DLPM/LPD III-1, 415-1345
Shared Package
ML071970001 List:
References
EA-02-026, TAC MD4710, TAC MD4711
Download: ML071970002 (18)
v • d • e


Text

DITIOU.... LUE :iiL: OEUUflIT. flEJTU II UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 26, 2007 Mr. G. R. Peterson Vice President McGuire Nuclear Station Duke Power Company LLC 12700 Hagers Ferry Road Huntersville, NC 28078

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 - CONFORMING LICENSE AMENDMENTS TO INCORPORATE THE MITIGATION STRATEGIES REQUIRED BY SECTION B.5.b. OF COMMISSION ORDER-EA-02-026 (TAC NOS. MD471 0 AND MD471 1)

Dear Mr. Peterson:

This letter documents the results of the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Duke Power Company LLC' for the McGuire Nuclear Station, Units 1 and 2, in response to Section B.5.b. of the February 25, 2002, Interim Compensatory Measures (ICM) Order (EA-02-026) and related NRC guidance.

The ICM Order was issued following the events of September 11, 2001, as part of a comprehensive effort by the NRC, in coordination with other government agencies, to improve the capabilities of commercial nuclear reactor facilities to, respond to terrorist threats.

Section B.5.b. Of the Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that could be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire, including those that an aircraft impact'might create. Although it was recognized prior toSeptember 11, 2001, that nuclear reactors already had significant capabilities to withstand a broad range of attacks, implementing these mitigation strategies would significantly enhance the plants' capabilities to withstand a broad range -of threats. It should be noted that portions of the ICM Order, as well as other documents referenced in this letter, contain security-related or safeguards information, and are not publicly available.

Licensee actions to implement Section B.5.b mitigation strategies have been ongoing since the issuance of the 2002 ICM Order. In 2005, the NRC issued 'guidance to more fully describe the NRC staff's expectations for implementing Section B.5.b of the ICM Order. The NRC guidance relied upon lessons learned from detailed NRC engineering studies and. industry best practices.

Additionally, the NRC conducted two on-site team assessments at each reactor facility that identified additional mitigating strategies for preservation of core cooling, containment integrity, and spent fuel pool cooling.. In total, these efforts have added defense in depth through the'use of additional equipment and strategies. Moreover, these enhancements that have strengthened the interface between plant safety and security operations'now'include fire-fighting -response strategies; plant operations to mitigate fuel damage; and actions to minimize releases.

NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this letter and Enclosures 1 and 2 are DECONTROLLED.

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ornoi.~z ~or or": nrw~nrn' nr T-r irrtrrnm -~r G. R. Peterson The enclosed Safety Evaluation'(SE) details the interactions between the NRC staff and the Duke Power Company LLC, as well as the rest of the nuclear'industry, related to the final, resolution of Section B.5.b. Of the ICM Order.

The NRC is incorporating requirements for the B.5.b mitigating strategies into the Facility Operating Licenses. This letter, therefore, also transmits the license condition that captures the ICM Order Section B.5.b mitigation strategy requirements and incorporates them into the licensing basis.

This proposed:license condition was transmitted by the NRC to the Duke Power, Company LLC in a letter dated October 12, 2006. By letter dated February 23, 2007, the Duke Power Company LLC informed the NRC staff that it would accept the proposed license condition, with a minor change that the NRC staff finds acceptable. The effectiveness of the licensee's actions to implement the mitigative strategies contained in this license condition will be subject to future NRC review and inspection.

Consistent with the Order, administrative license changes to Renewed Facility Operating Licenses NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2, respectively, are being made to incorporate the agreed upon license condition. These changes comply with the standards and requirements of the Atomic Energy Act of 1954, as amended, and the Commission's rules and regulations set forth, in Title 10 of the Code of FederalRegulations (10 CFR) Chapter I. Please replace the affected pages of:the Renewed Facility Operating

'Licenses with.the enclosed pages (Enclosure 1).

  • The attachments to the SE are designated exempt from public disclosure under 10 CFR 2.390(d)(1) since they contain security-related information and are, Official Use Only.

If you have any questions, please contact me at (301) 415-1345.

Sincerely h~n StangSenio roject Manager Plant Licensing Branch I1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370

Enclosures:

1. Revised Pages of Renewed Facility Operating Licenses NPF-9 and NPF-17
2. Safety Evaluation cc w/o atts to Encl. 2: See.next page n-rini- ~fli nr~ V fl~0LfllTV flEV.TEE i:r:~::.

McGuire Nuclear Station, Units1 & 2 cc w/o atts to Encl. 2:

Vice President Manager McGuire Nuclear Station Nuclear Regulatory Issues &

Duke Power Company, LLC Industry Affairs 12700 Hagers Ferry Road Duke Energy Corporation Huntersville, NC 28078 526 S. Church St.

Mail Stop EC05P Associate General Counsel and Managing Charlotte, NC 28202 Attorney Duke Energy Carolinas, LLC Division of Radiation Protection.

526 South Church Street - EC07H NC Dept of Environment, Health & Natural Charlotte, North Carolina 28202 Resources 3825 Barrett Dr.

County Manager of Mecklenburg County, Raleigh, NC 27609-7721 720 E. Fourth St.

Charlotte, NC 28202 Owners Group (NCEMC)

Duke Energy Corporation Regulatory Compliance Manager 4800 Concord Road Duke Energy Corporation York, SC 29745 McGuire Nuclear Site 12700 Hagers Ferry Road Group Vice President, Nuclear Generation

.Huntersville, NC 28078 & Chief Nuclear Officer P.O. Box 1006-EC07H Senior Resident Inspector Charlotte, NC 28201-1006 U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Senior Counsel Huntersville, NC .28078 Duke Energy Carolinas, LLC 526 South Church Street - EC07H Mecklenburg County Charlotte, NC 28202 Department of Environmental Protection 700 N. Tryon St Charlotte, NC 28202 Vice President Customer Relations and Sales Westinghouse. Electric Company 6000 Fairview Road, 12th Floor Charlotte, NC 28210 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713 Assistant Attorney General NC Department of Justice P 0. Box 629 Raleigh, NC 27602

ENCLOSURE1 REVISED PAGES OF RENEWED FACILITY OPERATING LICENSE NPF-9 and NPF-17 DOCKET NOS. 50-369 AND 50-370 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 Replace the following pages of the Facility Operating Licenses. The revised pages are identified by the date of the letter issuing these pages and contain marginal lines indicating the areas of change.

REMOVE INSERT License NPF-9 License NPF-9 Page 4 Page 4 Page 4a License NPF-17 License NPF-17 Page 4 Page4 Page 5 Page 5

(4) Fire Protection Program Duke Power Company LLC shall implement and maintain in effect a'll provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SER dated March 1978 and Supplements 2, 5 and 6 dated March 1979, April 1981, and February 1983, respectively, and the safety evaluation dated May 15, 1989, subject to the following provision:

Duke may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(5) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 200, are hereby incorporated into this renewed operating license. Duke Power Company LLC shall operate the facility in accordance with the Additional Conditions.

(6) Antitrust Conditions The licensee shall comply with the antitrust conditions delineated in Appendix C of this renewed operating license.

(7) Mitigation Strategy License 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 response 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 include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders Renewed License No. NPF-9 Amendment No. 233 Revised by letter dated July 26, 2007

-4A-D. Physical Protection Duke Power Company LLC shall fully implement and maintain in effect all provisionsof the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains safeguards information protected under 10 CFR 73.21, is entitled: "Duke Energy Physical Security Plan" submitted by letter dated September 8, 2004, and supplemented on September 30, 2004, October 15, 2004, October 21, 2004, and October 27, 2004.

E. Deleted by Amendment No. 233.

.Renewed License No. NPF-9 Amendment No. 233 Revised by~letter dated July 26, 2007

(4) Fire Protection Program Duke Power Company LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SER dated March 1978 and Supplements 2,5, and 6 dated March 1979, April 1981, and February 1983, respectively, iand the safety evaluation dated May 15, 1989, subject to the following provisions:

The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect theability to achieve and maintain safe shutdown in the event of a fire.

(5) Protection of the Environment Before engaging in additional construction or operational activities which may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in the Final Environmental Statement dated April 1976, the licensee shall provide written notification to the Office of Nuclear Reactor Regulation.

(6) Additional Conditions The Additional Conditions contained in Appendix B, as revised through Amendment No. 181, are hereby incorporated. into this renewed operating license. Duke Power Company LLC shall operate the facility in accordance with the Additional Conditions.

(7) Antitrust Conditions The licensee shall comply with the antitrust conditions delineated in Appendix C of this renewed operating license.

(8) Mitigation Strategy License 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 Renewed License No. NPF-17 Amendment No. 214 Revised by letter dated July 26, 2007
4. Procedures for implementing integrated fire response 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 include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders D. Physical Protection Duke Power Company LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains safeguards information protected under 10 CFR 73.21, is entitled:

"Duke Energy Physical Security Plan" submitted by letter dated September 8, 2004,' and supplemented on September 30, 2004, October 15, 2004, October 21, 2004, and October 27, 2004.

E. Deleted by Amendment No. 215.

F. The licensee shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

'G. In accordance with the Commission's direction in its Statement of Policy, Licensing and Regulatory Policy and Procedures for Environmental Protection:

Uranium Fuel Cycle Impacts, October 29, 1982, this renewed operating license is subject to the final resolution of the pending litigation involving Table S-3. See, Natural Resources Defense Council v. NRC, No. 74-1586 (D.C. cir. April 27, 1982).

H. The licensee is authorized to receive from the Oconee Nuclear Station, Units 1, 2, and 3, possess, and store irradiated Oconee fuel assemblies containing special nuclear material, enriched to not more than 3.24% by weight U-235 subject to the following conditions:

a. Oconee fuel assemblies may not be placed in the McGuire Nuclear Station, Unit 1 and 2, reactors.
b. Irradiated fuel shipped to McGuire Nuclear Station, Units 1 and 2, from Oconee shall have been removed from the Oconee reactor no less than 270 days prior to shipment.

Renewed License No. NPF-17 Amendment No. 215 Revised by letter dated July 26, 2007

~:ui;. UUJ2 Jil?: uE:~nIr flE TflT irirrinrr~it~i UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER NO. EA-02-026 DUKE POWER COMPANY LLC MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-370

1.0 INTRODUCTION

1.1 Purpose The purpose of this Safety Evaluation (SE) is to document the U.S. Nuclear Regulatory Commission (NRC) staff's regulatory assessment of the adequacy of the actions taken by the Duke Power Company LLC (the licensee) in response to the February 25, 2002, Interim Compensatory Measures (ICM) Order and the subsequent NRC letter to licensees dated February 25, 2005, transmitting NRC guidance (Phase 1 guidance document). This SE describes the basis for finding licensee strategies adequate to satisfy the requirements of the ICM Order. This SE also discusses the license condition that satisfactorily captures the mitigation strategy requirements. If the licensee makes future changes to its strategies within its commitment management program, this SE will be useful to the NRC staff in determining if the changed strategies are adequate to meet the license condition. It should be noted that portions of the ICM Order, as well as other documents referenced in this'SE, contain security-related or safeguards information, and are not publicly available.

1.2 Background The February 25, 2002, ICM Order that imposed interim compensatory measures on power reactor licensees required in Section B.5.b, Mitigative Measures, the development of "specific guidance and strategies tomaintain or restore core cooling, containment, and spent fuel pool cooling capabilities using existing or readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of plant due to explosions or fire." These actions were to be implemented by the end of August 2002. Inspections of the implementation of the Section B.5.b requirements were conducted in 2002 and 2003 (Temporary Instruction (TI) 2515/148). The inspections identified large variabilities in scope and depth of the enhancements made by licensees. As a result, the NRC determined that additional guidance and clarification was needed for nuclear power plant licensees.

NOTICE: The attachments to the Safety Evaluation contain Security-Related Information. Upon separation from these attachments, this Safety Evaluation is DECONTROLLED.

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Subsequent to the'conduct of the TI 2515/148 inspections, engineering studies conducted by the NRC Office of Regulatory Research (RES) provided insights into the implementation of mitigation strategies to address the loss of large areas of a plant due to explosions or fire, including those that an aircraft impact might create. The NRC actions resulting from these studies included: (1) inspections of licensee actions that address plant-specific consequences, (2) issuance of advisories that involve processes and protocols for licensee notification of an imminent aircraft threat, and (3) identification of mitigative measures to enhance plant response to explosions or fire.

On November 24, 2004, the NRC issued a letter to licensees providing information on the Commission's phased approach for enhancing reactor mitigative measures and strategies for responding to Section B.5.b of the ICM Order. On February 25, 2005, the NRC issued guidance (Phase 1 guidance document) to describe more fully the NRC staff's expectations for implementing Section B.5.b of the ICM Order. Determination of the specific strategies required to satisfy the Order, elaborated on by the Phase 1 guidance document, was termed Phase 1.

Further information on the Commission's phased approach and its reliance on the Phase 1 guidance document and related workshop was described in an NRC letter to licensees dated January 14, 2005.

The NRC Phase 1 guidance document relied upon lessons learned from recent NRC engineering studies involving plant assessments, as well as industry best practices. This guidance also included the spent fuel pool mitigative measures described in a NRC letter to licensees dated July 29, 2004, "Issuance of Spent Fuel Pool Mitigative Measures." These best practices were identified during the inspections conducted in 2002 and 2003. The Phase 1 guidance document also incorporated industry comments made at two B.5.b-related workshops held on.January 14, 2005, and February 2, 2005.

2.0 REGULATORY EVALUATION

Section B.5.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 existing or readily-available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with loss of large areas of the plant due to explosions or fire. Determination of the specific strategies required to satisfy the Order, elaborated on in the Phase I guidance document, was termed Phase 1.

In order to assure adequate protection of public health and safety and common defense and security, the NRC determined that differences in plant design and configuration warranted independent assessments to verify that the likelihood of damage to the reactor core, containment, and spent fuel pools and the release of radioactivity is low at each nuclear power plant. The Commission directed the NRC staff to conduct site-specific security and safety assessments to further identify enhanced mitigation capabilities. Site-specific assessments of spent fuel pools was deemed Phase 2 and site-specific assessments of reactor core and containments was deemed Phase 3.

The goal of the Phase 2 and 3 mitigation strategy assessments was for the NRC and the licensees to achieve a new level of cognition of safety and security through a comprehensive understanding of the capabilities and limitations of the plants under normal, abnormal, and severe circumstances (from whatever cause). Based on this improved understanding, licensees could take reasonable'steps to strengthen their capabilities and reduce their

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limitations. The NRC expected that safety and security would be well served by further enhancing the licensee's severe accident management strategies for mitigating a wide spectrum of events through the use of readily-available resources and by identifying potential, practicable areas for the use of beyond-readily-available resources.

During 2005, the NRC staff performed inspections (TI 2515/164) to determine licensees' compliance with Section B.5.b of the ICM Order (Phase 1). Subsequent meetings were held with licensees to resolve identified open issues. Confirmatory B.5.b Phase 1 inspections (TI 2515/168) were conducted during the period of June to December 2006. The NRC staff conducted site visits as part of the Phase 2 assessments during 2005. In 2006, the NRC staff observed licensee Phase 3 studies and conducted independent Phase 3 assessments.

On January 24, 2006, the Nuclear Energy Institute (NEI) submitted a letter (M. Fertel to L. Reyes) describing an industry proposal for resolving ("closing") Phase 2 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML060260220). The industry proposed high level functional mitigating strategies for a spectrum of potential scenarios involving spent fuel pools. In a letter to all Holders of Licenses for Operating Power Reactors dated June 21, 2006 (ADAMS Accession No. ML061.670146), the NRC accepted the Phase 2 proposal pending review of site-specific details of its application and implementation.

In arriving at this conclusion, the NRC staff placed significant weight on portions of the proposal that rely on industry commitments to provide beyond-readily-available resources not previously available. These additions will significantly enhance licensees' mitigating strategies capabilities.

.On June 27, 2006, the NEI submitted two letters (M. Fertel to W. Kane). In one of the letters, the NEI proposed a license condition to capture the Section B.5.b requirements and addressed items deferred from Phase 1 to Phase 2 (ADAMS Accession No. ML061790400). The license condition includes 14 items in the same broad categories as the February 25, 2005, Phase 1 guidance document; fire fighting response strategy, plant operations to mitigate fuel damage, and actions to minimize releases. The proposal suggested that the implementing details found to be an acceptable means of meeting the license condition would be treated as commitments, and managed in accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes." In the second letter, the NEI proposed generic strategies for closure of Phase 3 (ADAMS Accession No. ML061860753). The required strategies for all three phases would be covered by the license condition and all implementing details would be managed by NEI 99-04.

The February 25, 2005, Phase 1 guidance document included 34 expectations. Twoof these items were deferred to Phase 2 and seven items (i.e., six expectations and one element of a seventh expectation) were deferred to Phase 3. The NRC staff reached agreement with licensees on the non-deferred items under. Phase 1.

Table 1 provides a cross reference of how the 34 elements of the February 25, 2005, Phase 1 guidance document and Phases 2 and 3 mitigating strategies correspond to the sections of the license condition.

On June 29, 2006, the NRC staff issued a letter to the NEI conditionally accepting its proposed license condition and strategies (ADAMS Accession No. ML061790306). The letter reiterated that mitigation strategies in NEI's proposals that were identified during the Phase 2 and 3 assessments, which utilize reasonable, evident, readily-available resources (as identified in the February 25, 2005, Phase 1 guidance document) are required pursuant to Section B.5.b of the ICM Order. The implementing details of the required strategies will be implemented by commitment and managed in accordance with the NEI commitment management guideline, zrrl3l:.L WI OIiL~ OECUF.IT~ flEL~TED IfJ~~lT1.~Tl~II

NEI 99-04. The NRC staff believes the NEI proposal reasonably justifies excluding from formal regulatory controls those additional strategies identified during the site-specific Phases 2 and 3 assessments that the NRC previously deemed required under Section B.5.b of the ICM Order, but not identified in NEI's proposals. Inherent in this conclusion is recognition of the addition of beyond-readily-available resources included in the proposals. The implementing details of mitigation strategies included in the proposal, including those that utilize beyond-readily-available resources, will be treated as commitments, which will become part of the licensing basis of the plant. Additional strategies identified during site-specific assessments which licensees deem acceptable and valuable to promote diversification and survivability, will be incorporated into licensees' Severe Accident Management Guidelines, Extreme Damage Mitigation Guidelines, or appended to other site implementation guidance. To verify compliance, the NRC staff evaluated the site-specific implementation and documentation of the proposed Phases 2 and 3 mitigating strategies for each U.S. nuclear power plant.

3.0 TECHNICAL EVALUATION

The NRC staff's technical evaluation for strategies identified in Phase 1 of Section B.5.b is found in Appendix A. The NRC staff's technical evaluation for strategies identified in Phases 2 and 3 of Section B.5.b is found in Appendix B.

The Mitigating Strategies Table (MST) is included as Appendix C. The purpose of the MST is to capture, at the functional level, a summary of licensee strategies for compliance with the 34 measures presented in the February 25, 2005, Phase 1 guidance document and to indicate how the 34 items correlate to the 14 items in the license condition.

4.0 REGULATORY COMMITMENTS The implementing details of the mitigating strategies required by the license condition are identified in licensee submittals dated February 23, 2007 (ADAMS Accession No. ML070650415), and May 1, 2007 (ADAMS Accession No. ML071280309). These details will be implemented by commitment and managed in accordance with the NEI commitment management guideline, NEI 99-04. The NRC staff concludes this provides reasonable controls for mitigating strategy implementation and for subsequent evaluation of licensee-identified changes.

Because the 14 items required by the license condition correlate to the 34 items presented in the February 25, 2005, Phase 1 guidance document and the mitigating strategies within NEI's Phase 2 and 3 proposals, and because the implementing details will be managed under NEI 99-04, the NRC staff is satisfied that there will be sufficient controls to ensure that the strategies are adequately maintained.

5.0 CONCLUSION

Based on the NRC staff's review described in Appendices A, B, and C of this SE, the licensee's responses to the February. 25, 2005, Phase 1 guidance document and the spent fuel pool and reactor core and containment mitigating strategy assessments meet the requirements-of Section B.5.b, Mitigative Measures, of the February 25, 2002, [CM Order that imposed interim compensatory measures on power reactor licensees. The NRC staff concludes that full implementation of the licensee's enhancements in the submittals identified in Section 4.0, above, constitutes satisfactory compliance with Section B.5.b and the license condition, and A *.A,l, ..... .. -- .. .. N'"11WriP"

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0risW¶.Vlm -' .4 W.16.d' IT 1,11 -r1.1 f represents reasonable measures to enhance the licensee's effectiveness in maintaining reactor core and spent fuel pool cooling and containment integrity under circumstances involving the loss of large areas. of, the plant due to fires or explosions.

The Commission has concluded, based on the considerations discussed above, that: (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 the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Attachments (Official Use Only - Security-Related Information - ADAMS Accession No. ML071920525):

1. Phase 1 Assessment (Appendix A)
2. Phases 2 and 3 Assessment (Appendix B)
3. Mitigating Strategies Table (Appendix C)

Principal Contributors: David J. Nelson

" Michael K. Webb Nathan T. Sanfilippo Date: July 25, 2007 mrnv urn ni -- nns"rrn' fl~

.- ~... - u~.r; .2i~f:i lIIrErJ.lxTltII Table 1 CROSS.REFERENCE BETWEEN LICENSE CONDITION AND GUIDANCE DOCUMENT ELEMENTS License Condition section Guidance Document Elements A. Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and B.1.b Staging of personnel guidance B.1 .e Outside organization Support B.1.j Treatment of casualties B.1.k Site assembly areas (mass casualties)

B.1 .m Industry best practice - feeding fire protection ring header

2. Assessment of mutual aid fire fighting assets B.1.c Airlifted resources B.1.f Mobilization of fire fighting resources - existing or new MOUs B.1 .g Mobilization of fire fighting resources - coordination with.

other than local mutual aid fire fighting resources (i.e,,

Industrial facilities, large municipal fire departments,

._ airports, and military bases)

-

3. Designated staging areas for equipment and B.1.a Staging of equipment materials B.1.h Controlling emergency response vehicles (includes rad

____monitoring)

4. Command and Control B.1.d Command and control B.1.i Communications enhancements
5. Training of response personnel B.1.1 Training considerations 111010", 10 11111111"N .- i rLs

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B. Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets B.2.a Personnel considerations
2. Communications B.2.b Communications measures
3. Minimizing fire spread B.2.h Compartmentalization of plant areas
4. Procedures for implementing integrated fire response B.2.c Procedures (Included in Phase 3 strategies) strategy B.2.d Evaluation of vulnerable buildings andequipment (Included in Phase 3 strategies)

B.2.e Industry best practice - Containment venting and vessel flooding B.2.f Industry best practice for compensatory function (Included in Phase 3 strategies)

B.2.g Best practice for use of plant equipment B.2.i Best practice involving plant areas potentially affected by fire or explosions (Included in Phase 3 strategies)

B.2.k Best practice for establishing supplemental response capabilities B.2.1 Best practice for establishing supplemental response capabilities

5. Identification of readily-available, pre-staged B.2.g Best practice for use of plant equipment - portable equipment generator and transformer (Included in Phase 3 strategies)

B.2.j Best practice involving reliance on portable and offsite equipment (Included in Phase 3 strategies)

6. Training on integrated fire response strategy B.2.n Training considerations JrrI;Im. U012 )[IL~ OEOUflIT7 flrzTrD IITtrflrPT1~

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7. Spent fuel pool mitigation measures B.2.m.1 Dispersal of Fuel B.2.m.2 Hot fuel over rack feet B.2.m.3 Downcomer area B.2.m.4 Enhanced air circulation (Included in Phase 2 strategies)

B.2.m.5 Emergency pool makeup, leak reduction/repair (Included in Phase 2 strategies)

C. Actions to minimize release to include-considerations of:

1. Water spray scrubbing B.3.a Water spray scrubbing B.3.b Prestaging of equipment
2. Dose to onsite responders B.3.c Dose projection models (Included in Phase 3 strategies)

Pkg ML071970001 (Letter &,Encl 2: ML071970002, Encl 1: ML072050397, Attachments to SE (OUO): ML071920525)

OFFICE NRR/LPLIV/PM NRR/PSPB/LA NRR/DPR/PSPB NRR/LPII-1/PM NRR/PIT 1,/BF NAME MWields Dbaxley, JCB for DNelson JStang EMarinos DATE 7/19/07 7/19/07 7/19/07 7/19/07 7/23/07

Pkg ML071970001/

(Letter & Encl 2: ML071970002, Encl 1: MVL07, Attachments to SE 2OUO*:ML071920525)

OFFICE NRR/' PI IVIP NRRPSPB/'A NRRDP, PSPB NRR ' ',-11,RR NAME MFields* DBaxle y 51% rDN~nn .. JStan(7 EM--*

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DATE 7-' 90 30

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