ML14058A105
| ML14058A105 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 03/06/2014 |
| From: | Polickoski J NRC/NRR/MSD |
| To: | James Shea Tennessee Valley Authority |
| Polickoski J, NRR/DPR, 415-5430 | |
| References | |
| EA-12-049, TAC MF0950, TAC MF1177 | |
| Download: ML14058A105 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 6, 2014 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801
SUBJECT:
WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2- PLAN FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES RELATED TO ORDER EA-12-049 (MITIGATING STRATEGIES)
(TAC NOS. MF0950 and MF1177)
Dear Mr. Shea:
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved.
By letter dated February 28, 2013 (ADAMS Accession No. ML13067A030), Tennessee Valley Authority (TVA, the licensee) submitted its OIP for Watts Bar Nuclear Plant, Units 1 and 2 (Watts Bar) in response to Order EA-12-049. By letters dated August*28, 2013, and February 7, 2014 (ADAMS Accession Nos. ML13247A288 and ML14062A050), TVA submitted its first two six-month updates to the OIP.
By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Regulation Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). The purpose of the staff's audit is to determine the extent to which the licensees are proceeding on a path towards successful implementation of the actions needed to achieve full compliance with the order. This audit process led to the issuance of the Watts Bar interim staff evaluation (ISE) and audit report (ADAMS Accession No. ML13343A036) and continues with in-office and on site portions of this audit.
The ongoing audit process, to include the in-office and on site portions, allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation. The audit allows the staff to review open and confirmatory items from the ISE, the licensee's integrated plan, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to a declaration of compliance for the first unit at each site.
J.Shea This document outlines the on-site audit process that continues after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents, and continue in-office audit communications with staff while proceeding towards compliance with the order.
The staff plans to conduct an onsite audit at the Watts Bar in accordance with the enclosed audit plan from March 12-13, 2014.
If you have any questions, please contact me at 301-415-5430 or by e-mail at james.polickoski@ nrc.gov.
Sincerely, r:~-
James Polickoski, Project Manager Project Management Branch Mitigating Strategies Directorate Office of Nuclear Reactor Regulation Docket Nos.: 50-390 and 50-391 Enclosure Audit plan cc w/encl: Distribution via Listserv
Audit Plan Watts Bar Nuclear Plant, Units 1 and 2 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved.
In accordance with the order, the OIPs were submitted by February 2013, and licensees are in the process of implementing the requirements identified in the order. Licensees are required to complete full implementation no later than two refueling cycles after submittal of the OIPs or by December 31 , 2016, whichever comes first.
By letter dated February 28, 2013 (ADAMS Accession No. ML13067A030), Tennessee Valley Authority (TVA, the licensee) submitted its OIP for Watts Bar Nuclear Plant, Units 1 and 2 (Watts Bar) in response to Order EA-12-049. By letters dated August 28, 2013, and February 7, 2014 (ADAMS Accession Nos. ML13247A288 and ML14062A050), TVA submitted its first two six-month updates to the OIP.
By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Regulation Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). The purpose of the staff's audit is to determine the extent to which the licensees are proceeding on a path towards successful implementation of the actions needed to achieve full compliance with the order. This audit process led to the issuance of the Watts Bar interim staff evaluation (ISE) and audit report (ADAMS Accession No. ML13343A036) and continues with in-office and onsite portions of this audit.
The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make an Integrated Plan safety evaluation. The audit allows the staff to review open and confirmatory items from the ISE, the licensee's integrated plan, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to a declaration of compliance for the first unit at each site.
This document outlines the on-site audit process that continues after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents (OPDs), and continue in-office audit communications with staff while proceeding towards compliance with the order.
Enclosure
Following the licensee's declaration of order compliance, the NRC staff will evaluate the OIP as supplemented, the resulting site-specific OPD, and, as appropriate, and other licensee submittals based on the requirements in Order EA-12-049. The staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) developed guidance document NEI 21-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML12242A378), as endorsed by the staff via staff guidance JLD-ISG-2012-01 "Compliance with Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"" (ADAMS Accession No. ML12229A174). Should the licensee propose an alternative strategy to the guidance, as endorsed, for compliance, the staff will evaluate the alternative strategy in reference to the order.
AUDIT SCOPE As discussed, onsite audits will be performed per Office Instruction LIC-111, "Regulatory Audits," to support the development of safety evaluations. Site-specific OIPs and OPDs rely on equipment and procedures that apply to all units at a site, therefore, audits will be planned to support the first unit at each site." On-site audits for subsequent units at a site will be on an as-needed basis.
The purpose of the audits is to obtain and review information responsive to open and/or confirmatory items from the NRC ISE of the Watts Bar OIP, as supplemented, and to observe and gain a better understanding of the basis for the site's overall program to ensure the licensee is on the correct path for compliance with the Mitigating Strategies order. These may include, but are not limited to:
- Onsite review and discussion for the basis and approach for detailed analysis and calculations
- Walk-throughs of strategies and laydown of equipment to assess feasibility, timing, and effectiveness of a given mitigating strategy or integration of several strategies
- Storage, protection, access, and deployment feasibility and practicality for onsite portable equipment
- Evaluation of staging, access, and deployment of offsite resources to include Regional Response Center (RRC) provided equipment NRC AUDIT TEAM Title Team Member Team Lead Carleen Sanders Project Manager James Polickoski Technical Support Matthew McConnell Technical Support Kerby Scales Technical Support Diana Woodyatt
NRC AUDIT TEAM- SUPPLEMENTAL MEMBERS Title Team Member Senior Advisor Eric Bowman Branch Chief Sheena Whaley Process Oversight Victor Cusumano LOGISTICS The audit will be conducted onsite at Watts Bar on March 12-13,2014. Entrance and exit briefings will be held with the licensee at the beginning and end of the audit, respectively, as well as daily briefings of team activities. Additional details will be addressed over the phone. A more detailed schedule is provided below.
A private conference room is requested for NRC audit team use with access to audit documentation upon arrival and as needed.
DELIVERABLES An audit reporVsummary will be issued to the licensee within 45 days from the end of the audit.
INFORMATION NEEDS
- Materials/documentation provided in response to open or confirmatory items in the Watts Bar ISE
- Materials/documentation for staff audit questions and/or licensee OIP identified open items as listed in the Part 2 table below To provide supplemental input to the ongoing audit of documents submitted to the NRC and made available via e-portal, the onsite audit will have three components: 1) a review of the overall mitigating strategies for the site, including, if needed, walk-throughs of strategies and equipment laydown of select portions; 2) a review of material relating to open or confirmatory items from the ISE, staff audit questions, and licensee open items; and 3) additional specific issues requested by NRC technical reviewers related to preparation of a safety evaluation.
Each part is described in more detail below.
Part 1 - Overall Mitigating Strategies and Program Review:
During the onsite audit, please be prepared to conduct a tabletop discussion of the site's integrated mitigating strategies compliance program. This discussion should address the individual components of the plan, as well as the integrated implementation of the strategies including a timeline. The licensee team presenting this should include necessary
representatives from site management, engineering, training, and operations that were responsible for program development, and will be responsible for training and execution.
Following the tabletop discussion, please be prepared to conduct walk-throughs of procedures and demonstrations of equipment as deemed necessary by NRC audit team members. Include representatives from engineering and operations that will be responsible for training and execution. At this time we expect, at a minimum, to walk-through the items below. Based on the tabletop presentations and audit activities, this list may change.
WALK-THROUGH LIST:
- 1. Walk-through a sample of strategies that will be delineated by specific NRC technical staff audit team members
- 2. Walk-through of portable (FLEX) diesel generator (DG) procedures, to include power supply pathways and areas where manual actions are required (ISE open item (01) 3.2.4.8.A, audit question (AQ) 30/49/50)
- 3. Walk-through of building access procedures, to include any unique access control devices
- 4. Strategy walk-through of transfer routes from staging and storage areas for both onsite and offsite equipment
- 5. Strategy walk-through for core cooling, to include portable pumping equipment, flow paths, and water storage locations
- 6. Walk-through of communications enhancements Part 2- Specific Technical Review Items:
During the visit, the following audit items from the Watts Bar ISE (open items (01) and confirmatory items (CI)), Watts Bar audit question list (AQ), and licensee OIP, as supplemented, open items will be addressed. Please provide documents or demonstrations as needed to respond to each item.
Audit Item Reference Item Description ISE 01 3.2.1.6.A- Review the reanalysis to support the timelines.
Sequence of Events AQ 14 ISE CI3.1.1.2.A- Review the Flex Equipment Storage Building design Deployment of FLEX documents/features and verify that deployment of the equipment will Equipment not be impeded by the extended loss of alternating current (ac) power event (ELAP).
ISE Cl 3.1.2.2.A- Review a sample of onsite and offsite portable (FLEX) deployment Deployment of FLEX feasibility. The auditors will select FLEX deployment strategy sample Equipment to validate the timing and location for staging, connecting, and using AQ 4/55 the equipment is feasible. The auditors will communicate the desired
Licensee 01 P 01 2/5 items for the sample on the first day of the audit.
ISE CI3.2.1.7.A- Cold Review the licensee's shutdown risk process and procedures for Shutdown and incorporation of the supplemental guidance provided in the NEI Refueling position paper entitled "Shutdown I Refueling Modes," (ADAMS Accession No. ML13280A650), or plans to provide an equivalent level of safety by alternative means.
ISE Cl 3.2.4.4.A- Review a sample of the communication enhancements documented in Communication the NRC staff analysis (ADAMS Accession No. ML13142A348) of the AQ29 licensee's communications assessment (ADAMS Accession Nos.
ML12311A297 and ML13058A067J ISE Cl 3.2.4.5.A- Confirm the implementation of guidance and strategies for accessing Accessibility protected and locked internal areas during an ELAP through interviews with licensee staff and review of site procedures.
ISE Cl 3.2.4.8.A- Review summary of FLEX DG sizing calculation and manufacturer Electrical data.
AQ45 ISECI Review the strategy's list of portable equipment, the protected storage, 3.1.1.2.A/3.1.4.1.A/ and employment strategy in the various environments.
3.1.5.1 .A - Electrical AQ 9/38 ISE Cis 3.2.4.2.A-D- Review assessment of room temperature and equipment ratings for Electrical operations of installed and portable equipment to include personnel AQ 25/27 habitability.
ISE Cl 3.2.4.9.A - Review fuel management strategy for FLEX equipment and Electrical procedures.
AQ32 Licensee OIP 01 3 ISE Cl 3.2.4.1 O.A- Review battery sizing calculation.
Electrical AQ44 ISE Cl 3.2.4.1 O.A - Review direct current (de) load profile and shedding scheme.
Electrical AQ 42/43 Licensee OIP 01 18 ISE 01 3.2.4.8.A - Review electrical single line diagrams (FLEX DG and electrical supply Electrical pathway).
AQ 30/39 Ventilation Review finalized HVAC calculation MDQ0003602013000272.
Licensee OIP 01 11 Ventilation/Habitability Staff may request a walkthrough of any complex local operator actions AQ27 or actions deemed to be in a harsh environment. The auditors will communicate the desired walkthroughs on the first day of the audit.
Balance of Plant Review atmospheric relief valve operation, protection, and AQ52 accessibility during the ELAP event.
Licensee OIP 01 9 Review functional requirements for each of the Phase 3 strategies equipment and components.
Reactor systems Confirm effectiveness of gravity feed in cooling the reactor coolant
I Licensee 01 P 01 12 I system.
Part 3- Specific Topics for Discussion:
- 1. Draft of Watts Bar OPD
- 2. Regulatory approach in regards to the potential alternative to the NEI guidance related to pre-staged DGs
- 3. Thermo-hydraulic analyses to include a discussion of Modular Accident Analysis Program analysis, timeline analysis related to WCAP-17601-P, and boron mixing
- 4. Training
- 5. Portable (FLEX) equipment maintenance and testing
Proposed Schedule Onsite Day 1, Wednesday, March 12,2014 0800 Check in at site; Badging 0900 Entrance meeting 0930 TVA Presentation 1230 Lunch 1330 NRC Audit Team Activities commence (in parallel):
- Review documents relating to open or confirmatory items, codes, analyses, etc. {1 team members)
- Mitigating Strategies walk-throughs with licensee 1600 Audit Team meeting 1630 Team lead daily debrief with licensee Onsite Day 2, Thursday, March 13, 2014 0800 Check in at site; meet with Senior ResidenVResident 0900 NRC Audit Team Activities:
- Continue review of documents relating to open or confirmatory items, codes, analyses, etc.- if needed
- Continue Mitigating Strategy walk-throughs with licensee 1200 Lunch 1300 Continue NRC Audit Team Activities 1530 Audit Team meeting 1630 NRC/Licensee exit meeting 1700 Audit closeouVdeparture
J.Shea This document outlines the on-site audit process that continues after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents, and continue in-office audit communications with staff while proceeding towards compliance with the order.
The staff plans to conduct an onsite audit at the Watts Bar in accordance with the enclosed audit plan from March 12-13, 2014.
If you have any questions, please contact me at 301-415-5430 or by e-mail at james.polickoski@nrc.gov.
Sincerely,
/RAJ James Polickoski, Project Manager Project Management Branch Mitigating Strategies Directorate Office of Nuclear Reactor Regulation Docket Nos.: 50-390 and 50-391 Enclosure Audit plan cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsRgn2MaiiCenter Resource LPL 1 R/F JPolickoski, NRR/MSD RidsNrrDorllpl 2-2Resource JBowen, NRR/MSD RidsNrrPMWattsBar Resource CSanders, NRR/DIRS RidsNrrLASLent Resource RidsAcrsAcnw_MaiiCTR Resource ADAMS Accession No ML14058A105 OFFICE NRR/DIRSIIPAB/AET NRR/MSD/LA NRR/MSD/MESB/BC NRR/MSD/MRSB/BC NAME CSanders Slent SBailey SWhaley DATE 03/06/2014 03/06/2014 03/06/2014 03/06/2014 OFFICE NRR/MSD/MSPB/BC NRR/MSD/MSPB/PM NAME JBowen (JBoska for) JPolickoski DATE 03/06/2014 03/06/2014 OFFICIAL AGENCY RECORD