NextEra Energy Duane Arnold, LLC's, Overall Integrated Plan - NRC

55 Pages·2013·2.32 MB·English

NExTera"
ENERRC
February 28, 2013
NG-1 3-0084
10 CFR 2.202
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555-001
Duane Arnold Energy Center
Docket No. 50-331
Renewed Op. License No. DPR-49
NextEra Energy Duane Arnold, LLC's Overall Integrated Plan in Response to March 12,
2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation
Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
References: 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard
to Requirements for Mitigation Strategies for Beyond-Design-Basis
External Events dated March 12, 2012, Accession No. ML12056A045
2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with
Order EA-12-049, Order Modifying Licenses with Regard to
Requirements for Mitigation Strategies for Beyond-Design-Basis
External events," Revision 0, dated August 29, 2012, Accession No.
ML12229A174
3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX)
Implementation Guide," Revision 0, dated August, 2012, Accession
No. ML12242A378
4. Letter, R. Anderson (NextEra Energy Duane Arnold, LLC) to U.S.
NRC, "NextEra Energy Duane Arnold, LLC's Initial Status Report in
Response to March 12, 2012 Commission Order Modifying Licenses
with Regard to Requirements for Mitigation Strategies for Beyond-
Design-Basis External Events (Order Number EA-12-049)," NG-12-
0426, dated October 29, 2012, Accession No. ML12305A378
On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission")
issued an order (Reference 1) to NextEra Energy Duane Arnold, LLC (hereafter,
NextEra Energy Duane Arnold). Reference 1 was immediately effective and directs
NextEra Energy Duane Arnold to develop, implement, and maintain guidance and
strategies to maintain or restore core cooling, containment, and spent fuel pool cooling
NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324
Document Control Desk
NG-13-0084
Page 2 of 3
capabilities in the event of a beyond-design-basis external event. Specific requirements
are outlined in Attachment 2 of Reference 1.
Reference 1 requires submission of an Overall Integrated Plan by February 28, 2013.
The NRC Interim Staff Guidance (ISG) (Reference 2) was issued August 29, 2012
which endorses industry guidance document NEI 12-06, Revision 0 (Reference 3) with
clarifications and exceptions identified in Reference 2. Reference 3 provides direction
regarding the content of this Overall Integrated Plan.
Reference 4 acknowledged NextEra Energy Duane Arnold's receipt of Reference 2 and
provided the initial status report regarding mitigation strategies, as required by
Reference 1.
The purpose of this letter is to provide the Overall Integrated Plan pursuant to Section
IV, Condition C.1, of Reference 1. This letter confirms NextEra Energy Duane Arnold
has an Overall Integrated Plan developed in accordance with the guidance for defining
and deploying strategies that will enhance the ability to cope with conditions resulting
from beyond-design-basis external events that satisfies the requirements of Reference
1.
The information in the enclosure provides the NextEra Energy Duane Arnold Overall
Integrated Plan for mitigation strategies pursuant to Reference 3. The enclosed Overall
Integrated Plan is based on conceptual design information that is current as of this
letter. As design details and associated procedural guidance are finalized, additional
information, as well as revisions to the information contained in the enclosure to this
letter, will be communicated to the NRC in the 6-month Integrated Plan updates as
required by Reference 1.
This letter contains no new regulatory commitments.
If you have any questions or require additional information, please contact Ken Putnam
at 319-851-7238.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 28, 2013
Richard L. Andersoný
Vice President, Duane Arnold Energy Center
NextEra Energy Duane Arnold, LLC
Enclosure: Duane Arnold Energy Center Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
Document Control Desk
NG-1 3-0084
Page 3 of 3
cc: NRC Regional Administrator (Region Ill)
NRC Resident Inspector (DAEC)
NRC Licensing Project Manager (DAEC)
Enclosure to NG-13-0084
Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
51 Pages to Follow
Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
INDEX
Description Page
Determine Applicable Extreme External Hazards 2
Key Site Assumptions to Implement NEI 12-06 Strategies 3
Extent to which the Guidance, JLD-ISG-2012-01 and NEI 12-06 are being followed 6
Provide Sequence of Events and identify any Time Constraint required for success including 6
the technical basis for the time constraint
Identify how Strategies will be deployed in all modes 9
Provide a Milestone Schedule 10
Identify how Programmatic Controls will be met 10
Describe Training Plan 11
Describe Regional Response Center Plan 11
Maintain Core Cooling-BWR Installed Equipment Phase 1 13
Maintain Core Cooling-BWR Portable Equipment Phase 2 15
Maintain Core Cooling-BWR Portable Equipment Phase 3 19
Maintain Containment-BWR Installed Equipment Phase 1 21
Maintain Containment-BWR Portable Equipment Phase 2 23
Maintain Containment-BWR Portable Equipment Phase 3 25
Maintain Spent Fuel Pool Cooling-BWR Installed Equipment Phase 1 26
Maintain Spent Fuel Pool Cooling-BWR Portable Equipment Phase 2 28
Maintain Spent Fuel Pool Cooling-BWR Portable Equipment Phase 3 30
References 31
Attachment IA: Sequence of Events Timeline 33
Attachment 1B: NSSS Significant Reference Analysis Deviation Table 36
Attachment 2: BWR Portable Equipment Phase 2 37
Attachment 3: BWR Portable Equipment Phase 3 38
Attachment 4: Milestone Schedule 39
Attachment 5: Systems Credited for Core Cooling Baseline Coping 40
Attachment 6: Required Instruments 43
Attachment 7: Injection Point to RPV 45
Attachment 8: Instrument Power Connections 46
Attachment 9: Proposed Location of Storage Facilities 47
Attachment 10: Offsite 4160V AC Connection to an Essential Bus 48
Attachment 11: Spent Fuel pool Vent 49
Attachment 12: Implementation Action Items 50
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Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
1. General Integrated Plan Elements - BWR
Determine Applicable Extreme Input the hazards applicable to the site; seismic, externalf lood,
External Hazards high winds, snow, ice, cold, high tenips.
Describe how NEI 12-06 sections 5 - 9 were applied and the
Ref: NEI 12-06, Section 4 -9 basisf or why the plant screened outf or certain hazards.
JLD-ISG-2012-01, Section 1.0
Duane Arnold Energy Center (DAEC) reactor center line is at
latitude 420 6' 02" N, longitude 910 46' 36" W per UFSAR
2.1 (Reference 18). DAEC used NEI 12-06, Sections 4-9 and
Appendix B to evaluate applicable external hazards. Each of
the five classes of hazards identified applies to the DAEC
site.
Seismic:
* Seismic design of DAEC safety related structures are
discussed in UFSAR Section 3.7 (Reference 1).
* The DAEC UFSAR was reviewed to perform a limited
evaluation of the potential for soil liquefaction as result
of a design bases earthquake. UFSAR Section 2.5.4.5.3
(Reference 2) discusses excavation practices used to
ensure liquefaction will not occur in the building areas.
Based on this no additional evaluations of liquefaction is
planned for FLEX strategies unless storage and transport
paths are over previously un-excavated ground (Action
29).
* Seismic re-evaluations pursuant to the 10 CFR 50.54(f)
letter of March 12, 2012 are not completed and therefore
not assumed in this submittal. As the re-evaluations are
completed, appropriate issues will be entered into the
corrective action process and addressed (Action 1).
External Flooding:
* Design Bases of site includes flooding from the Cedar
River as a result of maximum precipitation. Warning
time of several days exist for flooding of this nature,
UFSAR 3.4 (Reference 3)
" Design Bases flood (el. 764.1' msl) is above plant grade
so FLEX strategies must address deployment with a flood
present.
* Flood re-evaluations pursuant to the 10 CFR 50.54(f)
letter of March 12, 2012 are not completed and therefore
not assumed in this submittal. As the re-evaluations are
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Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
completed, appropriate issues will be entered into the
corrective action process and addressed (Action 2).
Storms with High Winds:
* DAEC plant site is located adjacent to the Cedar River
approximately 2.5 miles northeast of Palo, Iowa
(Reference 43) and is not a coastal site exposed to
hurricanes.
* Regional history with tornadoes exists for the DAEC.
DAEC location falls in Region 1 of Figure 7.2 of NEI 12-
06. This would correspond to a location with a one in a
million probability of tornado winds speeds approaching
200 mph. The DAEC design bases (300 mph) for safety
related structures bounds this value, UFSAR 3.3
(Reference 4).
Snow,Ice and Low Temperatures:
0 Regional experience with snow, ice and low temperatures
exist. From Figure 8.2 of NEI 12-06 DAEC is located in
Region 5 corresponding to the highest region for ice
severity.
High Temperatures:
* Regional experience with high temperatures exists for
DAEC. Environmental design for DAEC electrical
equipment is discussed in UFSAR section 3.11
(Reference 5). The normal environmental service
conditions for areas containing safety related equipment
at DAEC are described in a controlled document, QUAL-
SC101 (Reference 6).
Key Site assumptions to Provide key assumptions associatedw ith implementation of
implement NEI 12-06 FLEX Strategies:
strategies.
All assumptions in NEI 12-06, Section 3.2.1 apply including the
Ref: NEI 12-06, Section 3.2.1 following:
* Prior to the event the reactor has been operating at 100
percent rated thermal power for at least 100 days or has
just been shut down from such a power history as
required by plant procedures in advance of the impending
event.
* At the time of the postulated event, the reactor and
supporting systems are within normal operating ranges
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Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
for pressure, temperature, and water level for the
appropriate plant condition. All plant equipment is either
normally operating or available from the standby state as
described in the plant design and licensing basis.
* Off site personnel resources are assumed to begin
arriving at 6 hours and the site will be fully staffed by 24
hours after the event.
* This plan defines strategies capable of mitigating a
simultaneous loss of all alternating current
(ac) power and loss of normal access to the ultimate heat
sink resulting from a beyond-design-basis event by
providing adequate capability to maintain or restore core
cooling, containment, and SFP cooling capabilities at all
units on a site. Though specific strategies are being
developed, due to the inability to anticipate all possible
scenarios, the strategies are also diverse and flexible to
encompass a wide range of possible conditions. These
pre-planned strategies developed to protect the public
health and safety will be incorporated into the unit
emergency operating procedures in accordance with
established EOP change processes, and their impact to the
design basis capabilities of the unit evaluated under 10
CFR 50.59. The plant Technical Specifications contain
the limiting conditions for normal unit operations to
ensure that design safety features are available to respond
to a design basis accident and direct the required actions
to be taken when"t he limiting conditions are not met. The
result of the beyond-design-basis event may place the
plant in a condition where it cannot comply with certain
Technical Specifications and/or with its Security Plan,
and, as such, may warrant invocation of 10 CFR 50.54(x)
and/or 10 CFR 73.55(p) (Reference 12).
* Recovery of damaged plant equipment is conservatively
excluded from FLEX.
* No specific initiating event is used. The initial condition
is assumed to be a loss of off-site power (LOOP) at a
plant site resulting from an external event that affects the
off-site power system either throughout the grid or at the
plant with no prospect for recovery of off-site power for
an extended period. The LOOP is assumed to affect all
units at a plant site.
* All installed sources of emergency on-site ac power and
SBO Alternate ac power sources are assumed to be not
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Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
available and not imminently recoverable.
" Cooling and makeup water inventories contained in
systems or structures with designs that are robust with
respect to seismic events, floods, and high winds, and
associated missiles are available.
" Normal access to the ultimate heat sink is lost, but the
water inventory in the UHS remains available and robust
piping connecting the U-IS to plant systems remains
intact. The motive force for River Water Supply pumps
is assumed to be lost with no prospect for recovery.
* Fuel for FLEX equipment stored in structures with
designs which are robust with respect to seismic events,
floods and high winds and associated missiles, remains
available.
* Permanent plant equipment that is contained in structures
with designs that are robust with respect to seismic
events, floods, and high winds, and associated missiles,
are available.
* Other equipment, such as portable ac power sources,
portable back up dc power supplies, spare batteries, and
equipment for 50.54(hh)(2), may be used provided it is
reasonably protected from the applicable external
hazards.
" Installed electrical distribution system, including
inverters and battery chargers, remain available provided
they are protected consistent with current station design.
" No additional events or failures are assumed to occur
immediately prior to or during the event, including
security events.
" Equipment designed to withstand external events is
assumed to be available.
" Spent fuel in dry cask storage is outside the scope of
FLEX.
* All boundaries of the SFP are intact, including the liner,
gates, transfer canals, etc.
* Although sloshing may occur during a seismic event, the
initial loss of SFP inventory does not preclude access to
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Duane Arnold Energy Center
Overall Integrated Plan with Regard to
Mitigation Strategies for Beyond-Design-Basis External Events
the refueling deck around the pool.
* SFP cooling system is intact, including attached piping.
* SFP heat load assumes the maximum design basis heat
load for the site.
Extent to which the guidance, Include a descriptiono f any alternatives to the guidance, and
JLD-ISG-2012-01 and NEI 12- provide a milestone schedule ofplanned action.
06, are being followed.
Identify any deviations to JLD- Full compliance with JLD-ISG-2012-01 (Reference 44) and NEI
ISG-2012-01 and NEI 12-06. 12-06 (Reference 45) is expected. Where there are interpretations
of NEI-12-06 or the Interim Staff Guidance requirements, DAEC
Ref: JLD-ISG-2012-01 will follow those interpretations jointly developed by the NRC
NEI 12-06, Section 13.1 and NEI.
Provide a sequence of events r Str-ategies that have a time constraintt o be successful should be
and identify any time identified with a technical basis and ajustificationp rovided that
constraint required for success the time can reasonably be met (for example, a walk through of
including the technical basis deployment).
for the time constraint.
Describe in detail in this section the technical basis for the time
Ref: NEI 12-06, Section 3.2.1.7 constrainti dentified on the sequence of events timeline
JLD-ISG-2012-01, Section 2.1 Attachment ]A.
DAEC Response:
Immediate operator actions for implementation of Phase I FLEX
strategies are consistent with existing immediate actions specified
for DAEC Station Blackout requirements under 10 CFR 50.63.
Initial operator actions are as described in Abnormal Operating
Procedure (AOP) 301.1 (Reference 21) consistent with the
existing Station Blackout analysis described in UFSAR Section
15.3.2 (Reference 8) with the exception that emergency reactor
vessel depressurization will not be performed when the
suppression pool water temperature reaches the Heat Capacity
Temperature Limit as listed in existing Emergency Operating
Procedures (References 22 and 23). Revisions to these
procedures will be made as noted in the Milestone Schedule
(Attachment 4) (Action 3). The timeline for deployment of initial
portable equipment under Phase 2 of the FLEX strategies are
anticipated to be completed within approximately the first 4
hours. Experience with deploying similar equipment/strategies
has shown that this is achievable with the on shift staff
(Reference 24), but this will need to be verified via formal
procedural validation when the final equipment, hookups and
procedures are developed (Action 4).
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