AEP-NRC-2012-34, Day Response to NRC Letter, Request for Information Pursuant to Title 10 of Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, & 9.3, of Near-Term Task Force Review of Insights from Fukushima..
| ML12142A110 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 05/11/2012 |
| From: | Gebbie J Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2012-34 | |
| Download: ML12142A110 (18) | |
Text
INDIANA MICHIGAN Indiana Michigan Power B10WER0 One Cook Place Bridgman, MI 49106 A unit of American Electric Power Indiana MichiganPower.com May 11,2012 AEP-NRC-2012-34 10 CFR 50.54(f) 10 CFR 50.4 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Donald C. Cook Nuclear Plant Units 1 and 2 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident; dated March 12, 2012
Reference:
Letter from E. J. Leeds and M. R. Johnson, U. S. Nuclear Regulatory Commission to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident;" dated March 12, 2012. Agencywide Documents Access and Management System (ADAMS) Accession Number ML12053A340 On March 12, 2012, the NRC staff issued a letter to Indiana Michigan Power Company (I&M),
licensee for the Donald C. Cook Nuclear Power Plant (CNP), Units 1 and 2, entitled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident." Enclosure 5 of the letter contained specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days.
The letter states that if an addressee cannot meet the requested response date, then the addressee must provide a response within 60 days of the date of the letter and describe the alternative course of action that it proposes to take, including the basis of the acceptability of the proposed alternative course of action and estimated completion date. After a careful review of the requested actions and information, we propose to take the alternative course of action described in Enclosure 2 of this letter. The basis for our proposal is explained in Enclosure 3.
U.S. Nuclear Regulatory Commission AEP-NRC-2012-34 Page 2 of this letter provides an affirmation. Newly created regulatory commitments are summarized in Enclosure 4.
Should you have any questions, please contact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.
Sincerely, Joel P. Gebbie Site Vice President MCS/jmr : Affirmation : Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request : Basis for Proposed Alternative Course of Action for Responding to EP Requested Information : Regulatory Commitments
U.S. Nuclear Regulatory Commission AEP-NRC-2012-34 Page 3 c: J. T. King - MPSC, w/o enclosures S. M. Krawec - AEP Ft. Wayne, w/o enclosures MDEQ - RMD/RPS, w/o enclosures NRC Resident Inspector C. D. Pederson - NRC Region III P. K. Tam - NRC Washington, DC to AEP-NRC-2012-34 AFFIRMATION AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.
Indiana Michigan Power Company Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME DANIELLE BURGOYNE THIS \DAY OF 0 ,2012 Notary Public, State of Michigan County of Berrien My Commission Expires 0_14-2018
_...Z,....- No61ý ublic \ Acting In the County of*4.[
My Commission Expires __________
\N +,
Enclosure 2 to AEP-NRC-2012-34 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request to AEP-NRC-2012-34 Page 1 of 4 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Communications Estimated Request # Completion Requested Information Date 1 10/31/2012 Provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event meeting the conditions described. The assessment should:
a Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, 0 Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, 0 Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and M Provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all AC power 2 6/11/2012 Describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.
3 Two dates Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
9/28/2012 Conduct the communications assessment.
10/31/2012 Provide an implementation schedule of the time needed to implement the results of the communications assessment.
to AEP-NRC-2012-34 Page 2 of 4 Staffing Estimated Request # Completion Requested Information Date 1 Two dates Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described. This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:
- How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NTTF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1 such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.
- New staff or functions identified as a result of the assessment.
- Collateral duties (personnel not being prevented from timely performance of their assigned functions).
4/30/2013 Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
5/23/2014 Provide onsite and augmented staffing assessment considering
[4 months functions related to NTTF Recommendation 4.2. [Phase 2 staffing prior to assessment]
beginning of second
- As used within the context of NRC Order EA-12-049. The U1C25 refueling refueling outage is considered to be the first refueling outage as it outage*] immediately follows submission of the overall integrated plan on February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.
to AEP-NRC-2012-34 Page 3 of 4 Estimated Request # Completion Requested Information Date 2 Four dates Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.
- 1. Conduct the onsite and augmented staffing assessment:
3/29/2013 The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
4/23/2014 The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- 2. A schedule of the time to needed to implement changes will be provided as follows:
4/30/2013 Those associated with the Phase 1 staffing assessment.
5/23/2014 Those associated with the Phase 2 staffing assessment.
[4 months prior to beginning of second
- As used within the context of NRC Order EA-12-049. The refueling outage*] U1C25 refueling outage is considered to be the first refueling outage as it immediately follows submission of the overall integrated plan on February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.
3 6/11/2012 Identify how the augmented staff would be notified given degraded communications capabilities.
4 6/11/2012 Identify the methods of access (e.g., roadways, navigable bodies of water and dockage, airlift, etc.) to the site that are expected to be available after a widespread large scale natural event.
to AEP-NRC-2012-34 Page 4 of 4 Estimated Request # Completion Requested Information Date 5 6/11/2012 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
6 Two dates Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.).
Changes will be identified as follows:
4/30/2013 Those associated with the Phase 1 staffing assessment.
5/23/2014 Those associated with the Phase 2 staffing assessment.
[4 months prior to beginning of second
- As used within the context of NRC Order EA-12-049. The refueling outage*] U1C25 refueling outage is considered to be the first refueling outage as it immediately follows submission of the overall integrated plan on February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.
Enclosure 3 to AEP-NRC-2012-34 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information to AEP-NRC-2012-34 Page 1 of 3 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information Communications There are two separate responses to the information requests related to communications. The alternative timing of responses to requests #1 and #3 proposed in this letter reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 2011 (76 Fed. Reg. 72,560). The proposed alternative timing is warranted as many of the licensee staff resources necessary for performing the communications assessment are the same resources involved in implementing new EP Rule requirements, responding to Institute of Nuclear Power Operations (INPO) initiatives related to enhancing communications capabilities (e.g., IER 11-4), and maintaining existing EP communications equipment.
In addition, the estimated completion date assigned to information request #3 will promote alignment between the out-year budgeting/funding of future enhancements, and the development of an accurate and complete enhancement implementation schedule.
Staffing As presented in Enclosure 2 of this letter, a 2-phase approach will be used to respond to the information requests associated with Staffing. The table below summarizes this approach.
Phase 1 Staffing Assessment Phase 2 Staffing Assessment Plant Type (for functions except those related (for functions related to NTTF to NTTF Recommendation 4.2) Recommendation 4.2)
Multi-unit plants o Perform staffing assessment Perform staffing assessment as and implement actions as requested by 50.54(f) letter using required by recent EP Rule NEI 12-01; provide results per using ISG and NEI 10-05 Enclosure 1 of this letter o Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01 and material from NEI 10-05; provide results per Enclosure 2 of this letter The basis for this approach is discussed below.
For multi-unit plants, the Phase 1 staffing assessment will be performed by March 29, 2013, and provided by April 30, 2013. This assessment will consider all requested functions except those related to Fukushima Near-Term Task Force (NTTF)
Recommendation 4.2. An assessment considering these functions will be performed in Phase 2.
to AEP-NRC-2012-34 Page 2 of 3 The timing of the Phase 1 staffing assessment reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 2011 (76 Fed. Reg. 72,560). In particular,Section IV.A.9 of 10 CFR 50, Appendix E, requires that licensees complete a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. As stated in the EP Rule, this analysis must be completed by December 24, 2012.
Following completion of EP Rule staffing analysis, the staffing assessment associated with the NRC Letter will be performed. Based on staffing analysis experience to date, it is anticipated that a multi-unit staffing analysis will require approximately 3 months to complete and validate. One additional month is allotted for processing of an assessment submittal package.
As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 1 staffing assessment.
The Phase 2 staffing assessment will be prepared by April 23, 2014 and provided by May 23, 2014. This assessment will consider the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.
The industry will be responding to multiple regulatory actions resulting from the recommendations contained in the Fukushima NTTF Report, as modified in related Commission Papers (SECY's) and Staff Requirements Memoranda (SRM). One of these actions, in particular, has the potential to impact emergency response staffing levels. This action is associated with Fukushima NTTF Recommendation 4.2 and subsequently issued as NRC Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events EA-12-049 [the Order].
A summary of the Order is provided below.
This Order requires a three-phase approach for mitigating beyond-design-basis external events. The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment and spent fuel pool (SFP) cooling. The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.
Additional details on an acceptable approach for complying with this Order will be contained in final Interim Staff Guidance (ISG) scheduled to be issued by the NRC in August 2012.
In response to the Order, each licensee must develop new strategies for mitigating beyond-design-basis external events. To ensure accurate results, the staffing assessment for response functions related to NTTF Recommendation 4.2 must be based on the actions delineated in procedures and guidelines developed in response to the Order.
to AEP-NRC-2012-34 Page 3 of 3 Once the site-specific actions associated with the new response strategies are defined (e.g., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.
Based on a review of the planned actions necessary to comply with the Order, an assessment of the staffing for the functions related to NTTF Recommendation 4.2 will be provided by 4 months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage") as used within the context of NRC Order EA-12-049.
As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 2 staffing assessment.
The Phase 2 staffing assessment is one component of the overall work plan necessary to implement the requirements of the Order. I&M, as stated in the Order, "...shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31, 2016, whichever comes first." "Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies."
to AEP-NRC-2012-34 Regulatory Commitments to AEP-NRC-2012-34 Page 1 of 4 Regulatory Commitments The following table identifies those actions committed to by Indiana Michigan Power Company (I&M) in this document. Any other actions described in this submittal represent intended or planned actions by I&M. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.
Commitment Date Communications Request #1 Provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event meeting the conditions described. The assessment should:
- Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, 10/31/2012
- Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, 0 Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and 0 Provide a description of how the new and/or improved systems and power supplies will be able to provide for communications durina a loss of all AC Dower Communications Request #2 Describe any interim actions that have been taken or are planned to be 6/11/2012 taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.
Communications Request #3 Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
Conduct the communications assessment. 9/28/2012 Provide an implementation schedule of the time needed to implement 10/31/2012 the results of the communications assessment to AEP-NRC-2012-34 Page 2 of 4 Commitment Date Staffing Request #1 Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described. This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:
" How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NTTF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1 such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.
- New staff or functions identified as a result of the assessment.
- Collateral duties (personnel not being prevented from timely performance of their assigned functions).
Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4/30/2013 4.2. [Phase 1 staffing assessment]
Provide onsite and augmented staffing assessment considering 5/23/2014 functions related to NTTF Recommendation 4.2. [Phase 2 staffing [4 months prior to assessment] beginning of second refueling outage*]
- As used within the context of NRC Order EA-12-049. The U1C25 refueling outage is considered to be the first refueling outage as it immediately follows submission of the overall integrated plan on February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.
to AEP-NRC-2012-34 Page 3 of 4 Commitment Date Staffing Request #2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.
- 1. Conduct the onsite and augmented staffing assessment:
The onsite and augmented staffing assessment considering all 3/29/2013 requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
The onsite and augmented staffing assessment considering functions 4/23/2014 related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- 2. A schedule of the time to needed to implement changes will be provided as follows:
Those associated with the Phase 1 staffing assessment. 4/30/2013 Those associated with the Phase 2 staffing assessment. 5/23/2014
- As used within the context of NRC Order EA-12-049. The U1C25 [4 months prior to refueling outage is considered to be the first refueling outage as it beginning of second immediately follows submission of the overall integrated plan on refueling outage*]
February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.
Staffing Request #3 Identify how the augmented staff would be notified given degraded 6/11/2012 communications capabilities.
Staffing Request #4 Identify the methods of access (e.g., roadways, navigable bodies of 6/11/2012 water and dockage, airlift, etc.) to the site that are expected to be available after a widespread large scale natural event.
Staffing Request #5 Identify any interim actions that have been taken or are planned prior 6/11/2012 to the completion of the staffing assessment.
to AEP-NRC-2012-34 Page 4 of 4 Commitment Date Staffing Request #6 Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.). Changes will be identified as follows:
Those associated with the Phase 1 staffing assessment. 4/30/2013 Those associated with the Phase 2 staffing assessment. 5/23/2014
- As used within the context of NRC Order EA-12-049. The U1C25 [4 months prior to refueling outage is considered to be the first refueling outage as it beginning of second immediately follows submission of the overall integrated plan on refueling outage*]
February 28, 2013. U1C26, the second refueling outage, is currently scheduled to start on September 23, 2014.