DCL-12-048, Day Response to NRC Letter, Request for Information Pursuant to 10 CFR 50.54 (F) Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Dtd 03/12/2012
| ML12131A410 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/09/2012 |
| From: | Halpin E Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| DCL-12-048 | |
| Download: ML12131A410 (9) | |
Text
III Pacific Gas and
~&~ Electric Company Diablo Canyon Power Plant PO. Box 56 Avil a Beach, CA 9342 4 800.545 .6000 May 9,2012 PG&E Letter DCL-12-048 u.s. Nuclear Regulatory Commission 10 CFR 50.54(f)
ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon 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-Ichi Accident." dated March 12,2012
Dear Commissioners and Staff:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued a letter 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-Ichi Accident" (NRC Letter). Enclosure 5 of the NRC Letter contains 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 NRC 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, Pacific Gas and Electric Company (PG&E) proposes to take the alternative course of action described in Enclosure 1 of this letter. The basis of the acceptability of the proposed alternative course of action is provided in Enclosure 2 of this letter.
PG&E is making regulatory commitments (as defined by NEI 99-04) in Enclosure 1 for Communications Items 1-3 and Staffing Items 1-6. There are no revisions to existing regulatory commitments.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway . Comanche Peak. Diablo Canyon
- Palo Verde
- San Onofre. South Texas Project
- Wolf Creek
m I
Document Control Desk May 9,2012
& Page 2 PG&E Letter DCL-12-048 If you have any questions, or require additional information, please contact Mr. Jearl Strickland at (805) 781-9785.
I state under penalty of perjury that the foregoing is true and correct.
Executed on May 9, 2012.
Sincerely, Edward D. Halpin Senior Vice President - Chief Nuclear Officer ckf6/SAPN 50465913-15 Enclosures cc: Diablo Distribution cc/enc: Elmo E. Collins, NRC Region IV Eric J. Leeds, NRC Director, Office of Nuclear Reactor Regulation Michael S. Peck, NRC, Senior Resident Inspector Joseph M. Sebrosky, NRR Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway. Comanche Peak. Diablo Canyon
- Palo Verde
- San Onofre. South Texas Project. Wolf Creek
Enclosure 1 PG&E Letter DCL-12-048 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:
- Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies,
- Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies,
- Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and
- 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 alternating current (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.
Enclosure 1 PG&E Letter DCL-12-048 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 Nuclear Regulatory Commission Near-Term Task Force (NTTF) Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654. Table 8-1, 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]
4 months Provide onsite and augmented staffing assessment prior to the considering functions related to NTTF Recommendation beginnin~ of 4.2. [Phase 2 staffing assessment]
1R19
Enclosure 1 PG&E Letter DCL-12-048 Page 3 of 4 Staffing 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.
3/29/2013 1. Conduct the onsite and augmented staffing assessment:
- a. The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
4 months b. The onsite and augmented staffing assessment prior to the considering functions related to NTTF beginnin~ of Recommendation 4.2. [Phase 2 staffing 1R19 assessment]
4/30/2013 2. A schedule of the time needed to implement changes will be provided as follows:
- a. Those associated with the Phase 1 staffing assessment.
4 months b. Those associated with the Phase 2 staffing prior to the assessment.
beginnin~ of 1R19 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.
5 6/11/2012 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
Enclosure 1 PG&E Letter DCL-12-048 Page 4 of 4 Staffing Estimated Request Completion Requested Information Date 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.
4 months Those associated with the Phase 2 staffing assessment.
prior to the beginnin~ of 1R19 1 Unit 1 nineteenth refueling outage (1 R19) is currently scheduled to begin Fall 2015.
2 Dependent on submittal date for Staffing Information Request #1
Enclosure 2 PG&E Letter DCL-12-048 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 Nuclear Regulatory Commission (NRC) staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of Pacific Gas and Electric Company's (PG&E's) actions necessary to comply with the Final Emergency Preparedness (EP) Rule issued on November 23,2011 (76 Fed. Reg. 72,560). The proposed alternative timing is warranted as many of PG&E's staff resources necessary for performing the communications assessment are the same resources involved in implementing the 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 1 of this letter, a 2-phase approach, which is summarized below, will be used to respond to the information requests associated with Staffing.
Phase 1 Staffing Assessment Phase 2 Staffing Assessment (for functions except those Plant Type (for functions related to NTTF related to NTTF Recommendation 4.2)
Recommendation 4.2)
Multi-unit plants
- Perform staffing Perform staffing assessment as assessment and implement requested by 50.54(f) letter actions as required by using NEI 12-01; provide recent EP Rule using ISG results per Enclosure 1 of this and NEI 10-05 letter
- Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01 and material from NEI 10-05; provide results per Enclosure 1 of this letter
Enclosure 2 PG&E Letter DCL-12-048 Page 2 of 3 The basis for this approach is discussed below.
- For Diablo Canyon Power Plant (DCPP), a dual-unit plant, the Phase 1 staffing assessment will be performed by March 29, 2013, and submitted to the NRC by April 30, 2013. The Phase 1 staffing assessment will consider all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. A staffing assessment considering these functions will be performed in Phase 2.
The timing of the Phase 1 staffing assessment reflects the higher priority placed by the staff, and approved by the Commission is 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, PG&E will perform the Phase 1 staffing assessment associated with the NRC Letter. Based on staffing analysis experience to date, PG&E anticipates that a DCPP dual-unit staffing analysis will require approximately 3 months to complete and validate.
One additional month is required for submitting the Phase 1 staffing assessment to the NRC.
As requested, PG&E will include an implementation schedule for any modifications that are determined to be appropriate with the Phase 1 staffing assessment.
- The Phase 2 staffing assessment will be completed and submitted to the NRC 4 months prior to the Unit 1 nineteenth refueling outage (1R19). 1R19 is currently scheduled to begin Fall 2015. The Phase 2 staffing assessment will consider the requested functions related to NTTF Recommendation 4.2.
PG&E will be responding to multiple regulatory actions resulting from the recommendations contained in the NTTF Report, as modified in related Commission Papers and Staff Requirements Memoranda. One of these actions, in particular, has the potential to impact emergency response staffing levels. This action is associated with NTTF Recommendation 4.2 and subsequently issued as NRC Order to Modifying 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.
Enclosure 2 PG&E Letter DCL-12-048 Page 3 of 3 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 compJying with this Order will be contained in final Interim Staff Guidance (lSG) scheduled to be issued by the NRC in August 2012.
In response to the Order, PG&E 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.
Once the DCPP-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, PG&E will provide an assessment of the staffing for functions related to NTTF Recommendation 4.2 four months prior to 1R19 (i.e., the first "second refueling outage") as used within the context of NRC Order EA-12-049. 1R19 is currently scheduled to begin Fall 2015.
As requested, PG&E will include an implementation schedule for any modifications that are determined to be appropriate with the Phase 2 staffing assessment.
The Phase 2 staffing assessment is one component of an overall licensee work plan necessary to implement the requirements of the Order. PG&E, as stated in the Order, " ... shall complete full implementation no later than two 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."