L-12-128, FENOC 60-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 and 9.3 of Near-Term Task Force Review Insights from Fukushima Dai-ichi Accident, Ma
| ML12130A416 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Davis Besse, Perry |
| Issue date: | 05/09/2012 |
| From: | Sena P FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-12-128 | |
| Download: ML12130A416 (11) | |
Text
FENOC FirstEnergy Nuclear Operating Company 76 South Main Street Akron, ahio 44308 Peter P. Sqa lll President and Chief Operating Officer May 9, 2012 L-12-128 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 10 cFR 50.54(f)
SUBJECT:
Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334. License No. DPR-66 Docket No. 50-412, License No. NPF-73 Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 FENOC 60-Day Response to NRC Letter, Request for lnformation Pursuant to Title 10 of the Code of Federal Requlafions 50.54(fl Reqardinq Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insiqhts from the Fukushima Dai-ichi Accident.
dated March 12,2012 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-ichiAccident."
Enclosure 5 of the 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 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, FENOC proposes to take the alternative course of action described in Attachment 1 of this letter. The basis for our proposal is explained in Attachment 2.
Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station Perry Nuclear Power Plant L-12-128 Page 2 This letter contains regulatory commitments as listed in Attachment
- 3. Should you have any questions concerning the contents of this letter, please contact Mr. Phil H. Lashley, Supervisor
- Fleet Licensing, at 330-315-6808.
I declare under penalty of perjury that the foregoing is true and correct. Executed on Mav q.2012.
Respectfully, f*14 Peter P. Sena, lll Attachments:
1 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request 2
Basis for Proposed Alternative Course of Action for Responding to Emergency Preparedness (EP) Requested Information 3
Regulatory Commitment List cc: Director, Office of Nuclear Reactor Regulation (NRR)
NRC Region I Administrator NRC Region lll Administrator NRC Resident Inspector (BVPS)
NRC Resident Inspector (DBNPS)
NRC Resident Inspector (PNPP)
Director BRP/DEP Site BRP/DEP Representative Utility Radiological Safety Board Executive
- Director, Ohio Emergency Management
- Agency, State of Ohio (NRC Liaison)
Director, Pennsylvania Emergency Management Agency L-12-128 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Page 1 of 5 Gommunications Request Estimated Completion Date Requested Information 1
10t31t12 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 in the 10 CFR 50.54(0 letter, Enclosure 5, Discussion section. The assessment should:
r ldentify any planned or potentiaf improvements to existing onsite communications systems and their required normal and/or backup power supplies, o ldentify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, o Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and o 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 allAC power 2
6t11t12 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 comolete.
3 9t28t12 10t31t12 Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
Planned date to complete the communications assessment.
Provide an implementation schedule of the time needed to implement the results of the communications assessment.
Attachment 1
L-12-128 Page 2 of 5 Staffing Request Estimated Completion Date Requested Information 1
Beaver Valley Power Station (BVPS) only 4t30t13 BVPS 4 months prior to beginning of Unit No. 1 refueling outage, spring 2015 (1R23)
Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the 10 CFR 50.54(f) letter, Enclosure 5, Discussion section. 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:
o How onsite staff will move back-up equipment (e.9.,
pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NRC Near-Term Task Force (NTTF) Recommendation 4.2. lt 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 4.2. [Phase 1 staffing assessmentl Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. lPhase 2 staffing assessmentl
Attachment 1
L-12-128 Page 3 of 5 Request Estimated Completion Date Reouested lnformation Davis-Besse Nuclear Power Station (DBNPS) 4 months prior to beginning of refueling
- outage, spring 2016 (1R19)
Perry Nuclear Power Plant (PNPP) 4 months prior to beginning of refueling
- outage, sprins 2015 (1R15) 2 BVPS only 3t29t13 One month prior to providing submittal of Phase 2 staffing assessment BVPS only 4t30t13 BVPS 4 months prior to beginning of Unit No. 1 refueling outage, spring 2015 (1R23)
Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. lf any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.
- 1. Planned dates to complete the onsite and augmented staffing assessments:
The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessmentl The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. lPhase 2 staffing assessmentl
- 2. A schedule of the time needed to implement changes will be provided as follows:
Those associated with the Phase 1 staffing assessment.
Those associated with the Phase 2 staffing assessment.
Attachment 1
L-12-128 Page 4 of 5 Request Estimated Completion Date Requested lnformation DBNPS 4 months prior to beginning of refueling
- outage, spring 2016 (1R19)
PNPP 4 months prior to beginning of refueling
- outage, sprinq 2015 (1R15) 3 6t11t12 ldentify how the augmented staff would be notified oiven deqraded communications capabilities.
4 6t11t12 ldentify the methods of access (e.9., roadways, navigable bodies of water and dockage, airlift, etc.) to the site that are expected to be available after a widespread larqe scale natural event.
5 6t11t12 ldentify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
6 BVPS only 4t30t13 BVPS 4 months prior to beginning of Unit 1 refueling
- outage, spring 2015 (1R23)
DBNPS 4 months prior to beginning of refueling
- outage, spring 2016 (1R19) ldentify 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.9., staffing, equipment, transportation, etc.).
Changes will be identified as follows:
Those associated with the Phase 1 staffing assessment.
Those associated with the Phase 2 staffing assessment.
Attachment 1
L-12-128 Page 5 of 5 Request Estimated Completion Date Requested Information PNPP 4 months prior to beginning of refueling
- outage, spring 2015 (1R15)
L-12-128 Basis for Proposed Alternative Course of Action for Responding to Emergency Preparedness (EP) Requested Information Page 1 of 3 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 and maintaining existing EP communications equipment.
ln addition, the estimated completion date assigned to information request #3 will promote alignment between the budgeting/funding of future enhancements, and the development of an accurate and complete enhancement implementation schedule.
Staffing As presented in Attachment 1 of this letter, a two-phase approach will be used to respond to the information requests associated with Staffing. The table below summarizes this approach.
Plant Type Phase 1 Staffing Assessment (for functions except those related to NTTF Recommendation 4.2)
Phase 2 Staffing Assessment (for functions related to NTTF Recommendation 4.2)
Single-unit plants
[such as Davis-Besse Nuclear Power Station (DBNPS) and Perry Nuclear Power Plant (PNPP)I Perform staffing assessment and implement actions as required by recent EP Rule using Interim Staff Guidance (lSG) and NEI 10-05 Perform staffing assessment as requested by 50.54(0 letter using NEI 12-01; provide results per Attachment 1 of this letter Multi-unit plants
[such as Beaver Valley Nuclear Power Station (BVPS)l
. Perform staffing assessment and implement actions as required by recent EP Rule using ISG and NEI 10-05
. Perform staffing assessment as requested by 50.sa(fl letter using NEI 12-01 and material from NEI 10-05; provide results per Attachment 1 of this letter Perform staffing assessment as requested by 50.54(0 letter using NEI 12-01; provide results per Attachment 1 of this letter
Attachment 2
L-12-128 Page 2 of 3 The basis for this approach is discussed below.
o For multi-unit plants (such as BVPS), the Phase 1 staffing assessment is planned to be performed by March 29,2013, and will be 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.
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 lV.A.g of 10 CFR 50, Appendix E, requires that licensees complete a detaibd 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 three 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.
Single-unit plants (such as DBNPS and PNPP) do not need to provide a Phase 1 staffing assessment in response to the 50.54(f) letter as performance of this activity is governed by the recent EP Rule and existing license requirements.
. The Phase 2 staffing assessment is planned to be performed by one month prior to providing the submittal of the Phase 2 staffing assessment, which will be provided for each FENOC site by four months prior to the beginning of the site's first occurrence of a second refueling outage as identified in Attachment
- 1. 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 Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-
Attachment 2
L-12-128 Page 3 of 3 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 (lSG) scheduled to be issued by the NRC in August 2012.
ln 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. Once the site-specific actions associated with the new response strategies are defined, 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 four months prior to beginning of 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. FENOC, 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."
Attachment 3
L-12-128 Regulatory Commitment List Page 1 of 1 The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, Davis-Besse Nuclear Power Station (DBNPS),
and Perry Nuclear Power Plant (PNPP) in this document. Any other actions discussed in this submittal represent intended or planned actions by FENOC. They are described only as information and are not Regulatory Commitments.
Please notify Mr. Phil H. Lashley, Supervisor
- Fleet Licensing, at 330-315-6808 of any questions regarding this document or associated Regulatory Commitments.
Reoulatory Commitment
- 1. FENOC will provide the requested information for the Communications Assessment (Communications Request 2) and Staffing Assessment (Staffing Requests 3, 4, and 5).
- 2. FENOC will provide the requested information for the Communications Assessment (Communications Requests 1 and 3).
- 3. FENOC will provide the requested information for Phase 1 (all functions except those related to NTTF Recommendation 4.2) of the Staffing Assessment (Staffing Request 1, 2, and 6).
Due Date June 11,2012 October 31,2012 April 30, 2013 (BVPS only)
- 4. FENOC will provide the requested information for Phase 2 BVPS (all functions considering the results of NTTF Recommendation 4 months prior to 4.2) of the Staffing Assessment (Staffing Requestl,2 and 6).
beginning of Unit 1 refueling
- outage, spring 2015 (1R23)
DBNPS 4 months prior to beginning of refueling outage, spring 2016 (1R1e)
PNPP 4 months prior to beginning of refueling outage, spring 2015 (1R15)