ML12132A375

Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near Term, Task Force Report

ML12132A375
Person / Time
Site:	San Onofre
Issue date:	05/09/2012
From:	Bauder D Southern California Edison Co, Edison International Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12132A375 (11)

Text

SOUTHERN CALIFORNIA Douglas R. Bauder EDISON Site Vice President & Station Manager San Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company 10 CFR 50.54(f)

May 9, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket Nos. 50-361 and 50-362 60 Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near Term, Task Force Report San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

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 On March 12, 2012, the NRC staff issued a letter entitled, Request for Information Pursuantto Title 10 of the Code of FederalRegulations 50.54(0 Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident. 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, Southern California Edison (SCE) proposes to take the alternative course of action described in Enclosure 1 of this letter. The basis for our proposal is explained in Enclosure 2.

This letter contains regulatory commitments. The specific regulatory commitments are identified in Enclosure 3 of this letter.

Should you have any questions concerning the content of this letter, please contact Larry McCann at 949-368-9281.

P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com

Document Control Desk May 9, 2012 I declare under penalty of perjury that the foregoing is true and correct.

By:

ibouglas Bauder Site Vice President and Station Manager Enclosures (3) cc: (with Enclosures)

E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3

Enclosure I Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Communications Estimated Request Completion Requested Information Date 10/31/12 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 Discussion section of Enclosure 5 of the Reference letter. 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 AC power 2 6/11/12 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.

9/28/12 Conduct the communications assessment.

10/31/12 Provide an implementation schedule of the time needed to implement the results of the communications assessment.

1-1

Enclosure 1 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request 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 in the Discussion section of Enclosure 5 of the Reference letter. 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]

4 months prior to Provide onsite and augmented staffing assessment Unit 3 Cycle 18 considering functions related to NTTF Recommendation Refueling outage or 4 months prior 4.2. [Phase 2 staffing assessment]

to Unit 2 Cycle 19 Refueling

• As used within the context of NRC Order EA-12-049 outage* or August 31, 2016, whichever comes first 1-2

Enclosure 1 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request 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.

1. Conduct the onsite and augmented staffing assessment:

3/29/13 The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

4 months prior to The onsite and augmented staffing assessment considering Unit 3 Cycle 18 functions related to NTTF Recommendation 4.2. [Phase 2 Refueling outage or 4 months prior staffing assessment]

to Unit 2 Cycle 19 Refueling

• As used within the context of NRC Order EA-12-049 outage* or August 31, 2016, whichever comes first i

2. A schedule of the time to needed to implement changes will be provided as follows:

4/30/13 Those associated with the Phase 1 staffing assessment.

4 months prior to Those associated with the Phase 2 staffing assessment.

Unit 3 Cycle 18 Refueling outage or 4 months prior to Unit 2 Cycle

• As used within the context of NRC Order EA-12-049 19 Refueling outage* or August 31, 2016, whichever comes first 3 6/11/12 Identify how the augmented staff would be notified given degraded communications capabilities.

1-3

Enclosure I Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Staffing Estimated Request Completion Requested Information Date 4 6/11/12 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 6/11/12 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:

4/30/13 Those associated with the Phase 1 staffing assessment.

4 months prior to Those associated with the Phase 2 staffing assessment.

Unit 3 Cycle 18 Refueling outage or 4 months prior to Unit 2 Cycle

• As used within the context of NRC Order EA-12-049 19 Refueling outage* or August 31, 2016, whichever comes first 1-4

Enclosure 2 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 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 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 (for functions related to NTTF relatedRecommendation 4.2)

Recommendation 4.2)

Single-unit plants Perform staffing assessment Perform staffing assessment as and implement actions as requested by 50.54(f) letter required by recent EP Rule using NEI 12-01; provide using ISG and NEI 10-05 results per Enclosure 1 of this letter Multi-unit plants

• Perform staffing assessment Perform staffing assessment as and implement actions as requested by 50.54(f) letter required by recent EP Rule using NEI 12-01; provide using ISG and NEI 10-05 results per Enclosure 1 of this

• Perform staffing assessment letter 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 2-1

Enclosure 2 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information 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.

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.

Single-unit plants 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 will be performed, and provided by 4 months prior to Unit 3 Cycle 18 Refueling outage or 4 months prior to Unit 2 Cycle 19 Refueling outage or August 31, 2016, whichever comes first. (The August 31, 2016 limit is included because the effective length of the fuel cycles for San Onofre Unit 2 and Unit 3 are presently uncertain.) 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 2-2

Enclosure 2 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information 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-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. 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 (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. SCE, 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."

2-3

Enclosure 3 List of Commitments for Proposed Alternative Course of Action for Responding to EP Requested Information Commitment L i

Scheduled Due Date

1. Provide an assessment of the current 10/31/12 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 Discussion section of Enclosure 5 of the Reference letter. The assessment should:

o Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, o Identify 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 all AC power Provide a schedule of the time needed to implement the results of the communications assessment.

3-1

Enclosure 3 List of Commitments for Proposed Alternative Course of Action for Responding to EP Requested Information Commitment Scheduled Due Date i

2. Provide onsite and augmented staffing 4/30/2013 assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

Provide a schedule of the time needed to implement changes associated with the Phase I staffing assessment.

Identify changes that have been made or will be made to your emergency plan associated with the Phase 1 staffing assessment, 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.).

3. Provide onsite and augmented staffing 4 months prior to Unit 3 assessment considering functions related Cycle 18 Refueling to NTTF Recommendation 4.2. [Phase 2 outage* or 4 months staffing assessment] prior to Unit 2 Cycle 19 Refueling outage* or Provide a schedule of the time needed to August 31, 2016, implement changes associated with the whichever comes first Phase 2 staffing assessment.

• As used within the Identify changes that have been made or context of NRC Order will be made to your emergency plan EA-12-049 associated with the Phase 2 staffing assessment, 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.).

3-2