ML12132A379
| ML12132A379 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 05/09/2012 |
| From: | Heacock D Dominion Resources Services, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 12-206A | |
| Download: ML12132A379 (11) | |
Text
Dominion Resources Services, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard, 2SE, Glen Allen, VA 23060 May 9, 2012
- 2jiDominion U.S. Nuclear Regulatory Commission Serial No. 12-206A Attention: Document Control Desk NL&OS/WDC RO Washington, DC 20555 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE. INC.
KEWAUNEE POWER STATION 60 DAY RESPONSE TO MARCH 12, 2012 INFORMATION REQUEST On March 12, 2012, the Nuclear Regulatory Commission (NRC) 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. 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 March 12, 2012 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 1 of this letter. The basis for our proposal is explained in Enclosure 2.
If you have any questions regarding this proposed alternative course of action for the resolution of Recommendation 9.3, please contact Craig Sly at (804) 273-2784.
Sincerely, David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.
COMMONWEALTH OF VIRGINIA )
&fVrii MCKI L.HULL Notary Public lmeayt Co 140a542fVigii FMy'Cnn"f EPrsMay 31, 24014
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COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by David A. Heacock, who is President and Chief Nuclear Officer of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this _Z-_day of 2012.
My Commission Expires: 31 J w
Notary PublicA
Serial No. 12-206A Docket No. 50-305 Page 2 of 2 Commitments made in this letter: As proposed in Enclosure 1 based on currently scheduled refueling outage dates.
Enclosures:
- 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 EP Requested Information cc: U.S. Nuclear Regulatory Commission, Region III Regional Administrator 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 H-4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station
Serial No. 12-206A Docket No. 50-305 ENCLOSURE 1 PROPOSED ALTERNATIVE COURSE OF ACTION FOR RESPONDING TO RECOMMENDATION 9.3 INFORMATION REQUEST DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure,1, Page 1 of 4 Enclosure I Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Communications Estimated Request Completion Requested Information
- Date 1 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 Enclosure 2. The assessment should:
0 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,
- 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 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.
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 1, Page 2 of 4 Staffing Estimated Request Completion Requested Information
- Date Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in Enclosure 2. 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 NRC Near-Term Task Force (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 months prior Provide onsite and augmented staffing assessment to beginning of considering functions related to NTTF Recommendation second refueling 4.2. [Phase 2 staffing assessment]
outage*
(Spring 2015 outage) *As used within the context of NRC Order EA-12-049
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 1, Page 3 of 4 Estimated Request Completion Requested Information
- Date 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:
5 months prior The onsite and augmented staffing assessment to beginning of considering functions related to NTTF Recommendations second refueling 4.2. [Phase 2 staffing assessment]
outage*
(Spring 2015 outage)
- 2. A schedule of the time needed to implement changes will be provided as follows:
Implementation schedule associated with the Phase 2 4 months prior to beginning of staffing assessment.
second refueling outage* *As used within the context of NRC Order EA-12-049 (Spring 2015 outage) 3 6/11/12 Identify how the augmented staff would be notified given degraded communications capabilities.
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.
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 1, Page 4 of 4 Estimated Request Completion Requested Information
- Date 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.).
4 months prior Changes associated with the Phase 2 staffing to beginning of assessment.
second refueling outage*
(Spring 2015 *As used within the context of NRC Order EA-12-049 outage)
Serial No. 12-206A Docket No. 50-305 ENCLOSURE 2 BASIS FOR PROPOSED ALTERNATIVE COURSE OF ACTION FOR RESPONDING TO EP REQUESTED INFORMATION DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 2, 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 Enclosure 1 reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-1 2-0025, 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., INPO Event Report (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 two-phase approach will be used to respond to the information requests associated with Staffing. The table below summarizes this approach. Alternative timing of responses to requests #1, #2, and #6 are proposed in .
Plant Type Phase 1 Staffing Assessment Phase 2 Staffing Assessment (for functions except those related (for functions related to NTTF to NTTF Recommendation 4.2) Recommendation 4.2)
Single-unit Perform staffing assessment and Perform staffing assessment as plants implement actions as required by requested by 50.54(f) letter recent EP Rule using Interim Staff using NEI 12-01; provide results I Guidance (ISG) and NEI 10-05 per Enclosure 1 of this letter The basis for this approach is discussed below.
Following completion of EP Rule staffing analysis, the staffing assessment associated with the NRC letter will be performed. Single-unit plants do not need to provide a Phase 1 staffing assessment in response to the 50.54(f) letter as
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 2, Page 2 of 3 performance of this activity is governed by the recent EP Rule and existing license requirements.
The Phase 2 staffing assessment will be performed by five months prior to the beginning of the second refueling outage, and provided by four months prior to the beginning of the second refueling outage. 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 and Staff Requirements Memoranda. 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-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 four months prior to the beginning of the second refueling outage (as used within the context of NRC Order EA-12-049).
Serial No. 12-206A Docket No. 50-305 60 Day Response to March 12, 2012 Information Request Enclosure 2, Page 3 of 3 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. Dominion Energy Kewaunee, Inc., 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."