ML12146A102
| ML12146A102 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  (DPR-080, DPR-082) |
| Issue date: | 06/11/2012 |
| From: | Joseph Sebrosky Plant Licensing Branch IV |
| To: | Halpin E Pacific Gas & Electric Co |
| Sebrosky J | |
| References | |
| TAC ME8673, TAC ME8674 | |
| Download: ML12146A102 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 11,2012 Mr. Edward D. Halpin Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - REVIEW OF 60-DAY RESPONSE TO REQUEST FOR INFORMATION REGARDING RECOMMENDATION 9.3 OF THE NEAR-TERM TASK FORCE RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS.
ME8673 AND ME8674)
Dear Mr. Halpin:
By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a Request for Information pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(f) which included the Near Term Task Force (NTTF)
Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged Station Blackout (SBO) event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date.
By letter dated May 9, 2012, Pacific Gas and Electric the licensee for Diablo Canyon Power Plant, Unit Nos. 1 and 2, submitted its 60-day response proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. As discussed in the enclosed NRC staff evaluation, the licensee's alternative approach outlined in its 60-day response letter is consistent with the guidance of industry document Nuclear Energy Institute (NEI) 12-01, "Guidance for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,,,l and the direction of the Commission.
In addition, the NRC staff concludes that the licensee provided an adequate basis for its proposed alternative to responding to the 50.54(f) Request for Information regarding communications and staffing for NTTF Recommendation 9.3. In its letter dated May 9,2012, the licensee identified the regulatory commitments provided in the attachment to the enclosure to this letter.
NRC staff determined NE112-01 to be an acceptable approach in a letter dated May 15, 2012 (ADAMS Accession No. ML12131A043).
E. Halpin
- 2 If you have any questions, please contact me at 301-415-1132 or via e-mail at joseph.sebrosky@nrc.gov.
Docket Nos. 50-275 and 50-323
Enclosure:
Staff Evaluation cc w/encl: Distribution via Listserv
NUCLEAR REGULATORY COMMISSION STAFF EVALUATION INFORMATION REQUEST MADE UNDER 10 CFR 50.54(f}
REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 9.3 PACIFIC GAS AND ELECTRIC DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323 By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12073A348), the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a Request for Information pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(f) which included the Near-Term Task Force (NTTF)
Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged Station Blackout (SBO) event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date.
By letter dated May 3,2012 (ADAMS Accession No. ML12125A410), the Nuclear Energy Institute (NEI) submitted NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012. The NRC staff reviewed NEI 12-01 and found it to be an acceptable method for licensees to use when responding to the NRC's 10 CFR 50.54(f) Request for Information regarding communications and staffing for EP.
This staff evaluation is focused specifically on the licensee's response to the 10 CFR 50.54(f) letters and not on the associated Orders.
By letter dated May 9, 2012 (ADAMS Accession No. ML 12131 A41 O), Pacific Gas and Electric, the licensee for Diablo Canyon Power Plant, Unit Nos. 1 and 2, submitted its 60-day response to the 10 CFR 50.54(f) Request for Information proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. The NRC staff reviewed the licensee's proposed alternative against the guidance contained in NEI 12-01. In addition, the NRC staff also considered the direction given by the Commission in the Staff Requirements Memorandum (SRM) to SECY 12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," dated March 9,2012 (ADAMS Accession No. ML120690347). This SRM stated, in part, that Completing implementation activities associated with the rule we have already promulgated has greater safety significance and also involves the coordinated actions of our partners in State and local governments. Substantial public credibility benefits accrue from continuing these activities as a priority.
Enclosure
- 2 The NRC staff considers the existing EP framework and regulations providE*; reasonable assurance of adequate protection of public health and safety in the event of a radiological emergency. The revised EP rule that was promulgated on November 23, 2011, initiated a number of activities that will enhance EP programs, including conducting a staffing analysis and enhancing public notification systems. The implementation of the EP rule was given priority by the Commission and the NTTF recommendations should not displace ongoing work that has greater safety benefit, higher priority, or is necessary for continued safe operation of nuclear power plants. The NTTF Report concluded that continued operation and continued licenSing activities do not pose an imminent risk to the public health and safety and are not inimical to the common defense and security.
The phased approach to responding to the 10 CFR 50.54(f) letters, combined with the definition of new response requirements associated with Fukushima NTTF Recommendation 4.2, as subsequently modified by the NRC staff and issued as NRC Order EA-12-049 (ADAMS Accession No. ML12054A736), will ensure that enhancements will be made to staffing and communications by licensees. It should be noted that the 10 CFR 50.54(f) letter and implementation of the Order includes completion of actions related to response assignments, staffing changes, issuance of new or revised procedures or guidelines, and training. Activities are ongoing by both the NRC and industry to initiate interim actions as a result of lessons learned from the events which will be provided in the 90-day response such as:
Methods to access the site Notification of staff Interim actions taken to date Given the above and that the licensee's approach was found to be consistent with the guidance of NEI 12-01 and the direction of the Commission, the NRC staff concludes that the licensee has provided an adequate basis for its proposed alternative responding to the 10 CFR 50.54(f) letters regarding communications and staffing for Recommendation 9.3.
In its letter dated May 9, 2012, the licensee identified the regulatory commitments provided in the attachment to this staff evaluation.
Attachment
LIST OF REGULATORY COMMITMENTS PROVIDED IN PACIFIC GAS AND ELECTRIC'S LETTER DATED MAY 9,2012 The following two tables provide regulatory commitments related to Communications and Staffing items found in Enclosure 5 of the March 12, 2012, request for information.
Communications Request Estimated Completion Date Requested information 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 andlor backup power supplies,
- Identify any planned or potential improvements to existing offsite communications systems and their required normal andlor 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 andlor 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 9/28/2012 10/31/2012 Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
Conduct the communications assessment Provide an implementation schedule of the time needed to implement the results of the communications assessment.
Attachment
- 2 StaffinjJ Request Estimated Completion Date Requested Information 1
Two Dates 4/30/2013 4 months prior to the beginning of 1R191 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).
Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2.
[Phase 1 staffing assessment]
Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- 3 Request Estimated Completion Date Requested Information 2
Four Dates 3/29/2012 4 months prior to the beginning of 1R192 4/30/2013 4 months prior to the beginning of 1R191 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.
- a. The onsite and augmented staffing assessment conSidering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
- b. The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- 2. A schedule of the time needed to implement changes will be provided as follows:
- a. Those associated with the Phase 1 staffing assessment.
- b. Those associated with Phase 2 staffing assessment.
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.
-4 Request Estimated Completion Date Requested Information 6
Two Dates 4/30/2013 4 months prior to the beginning of 1R191 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.
Those associated with the Phase 2 staffing assessment.
1Unit 1 nineteenth refueling outage (1 R19) is currently scheduled to begin Fall 2015.
2Dependent on submittal date for Staffing Information Request #1
ML12146A102 Sincerely, IRAJ Joseph M. Sebrosky, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
- via email OFFICE NRRIDORLlLPL4/PM NRRlDORLlLPL4/LA NSIRIDPR/NRLB/BC NAME JSebrosky JBurkhardt*
KWilliams*
1 DATE 617/12 617/12 5124/12
.OFFICE NRR/JLD/PMB/BC NRR/DORLlLPL4/BC NRRlDORLlLPL4/PM
'NAME RPascarel1i MMarkley JSebrosky DATE 617112 6111/12 6/11/12