ML12159A288
| ML12159A288 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/11/2012 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Flores R Luminant Generation Co |
| References | |
| TAC ME8686, TAC ME8687 | |
| Download: ML12159A288 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 11, 2012 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention:
Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 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. ME8686 and ME8687)
Dear Mr. Flores:
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 SO.S4(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 10, 2012, as supplemented by letter dated June 5. 2012, Luminant Generation Company LLC, the licensee for Comanche Peak Nuclear power Plant. Units 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,,,1 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 SO.S4(f) Request for Information regardhg communications and staffing for tHTF Recommendation 9.3.
In its letter dated.June 5, 2012, the licensee identified the regulatory commitments provided in the attachment to the enclosure to this letter.
NRC staff determined NEI 12-01 to be an acceptahle approach in letter dated May 1S, 2012 (ADAMS Accession No. ML12131A043).
R. Flores
- 2 If you have any questions, please contact me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.
Sincerely,
~-\\
'LS~'o-O Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
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 LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 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 10, 2012 (ADAMS Accession No. ML12136A473), as supplemented by letter dated June 5,2012 (ADAMS Accession No. MLxxxxxxxxx2), Luminant Generation Company LLC, the licensee for Comanche Peak Nuclear Power Plant (CPNPP), Units 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 2 ADAMS Accession No. was not available at the time of issue of this document.
Enclosure
- 2 actions of our partners in State and local governments. Substantial public credibility benefits accrue from continuing these activities as a priority.
The NRC staff considers the existing EP framework and regulations provides 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 June 5, 2012, the licensee identified the regulatory commitments provided in the attachment to this staff evaluation.
Attachment
LIST OF REGULATORY COMMITMENTS PROVIDED IN LUMINANT GENERATION COMPANY LLC'S LETTER DATED JUNE 5, 2012 SCHEDULED COMMITMENT COMPLETION COMMITMENT NO.
DATE
- 1. Provide an assessment of the current 4392894 10/31/2012 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.
- 2. Provide an implementation schedule of the time 4392918 10/31/2012 needed to conduct and implement the results of the communications assessment.
- 3. Conduct and provide results for an onsite and 4392919 4/30/2013 augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment for Staffing Request 1]
- 4. Conduct and provide results for an onsite and 4392932 4 months prior to augmented staffing assessment considering functions beginning of 1RF17 related to NTTF Recommendation 4.2. [Phase 2 refueling outage staffing assessment for Staffing Request 1]
(est. June 2014)
!5. Provide a schedule of the time needed to implement 4392934 4/30/2013 changes associated with the Phase 1 staffing assessment [for Staffing Request 2].
- 6. Provide a schedule of the time needed to implement 4392952 4 months prior to changes associated with the Phase 2 staffing beginning of 1RF17 assessment. [for Staffing Request 2]
refueling outage (est. June 2014)
- 7. Identify changes associated with the Phase 1 staffing 4392954 4/30/2013 assessment 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 [for Staffing Request 6].
- 8. Identify changes associated with the Phase 2 staffing 4392956 4 months prior to assessment that have been made or will be made to beginning of 1 R17 your emergency plan regarding the on-shift or refueling outage augmented staffing changes necessary to respond to *
(est. June 2014) a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers [for Staffing Request 6].
Attachment
- concurrence via email OFFICE NRR/DORLlLPL4/PM NRR/DORLlLPL4/LA NSIR/DPR/DDEPE/NRLB/BC NAME BSingal JBurkhardt*
KWilliams*
DATE 6/7/12 6/7/12 6/6/12 OFFICE NRR/JLD/PMB/BC NRR/DORULPL4/BC NRR/DORL/LPL4/PM NAME IRPascarelli MMarkley BSingal DATE 6/7/12 6/11/12 6/11/12