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Category:Letter type:RA
MONTHYEARRA-24-0012, Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report2024-02-0505 February 2024 Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report RA-24-0015, Submittal of 2023 Sea Turtle Annual Report2024-01-10010 January 2024 Submittal of 2023 Sea Turtle Annual Report RA-23-0325, Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX2024-01-0808 January 2024 Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX RA-24-0006, 10 CFR 50.54(q) Evaluation2024-01-0404 January 2024 10 CFR 50.54(q) Evaluation RA-23-0313, Baffle-Former Bolt (Bfb) Subsequent Inspection Interval Evaluation2023-12-14014 December 2023 Baffle-Former Bolt (Bfb) Subsequent Inspection Interval Evaluation RA-23-0306, Procedures CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 006 and CSD-EP-CNS-0101-01, EAL Technical Basis Document, Revision 005, Summary Of.2023-12-12012 December 2023 Procedures CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 006 and CSD-EP-CNS-0101-01, EAL Technical Basis Document, Revision 005, Summary Of. RA-23-0318, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0404 December 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0284, RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-16016 November 2023 RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0276, Response to Request for Additional Information Regarding License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specific2023-11-0606 November 2023 Response to Request for Additional Information Regarding License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specific RA-23-0281, Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes2023-11-0101 November 2023 Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes RA-23-0121, License Amendment Request to Adopt TSTF-258-A, Revision 4, Regarding Changes to Technical Specification Section 5.7, High Radiation Area2023-10-0505 October 2023 License Amendment Request to Adopt TSTF-258-A, Revision 4, Regarding Changes to Technical Specification Section 5.7, High Radiation Area RA-23-0218, Review Request for the Aging Management Program and Inspection Plan for the Shearon Harris Nuclear Power Plant, Unit 1, Reactor Vessel Internals2023-09-21021 September 2023 Review Request for the Aging Management Program and Inspection Plan for the Shearon Harris Nuclear Power Plant, Unit 1, Reactor Vessel Internals RA-23-0225, Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes2023-09-20020 September 2023 Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes RA-22-0290, License Amendment Request to Exclude the Dynamic Effects of Specific Postulated Pipe Ruptures from the Design and Licensing Basis Based on Leak-Before-Break Methodology2023-08-30030 August 2023 License Amendment Request to Exclude the Dynamic Effects of Specific Postulated Pipe Ruptures from the Design and Licensing Basis Based on Leak-Before-Break Methodology RA-23-0216, Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks2023-08-22022 August 2023 Independent Spent Fuel Storage Installation, Registration of Use of Spent Fuel Casks RA-23-0199, Response to Request for Additional Information (RAI) Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner2023-08-18018 August 2023 Response to Request for Additional Information (RAI) Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner RA-23-0122, License Amendment Request to Revise the 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Categorization Process to .2023-08-17017 August 2023 License Amendment Request to Revise the 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Categorization Process to . RA-23-0195, Notice of Intentions Regarding Apparent Violation Response; (EA-23-060)2023-07-20020 July 2023 Notice of Intentions Regarding Apparent Violation Response; (EA-23-060) RA-23-0154, Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0136, Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0141, Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule2023-07-12012 July 2023 Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule RA-23-0142, Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require2023-07-0707 July 2023 Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require RA-23-0045, Inservice Inspection Program Owner'S Activity Report for Unit 2 Refueling Outage 262023-06-28028 June 2023 Inservice Inspection Program Owner'S Activity Report for Unit 2 Refueling Outage 26 RA-23-0145, Independent Spent Fuel Storage Installation (Isfsi), Registration for Use of General License Spent Fuel Casks2023-06-15015 June 2023 Independent Spent Fuel Storage Installation (Isfsi), Registration for Use of General License Spent Fuel Casks RA-23-0135, Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory2023-06-0707 June 2023 Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory RA-23-0139, Registration for Use of General License Spent Fuel Casks2023-06-0606 June 2023 Registration for Use of General License Spent Fuel Casks RA-23-0120, Supplemental Information Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.22023-05-31031 May 2023 Supplemental Information Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.2 RA-23-0005, License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specifications2023-05-31031 May 2023 License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specifications RA-23-0041, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-30030 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations RA-23-0047, Duke Energy Annual Radiological Environmental Operating Report - 20222023-04-26026 April 2023 Duke Energy Annual Radiological Environmental Operating Report - 2022 RA-23-0044, Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.462023-04-26026 April 2023 Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.46 RA-23-0064, Inservice Testing Program Plan and Snubber Program Plan for Sixth 10-Year Inservice Testing (1ST) Program Interval2023-04-24024 April 2023 Inservice Testing Program Plan and Snubber Program Plan for Sixth 10-Year Inservice Testing (1ST) Program Interval RA-23-0046, Annual Radioactive Effluent Release Report - 20222023-04-24024 April 2023 Annual Radioactive Effluent Release Report - 2022 RA-23-0098, Annual Environmental (Nonradiological) Operating Report2023-04-19019 April 2023 Annual Environmental (Nonradiological) Operating Report RA-23-0096, Post Accident Monitoring (PAM) Instrumentation Report2023-04-12012 April 2023 Post Accident Monitoring (PAM) Instrumentation Report RA-23-0063, Notification of Deviation from BWRVIP Guidelines2023-04-11011 April 2023 Notification of Deviation from BWRVIP Guidelines RA-23-0080, Refueling Outage 32 Steam Generator Tube Inspection Report Supplement Pursuant to Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube2023-04-0505 April 2023 Refueling Outage 32 Steam Generator Tube Inspection Report Supplement Pursuant to Technical Specifications Task Force (TSTF) Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube RA-23-0043, Refuel 33 (R2R33) Inservice Inspection Program Ninety Day Owner'S Activity Report and Analytical Evaluations2023-03-30030 March 2023 Refuel 33 (R2R33) Inservice Inspection Program Ninety Day Owner'S Activity Report and Analytical Evaluations RA-23-0036, Biennial Decommissioning Financial Assurance Reports2023-03-30030 March 2023 Biennial Decommissioning Financial Assurance Reports RA-23-0040, Onsite Property Insurance Coverage2023-03-30030 March 2023 Onsite Property Insurance Coverage RA-23-0039, 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2023-03-30030 March 2023 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums RA-23-0055, Notice of Intent to Pursue Subsequent License Renewal for H. B. Robinson Steam Electric Plant, Unit Number 22023-03-24024 March 2023 Notice of Intent to Pursue Subsequent License Renewal for H. B. Robinson Steam Electric Plant, Unit Number 2 RA-23-0021, Unit 2 Cycle 26 Core Operating Limits Report (COLR)2023-02-22022 February 2023 Unit 2 Cycle 26 Core Operating Limits Report (COLR) RA-22-0257, Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-02-17017 February 2023 Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-22-0091, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2023-02-16016 February 2023 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RA-23-0015, Response to Request for Additional Information (RAI) Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.22023-02-0909 February 2023 Response to Request for Additional Information (RAI) Regarding Addition of Feedwater Isolation on Steam Generator Level High-High to Technical Specification 3.3.2 RA-22-0081, License Amendment Request to Address Administrative Changes to the Operating License and Technical Specifications2023-02-0707 February 2023 License Amendment Request to Address Administrative Changes to the Operating License and Technical Specifications RA-23-0001, Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI2023-02-0202 February 2023 Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI RA-22-0118, License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies2023-02-0101 February 2023 License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies RA-23-0029, Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable Containment Sump Water Level (Wide Range)2023-01-30030 January 2023 Technical Specifications Section 5.6.6 Post Accident Monitoring Instrumentation Report for Inoperable Containment Sump Water Level (Wide Range) 2024-02-05
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Progress Energy 10 CFR 50.4 10 CFR 50.54(0 411 Fayetteville Street Mall Raleigh NC 27602 Serial: RA-12-023 June 11, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 / RENEWED LICENSE NOS. DPR-71 AND DPR-62 CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NO. 50-302 / LICENSE NO. DPR-72 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 / RENEWED LICENSE NO. DPR-23
SUBJECT:
CAROLINA POWER & LIGHT COMPANY AND FLORIDA POWER CORPORATION'S 90-DAY RESPONSE TO THE MARCH 12, 2012, REQUEST FOR INFORMATION REGARDING ENCLOSURE 5, RECOMMENDATION 9.3: EMERGENCY PREPAREDNESS
REFERENCE:
- 1. NRC Letter, Request for Information Pursuantto Title 10 of the Code of Federal Regulations 50.54(6 RegardingRecommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insightsfrom the Fukushima Dai-IchiAccident, dated March 12, 2012
- 2. Progress Energy Letter, CarolinaPower & Light Company and FloridaPower Corporation's60-Day Response to the March 12, 2012, Request For Information Regarding Enclosure 5, Recommendation 9.3: Emergency Preparedness,dated May 9, 2012.
Ladies and Gentlemen:
The NRC staff issued Reference I on March 12, 2012. Enclosure 5 of Reference 1 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 written responses to the information request on requested due dates.
In accordance with Reference 1, on May 9, 2012, Carolina Power & Light Company (CP&L) and Florida Power Corporation (FPC) submitted, via Reference 2, an alternative course of action for providing the requested information. The alternative course of action included revised information due dates and the basis for those dates. As described in the alternative course of action, this letter transmits the responses for the following information requests.
United States Nuclear Regulatory Commission RA-12-023 Page 2
" Enclosure 5, Communications request 2
" Enclosure 5, Staffing request 3
" Enclosure 5, Staffing request 4
" Enclosure 5, Staffing request 5 Finally, Enclosure 1 of Reference 2 contained a typographical error on Page 4 of 7. The "Estimated Completion Date" for Crystal River Unit 3 (CR3) Nuclear Generating Plant, for Staffing Request #1, was inadvertently listed as "-12/31/16" when it should have been listed as "-8/3 1/16" to correspond to "four months prior to December 31, 2016."
This letter contains no new commitments. Any actions discussed in this document should be considered intended or planned actions.
If you have any questions or require additional information, please contact Donna Alexander, Manager, Nuclear Regulatory Affairs, at (919) 546-5357.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on June 11, 2012.
Sincerely, Garry iller Vice President - Nuclear Engineering Progress Energy, Inc.
DBM
Enclosure:
Request for Information 90-Day Emergency Preparedness Response cc: USNRC Region II, Regional Administrator USNRC Resident Inspector - BSEP, Unit Nos. 1 and 2 USNRC Resident Inspector - CR3 USNRC Resident Inspector - SHNPP, Unit No. 1 USNRC Resident Inspector - HBRSEP, Unit No. 2 F. Saba, NRR Project Manager - BSEP, Unit Nos. I and 2; CR3 A. T. Billoch Col6n, NRR Project Manager - SHNPP, Unit No. 1; HBRSEP, Unit No. 2
United States Nuclear Regulatory Commission RA- 12-023, Enclosure Enclosure Request for Information 90-Day Emergency Preparedness Response Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324 / Renewed License Nos. DPR-71 and DPR-62 Crystal River Unit 3 Nuclear Generating Plant Docket No. 50-302 / License No. DPR-72 Shearon Harris Nuclear Power Plant, Unit No. 1 Docket No. 50-400 / Renewed License No. NPF-63 H. B. Robinson Steam Electric Plant, Unit No. 2 Docket No. 50-261 / Renewed License No. DPR-23
United States Nuclear Regulatory Commission RA- 12-023, Enclosure Page 1 of 4 Request for Information (RFI) 90-Day Emergency Preparedness Response Communications:
RFI 2 - 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.
Carolina Power & Light (CP&L) and Florida Power Corporation (FPC) have purchased four 6 kW portable diesel generators per unit. These portable diesel generators can be used to power handheld radio chargers and portable satellite phone chargers. These portable diesel generators are expected to be on site by the end of the third quarter 2012.
Additionally, CP&L and FPC have purchased additional satellite phones that utilize a battery power source to increase the overall diversity of the communication system power supplies.
Approximately 35 satellite phones have been purchased for each site. CP&L and FPC currently plan to distribute these satellite phones to the four sites for use by the emergency response organizations by the end of 2012.
Staffing:
RFI 3 - Identify how the augmented staff would be notified given degraded communications capabilities.
CP&L and FPC plan to implement a protocol by which Emergency Response Organization members will automatically respond to their designated Emergency Response Facilities when made aware of an area-wide disaster (e.g., large scale natural disaster, regional blackout, technological disaster, etc.). This will be accomplished by December 20, 2012.
RFI 4 - 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.
Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Method Description Roadway There are several roadways into the BSEP region. If one path becomes impassable, detours using other roadways are viable. Major routes include:
- NC 87, NC 133, and US Highway 74/76 and adjoining roadways from the north and northwest.
- NC 132 and US Highway 421 and adjoining roadways from the north
" US Highway 17 Bypass, NC 211, and NC 130 and adjoining roadways from the west.
" The primary plant access road travels northeast from NC 87 near the intersection with NC 133.
" Cogentrix Drive travels north from East Leonard Street to the plant site and could be used to access the plant site if necessary. East Leonard
United States Nuclear Regulatory Commission RA- 12-023, Enclosure Page 2 of 4 Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2 Method Description Street is accessible from Jabbertown Road via NC 87 near the intersection with NC 211.
Air Access to BSEP can be provided from staging areas and a landing zone via helicopters arranged for by Progress Energy.
Water The BSEP can also be accessed from the Cape Fear River. The Cape Fear River can be accessed from multiple roadways. Access to the BSEP can be through personal watercraft or watercraft arranged for by Progress Energy.
Rail The BSEP can be accessed via an active rail line arranged for by Progress Energy.
Crystal River Unit 3 (CR-3) Nuclear Generating Plant Method Description Roadway There are several roadways into the CR-3 region. If one path becomes impassable, detours using other roadways are viable. Major routes include:
- US Highway 19/98, US Highway 41, CR 337, SR 121, SR 24, and CR 336 and adjoining roadways from the north.
" US Highway 19/98, US Highway 41, CR 491 and adjoining roadways from the south.
- SR 40, CR 488, CR 486, and SR 44 and adjoining roadways from the east.
- The primary plant access road, W. Power Line Rd., travels west from US Highway 19/98 to the plant site. Various dirt/limestone roads parallel portions of the plant access road and could be used to bypass portions of the primary access road.
" A limestone quarry road travels west and south from US Highway 19/98 to the plant site and could be used to access the plant site if necessary.
Air Access to CR-3 can be provided from staging areas and a landing zone via helicopters arranged for by Progress Energy.
Water CR-3 can also be accessed from the Gulf of Mexico. The Gulf can be accessed from multiple roadways. Access to CR-3 can be through personal watercraft or watercraft arranged for by Progress Energy.
Rail CR-3 can be accessed via an active rail line arranged for by Progress Energy.
Shearon Harris Nuclear Power Plant (SHNPP), Unit No. 1 Method Description Roadway There are several roadways into the SHNPP region. If one path becomes impassable, detours using other roadways are viable. Major routes include:
" US Highway One and adjoining roadways from the north.
" US Highway One and adjoining roadways from the south.
" NC 42 and adjoining roadways from the southeast.
e New Hill Holleman Road from the south.
United States Nuclear Regulatory Commission RA- 12-023, Enclosure Page 3 of 4 Shearon Harris Nuclear Power Plant (SHNPP), Unit No. 1 Method Description
- The primary plant access road is off of Shearon Harris Road and travels west to the south side of the plant site. Shearon Harris Road can be accessed from US Highway One/New Hill Holleman Road to the East or Old US Highway One from the North.
- A secondary site access road off of Shearon Harris Road travels west to the north side of the plant site and could be used to access the plant site if necessary.
Air Access to SHNPP can be provided from staging areas and a landing zone via helicopters arranged for by Progress Energy.
Water The SHNPP can also be accessed from the Harris Lake. Harris Lake can be accessed from multiple roadways adjacent to the owner controlled area.
Access to the SHNPP can be through personal watercraft or watercraft arranged for by Progress Energy.
Rail The SHNPP can be accessed via an active rail line arranged for by Progress Energy.
H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2 Method Description Roadway There are several roadways into HBRSEP region. If one path becomes impassable, detours using other roadways are viable. Major routes include:
" South Carolina Highway 151 and adjoining roadways from the northwest.
" South Carolina Highway 151 and adjoining roadways from the southeast.
- South Carolina-23/Old Camden Road and adjoining roadways from the northeast.
" South Carolina-23/Old Camden Road and adjoining roadways from the southwest.
- The primary plant access road travels north from South Carolina-23/Old Camden Road near the intersection with South Carolina Highway 151.
" Silo Road travels east and south from South Carolina Highway 151 and could be used to access the site if necessary.
The South Carolina Operation Radiological Emergency Response Plan provides guidance to State Law Enforcement for allowing passage of HBRSEP personnel if roads are closed but safe passage is possible.
Air Access to HBRSEP can be provided from staging areas and a landing zone via helicopters arranged for by Progress Energy.
Water The HBRSEP can also be accessed from the Robinson Lake. Robinson Lake can be accessed from multiple roadways adjacent to the owner controlled area.
Access to the HBRSEP can be through personal watercraft or watercraft arranged for by Progress Energy.
Rail The HBRSEP can be accessed via an active rail line and arranged for by Progress Energy.
United States Nuclear Regulatory Commission RA- 12-023, Enclosure Page 4 of 4 RFI 5 - Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
Interim staffing actions have not been taken nor are planned prior to completion of the emergency response organization staffing assessments.