ML14189A320
| ML14189A320 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/08/2014 |
| From: | Heacock D Virginia Electric & Power Co (VEPCO) |
| To: | Stephen Philpott Japan Lessons-Learned Division |
| Philpott S, NRR/JLD, 415-2365 | |
| References | |
| EA-12-049 | |
| Download: ML14189A320 (16) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 8, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Dominion Nuclear 5000 Dominion Blvd.
Glen Allen, VA 23060-6711
SUBJECT:
PLAN TO AUDIT THE REGIONAL RESPONSE CENTER PROOF OF CONCEPT DEMONSTRATION WITH SURRY POWER STATION UNIT NOS. 1 AND 2 REGARDING IMPLEMENTATION OF PHASE 3 RELATED TO ORDER EA-12-049 (MITIGATING STRATEGIES)
Dear Mr. Heacock:
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved.
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 capabilities. 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.
Industry is working cooperatively via the Strategic Alliance for FLEX Emergency Response (SAFER) to implement Regional Response Centers (RRCs) in Memphis, TN, and Phoenix, AZ.
as the repositories for offsite resources.
On July 17, 2014, the SAFER organization and staff from Surry Power Station, Unit Nos. 1 and 2 (Surry) plan to conduct a demonstration of SAFER's ability to activate the SAFER Control Center in Lynchburg, VA, as well as the Phoenix RRC, and deliver Phase 3 off-site equipment to the Surry site in accordance with the SAFER response plan. The enclosed document outlines the audit process that the NRC staff will follow while observing this demonstration. The NRC staff will document its observations from the demonstration as part of its evaluation of the readiness of the RRCs and the SAFER organization to support Phase 3 of licensees' Mitigating Strategies in response to Order EA-12-049.
D. Heacock If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.
Sincerely,
~t&4*,/,~
Steptien Philpott, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
Audit plan cc w/ encl: Distribution via Listserv
Audit Plan SAFER Response Proof of Concept Demonstration Surry Power Station Regional Response Center- Phoenix, AZ SAFER Control Center- Lynchburg, VA BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12054A736), requiring holders of operating licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of the order will be achieved. In accordance with the order, the OIPs were submitted by February 2013, and required subsequent 6-month updates were submitted in August 2013 and February 2014. Licensees are in the process of implementing the requirements identified in the order. Licensees are required to complete full implementation no later than two refueling cycles after submittal of the OIPs or by December 31, 2016, whichever comes first.
Since receiving the OIPs, the NRC staff has started the audit process, as well as reviewing any related additional information, to determine the extent to which the licensees are proceeding on a path towards successful implementation. The NRC staff has provided feedback to licensees on their submittals via Interim Staff Evaluations (ISEs); which were completed in February 2014.
Order EA-12-049 requires a three-phase approach for mitigating beyond-design-basis external events (BDBEE). The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment and spent fuel pool (SFP) cooling capabilities.
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. Industry is working cooperatively to implement Regional Response Centers (RRCs) in Memphis, TN and Phoenix, AZ as the repositories for offsite resources. The cooperative organization formed to manage and maintain these offsite resources and implement the Phase 3 offsite response is the Strategic Alliance for FLEX Emergency Response (SAFER).
The SAFER organization and staff from Surry Power Station, Unit Nos. 1 and 2 (Surry) plan to conduct a demonstration of SAFER's ability to activate the SAFER Control Center (SCC) in Lynchburg, VA, as well as the Phoenix RRC, and deliver Phase 3 offsite equipment to the Surry site in accordance with the SAFER response plan on July 17, 2014. This document outlines the audit process that the NRC staff will follow while observing this demonstration. The NRC staff will document its observations from the proof-of-concept demonstration as part of its evaluation of the readiness of the RRCs and the SAFER organization to support Phase 3 of licensees' Mitigating Strategies in response to Order EA-12-049.
Enclosure
NRC staff will observe and evaluate the proof-of-concept demonstration in accordance with the SAFER Response Plan based on the requirements in Order EA-12-049.
The Nuclear Energy Institute (NEI) developed NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" in August, 2012 (ADAMS Accession No. ML12242A378) to outline a process, by which, individual licensees would define and implement site-specific diverse and flexible mitigation strategies that reduce the risk associated with beyond-design-basis conditions. FLEX represents the industry's approach to addressing the three-phase approach for mitigation strategies, as described above. This guide was endorsed, with clarifications, by NRC interim staff guidance (ISG) JLD-ISG-2012-01 "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (ADAMS Accession No. ML12229A174).
AUDIT SCOPE The purpose of the audits is to observe the industry's RRC proof-of-concept demonstration in order to evaluate: (1) coordination between the licensee, the SAFER organization, and state and local officials in a simulated BDBEE scenario requiring the need for offsite equipment, and (2) the SAFER organization's ability and readiness to deliver needed offsite equipment to a United States nuclear power plant to support the licensees' Phase 3 strategies needed to comply with Order EA-12-049 (Mitigating Strategies).
The audit will be performed in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits," (ADAMS Accession No. ML082900195) to support the development of safety evaluations regarding licensees' final integrated plans in response to Order EA-12-049.
NRC AUDIT TEAM AND LOGISTICS NRC staff will observe the RRC Proof-of-Concept demonstration at various locations at or near Surry, at the SAFER Control Center in Lynchburg, VA, and at the RRC in Phoenix, AZ on July 17, 2014.
Area of Review Assigned Auditoiis)
Surry Training Complex Eric Bowman, NRR (simulated Control Room Mandy Halter, NRR and Amanda Marshall, NSIR simulated Corporate Emergency Response Center I Utility Single Point of Contact)
Additional Observers- Surry Training Complex James Polickoski, NRR Anne Boland, Rill Christine Lipa, Rill Steven Rose, Ril Wayne Schmidt, Rl Staging Area "B" I Surry Training Complex Eric Bowman, NRR Mandy Halter, NRR Amanda Marshall, NSIR
Staqinq Area "C" I Richmond International Airport Joshua Miller, NRR Regional Response Center- Phoenix, AZ Jack Davis, NRR Jeremy Bowen, NRR Stewart Bailey, NRR Carla Rogue-Cruz, NRR SAFER Control Center- Lynchburg, VA John Boska, NRR Stephen Philpott, NRR Charles Murray, NSIR DELIVERABLES NRC staff will conduct an exit meeting via conference call with the SAFER organization and Surry staff on a date to be determined following the RRC Proof-of-Concept demonstration in order to provide verbal observations.
Formal NRC observations will be documented in a report format following the SAFER organization's notification to the NRC that the RRCs are operational. NRC staff currently estimates that this report will be issued to the SAFER organization in September 2014.
INFORMATION NEEDS
- Latest version of the Surry SAFER Response Plan ("playbook")
- Surry operator and staff procedures
NRC Staff Schedule (Subject to change based on timing of the demonstration)
Thursday, July 17, 2014 07 45* Check in at demonstration locations 0800 Controller briefings 0830 Participant briefings 0900 Begin exercise 1430 Conclude Exercise 1530 Controllers exercise review with participants (conference call with all locations) 1600 Departure
- All times are local times at the Surry site (EDT). Times should be adjusted accordingly for participation at the Phoenix RRC.
RRC Proof of Concept Objectives Surry Simulated Control Room Surry Training Complex Surry, VA Participants Objective Est Actual Expected Actions Time (Event Time\
Demonstrate the ability of the
- Shift Manager declares
- Shift licensee to perform the initial 0900 Extended loss of alternating Manager request for SAFER FLEX (0700) current power and calls (Operations) Phase 3 equipment SAFER 2417 contact point
- Shift Security Coordinator
- Shift Manager I Emergency
- Site 0900-1000 Director advises CERC of Radiological Demonstrate effective (0700-0800) priority of equipment, nature Protection communications and of incident, selected SA (RP) coordination with the location, & status of site Supervisor Corporate Emergency access routes
- Shift Response Center (CERC)
- Shift Manager advises Maintenance CERC that SA "B" is ready Supervisor to receive equipment.
- Assesses plant access &
0900-1400 area infrastructure (SA "B",
(0700- 0300, routes, etc.)
next day)
- coordinates clearing of Assessing and clearing of access route impediments access routes, preps to to SA "B" receive shipment
- makes preparations to receive shipments at SA "B" (equipment movement, operation, connection, refueling, etc.)
- determines Protected Area Coordination with Security I requirements for equipment Throughout RP (Protected Area & personnel (SecurityiRP) demonstration requirements)
- assesses additional resources to call in
- transitions from Phase 1 (installed) to Phase 2 equipment (onsite portable)
- make plans to transition Demonstrate effective from Phase 2 to Phase 3 Throughout Command and Control equipment demonstration Structure for a BDBEE - clear access routes
- staging support equipment
- prepare SA "B"
- manage staging &
deployment of RRC equipment
RRC Proof of Concept Objectives Simulated Corporate Emergency Response Center (CERC)
Surry Training Complex Surry, VA Participants Objective Est Actual Expected Actions Time (Event Time) 0900-0915
- CERC Logistics Coordinator
- CERC (0700 - 0800) establishes communication Logistics with site and assumes role Coordinator I of SPOC Single Point
- SPOC confirms that Phase of Contact 3 equipment has been (SPOC) requested from SAFER 24/7 contact point.
0915
- SPOC advises SAFER of Demonstrate effective (0800) priority of equipment and coordination between the site nature of incident SPOC and the SAFER Control
- The SPOC communicates a Center (SCC) until the SAFER staging area "C" or "D" SA Lead is operational at the location and the associated staging area. access routes that are both accessible and available for intended operations (status Throughout of site access routes) demonstration
- SCC and SPOC have periodic updates on shipment & routes (location/ETA) & mitigates potential issues/delays
- The SPOC coordinates Throughout access of SAFER demonstration equipment and personnel to the nuclear site (i.e.,
identifies access route to SA B, facilitates provisions Demonstrate the ability to for entry into restricted support the access of SAFER access areas, equipment personnel and equipment to security, rad briefings, etc).
the nuclear site (i.e., assess
- Assesses plant access and and select access route and area infrastructure (SA B, staging area, entry to site routes, road conditions w/in protected areas).
25-mile radius, etc.)
coordinates clearing of access routes with EOC
- Receive I assess weather conditions for helicopter operations
Throughout
- Inform SA Lead when site Demonstrate effective ready for delivery coordination with SA "C" I SA 1230
- Provide weather conditions for helicopter operations
- State I Local agencies assess plant access and area infrastructure (routes Throughout to SAC, SAD and the site)
Demonstrate effective licensee demonstration
- Determine accessibility and coordination with state and availability of SA C and SA local agencies and D (VA Department of representatives to address Transportation (DOT), VA licensee needs.
Police, airport officials)
- coordinate clearing of staging areas and route impediments
- The SPOC and SA Lead Simulate the Utility's SPOC 1415- 1430 communicate to the sec support for the turnover of (0400 - 0700, that RRC equipment has equipment. next day) been received and turned over to utility personnel.
RRC Proof of Concept Objectives Staging Area "C" Richmond International Airport- Dominion Hangar Richmond, VA Participants Objective Est Actual Expected Actions Time (Event Time)
- SA Coordinator will Lead provide essential services for Throughout establish essential services
- VA staging area personnel. demonstration (lodging, food, shelter), see Departmnent also Appendix 5C, step 5.
of Health
- SA C Facilities Mgr
( Rad iolog ica I contacted by SPOC to Health) ensure airport is ready
- Surry Escort 0915-1215
- Escort T earn Lead Team Lead (0800- 2300) dispatched by On Shift staff Demonstrate effective (prestaged at SA "C")
coordination between the
- Escort Team Lead briefs licensee and SA "C" At the VA personnel being dispatched Emergency to SA B Operations - safety brief Center - escort arrangements (Richmond, VA): - planUroad conditions Demonstrate mobilization of
- Virginia (VA) staging area personnel. 1145 "C" at the required time Department (handled by SCC SA (2100) (pre-staged) and establish of Emergency Coordinator) communications with the Management sec
- VA State
- SA Lead simulates Police 1145-1215 establishing an operational
Demonstrate the ability to
- SA Lead reports to SCC establish and maintain staging Team Lead that SAC is area facilities and equipment.
operational 1215
- Simulate the establishment (2300) of SA "D" for helicopter operations
- Aircraft arrive and unload at Demonstrate the ability to 1200 SAC (simulated) manage arriving transportation (2200)
- SA Lead monitor the arrival providers upon arrival at the of trucks and equipment as staging area.
documented on Appendix 51.
Demonstrate command and SA lead will:
control of the offsite staging 1145- 1215
- Assume the role of area (SA "C") and the ability to (2100- 2300) communicator with the manage the movement and SPOC from the SCC Lead.
release of shipments from the
- Conduct staging area
offsite staging area to the on- briefings as documented on site staging area (SA "B"). Appendix 5H.
- Release equipment 1230 shipments as directed by (0200) the SPOC (When directed by the SPOC, SA Lead instructs truck drivers to deploy to site with specified equipment.)
RRC Proof of Concept Objectives Staging Area "B" Surry Training Complex I Adjacent Parking Lot Surry, VA Participants Objective Est Actual Expected Actions Time (Event Time)
- As directed by the SPOC, Augmented ERO: set up command and
- Shift Security 0915- 1145 control facility (simulated)
Coordinator Establish staging area "B" and (0800 - 21 00)
- Establish communications
- Shift demonstrate command and with the SPOC, the CERC, Operations control logistics etc. (simulated)
Supervisor
- Turn over to lead ERO
- Site member- follows ERO Radiological procedures (simulated)
Protection
- prioritizes & prepares to Assessing and clearing of Supervisor Throughout receive equipment at SA "B" access routes, preps to
- Shift receive shipment, coordination demonstration
- Security coordinates access Maintenance and escort arrangements with Security I RP (Protected Supervisor for personnel entering Area requirements)
Protected Area
- equipment arrives at SA "B" 1400- 1430 (simulated I pre-staged)
(0300 - 0700,
- SAFER SA B personnel next day) direct rigging and Simulate delivery I receipt and offloading of equipment turnover of equipment at (simulated),
Staging Area (SA) "B"
- SAFER SA B personnel conduct equipment turnover and initial operation with site personnel (simulated)
RRC Proof of Concept Objectives Regional Response Center Phoenix, AZ
- Estimated actual times are local time for Phoenix, AZ Participants Objective Est Actual Expected Actions Time*
(Event Time)
- RRC staffing for activation
- RRC Lead Demonstrate the activation of 0615 occurs within 60 minutes the RCC functions within 60 (0800) from a utility request.
minutes from a utility request. Documented on SAFER Response Plan (SRP)
Appendix 3C.
- The facility is functional as Demonstrate command and 0615 documented on SRP control of operations at the (0800) Appendix 3A.
RRC.
- The equipment is identified 0730-0800 by review of the SRP Demonstrate the ability to (1000- 1200) Chapter 7 equipment list.
execute a loading and
- Fed Ex arrives at RRC shipping strategy.
- Briefings are conducted lAW SRP Appendix 3E.
- Fed Ex vehicle loads simulated equipment (box)
- Fed Ex vehicle dispatches 0800-0830 to airport (1200- 1400)
- Fed Ex vehicle arrives at airport, clears security and Simulate deployment of delivers equipment (box) to equipment shipments from the ramp area for simulated RRC. plane loading
- The RRC is deactivated Simulate deactivation of the 1130 lAW SRP Appendix 38, (as RRC. (T + 3 Days) required).
RRC Proof of Concept Objectives SAFER Control Center Lynchburg, VA Participants Objective Est Actual Expected Actions Time (Event Time}
Demonstrate the ability of the
- SAFER 24/7 contact
- sec Lead SAFER 24/7 notification point 0900 receive a request, log the
- sec L&T to receive a request for FLEX (0700) time and notify the SAFER Coordinator Phase 3 equipment and to Team within 15 minutes
- sec sA notify the SAFER SCC Lead following receipt of a Coordinator within 15 minutes. request for RRC equipment.
Demonstrate the ability of
personnel to report to the (0715) demonstration sec.
Demonstrate the ability of
personnel to report to the (0715) demonstration RRC.
- sec minimum staffing for 0915 activation is achieved within Demonstrate the activation of (0800) 60 minutes from a utility the sec within 60 minutes request and is documented from a utility request in Appendix 2C of the SAFER Response Plan (SRP1 Demonstrate the activation of
- The SA Coordinator arrives the Staging Area Coordinator 0915 at the sec within the function at the sec within 60 (0800) required time period as minutes from a utility request. documented in SRP Appendix 2C.
Demonstrate the activation of
- The L& T Coordinator the L& T function at the SCC 0915 arrives at the sec within within 60 minutes from a utility (0800) the required time period as request. documented in SRP Appendix 2C.
- SA Coordinator identifies Demonstrate mobilization of 0915 limited personnel and staging area personnel. (0-1) directs deployment to the staging area lAW SRP Appendix 5C.
- The following are completed Demonstrate command and 0915- 1015 within 60 minutes of arrival:
control of the SAFER (0800- 0900) - SRP Appendix 2A response via the SCC Lead. (Facility Preparation)
- SRP Appendix 2D (Initial Contact Checklist)
o Periodic communications 0915- 1145 with the SPOC occur Demonstrate effective (0800- 2100) regarding the assessment communications via the sec and selection of staging Lead and the site's Single area and the associated Point of Contact (SPOC) until access route accessibility.
the staging area is operational.
- Periodic briefings are conducted lAW SRP Appendix 2E.
o L& T Coordinator- Notifies Demonstrate the ability to 0915- 1000 ground transport providers notify and provide reporting (0800- 0900) using SRP Addendum 8 instructions to ground contact information (directs transport providers for RRC FedEx to report to RRC, shipments. determines mode of transportation, and notifies RRC) o L&T Coordinator- Reviews 0915- 1000 the proposed travel routes Demonstrate the ability to (0800- 0900) and modes with the assess travel route conditions transportation provider.
between the RRC and Staging o L& T Coordinator-Areas 8, Cor D.
Determines a Fly or Drive decision as documented in SRP Appendix 4C.
Demonstrate the ability to o Simulate notification of air notify and coordinate 0915-1000 transport providers using necessary air transport for (0800- 0900) SRP Addendum 8 and specific travel segments, Appendix 4E.
(regional airport or staging area helicopter lifts).
o L& T Coordinator- Notifies the sec of the ETA of Throughout transportation providers.
Demonstrate the ability to demonstration o L& T Coordinator- Acquires coordinate the departure of a status from transportation shipments from the RRC and providers hourly or if there to maintain a status on the is a change.
shipments.
o L& T Coordinator-Coordinate action for abnormal conditions lAW SRP Appendix 48 Simulate command and o The SCC Team Lead control for deactivation of the 1430 deactivates the sec as sec. (T + 3 Days) documented in SRP Appendix 28, (as required).
D. Heacock If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.
Sincerely, IRA/
Stephen Philpott, Project Manager Orders Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-280 and 50-281
Enclosure:
Audit plan cc w/ encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsRgn2MaiiCenter Resource JLD R/F SPhilpott, NRR/JLD RidsNrrDorllp12-1 Resource JBowen, NRR/ JLD RidsNrrPMSurry Resource MHalter, NRR/JLD RidsNrrLASLent Resource JPolickoski, NRR/JLD RidsAcrsAcnw_MaiiCTR Resource V Sreenivas, NRR/DORL ADAMS Accession No ML14189A320 OFFICE NRR/JLD/JOMB/PM NRR/JLD/JOMB/PM NRR/JLD/LA NAME SPhilpott MHalter Slent DATE 07/08/14 07/08/14 07/08/14 OFFICE NRR/ JLD/JOMB/BC NRR/JLD/JOMB/PM NAME JBowen SPhilpott DATE 07/08/14 07/08/14 OFFICIAL AGENCY RECORD