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 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company Dominion Nuclear 5000 Dominion Blvd.
Glen Allen, VA 23060-6711 July 8, 2014
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.
If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.
Docket Nos. 50-280 and 50-281
Enclosure:
Audit plan cc w/ encl: Distribution via Listserv Sincerely,
~t&4*,/,~
Steptien Philpott, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation
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 1 0 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")
RRC - SAFER Plan for Proof of Concept 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.
Participants Shift Manager (Operations)
Shift Security Coordinator Site Radiological Protection (RP)
Supervisor Shift Maintenance Supervisor RRC Proof of Concept Objectives Surry Simulated Control Room Surry Training Complex Surry, VA Objective Est Actual Time (Event Time\\
Demonstrate the ability of the licensee to perform the initial 0900 request for SAFER FLEX (0700)
Phase 3 equipment 0900-1000 Demonstrate effective (0700-0800) communications and coordination with the Corporate Emergency Response Center (CERC) 0900-1400 (0700- 0300, next day)
Assessing and clearing of access routes, preps to receive shipment Coordination with Security I Throughout RP (Protected Area demonstration requirements)
Demonstrate effective Throughout Command and Control Structure for a BDBEE demonstration Expected Actions
- Shift Manager declares Extended loss of alternating current power and calls SAFER 2417 contact point
- Shift Manager I Emergency Director advises CERC of priority of equipment, nature of incident, selected SA location, & status of site access routes
- Shift Manager advises CERC that SA "B" is ready to receive equipment.
- Assesses plant access &
area infrastructure (SA "B",
routes, etc.)
- coordinates clearing of access route impediments to SA "B"
- makes preparations to receive shipments at SA "B" (equipment movement, operation, connection, refueling, etc.)
- determines Protected Area requirements for equipment
& personnel (SecurityiRP)
- assesses additional resources to call in
- transitions from Phase 1 (installed) to Phase 2 equipment (onsite portable)
- make plans to transition from Phase 2 to Phase 3 equipment
- clear access routes
- staging support equipment
- prepare SA "B"
- manage staging &
deployment of RRC equipment
Participants CERC Logistics Coordinator I Single Point of Contact (SPOC)
RRC Proof of Concept Objectives Simulated Corporate Emergency Response Center (CERC)
Surry Training Complex Surry, VA Objective Est Actual Expected Actions Time (Event Time) 0900-0915
- CERC Logistics Coordinator (0700 - 0800) establishes communication with site and assumes role of SPOC
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 Demonstrate the ability to SA B, facilitates provisions support the access of SAFER for entry into restricted personnel and equipment to access areas, equipment the nuclear site (i.e., assess security, rad briefings, etc).
and select access route and
- Assesses plant access and staging area, entry to site area infrastructure (SA B, protected areas).
routes, road conditions w/in 25-mile radius, etc.)
coordinates clearing of access routes with EOC
- Receive I assess weather conditions for helicopter operations
Throughout
- Provide weather conditions for helicopter operations
- State I Local agencies assess plant access and area infrastructure (routes Demonstrate effective licensee Throughout to SAC, SAD and the site) coordination with state and demonstration
- Determine accessibility and local agencies and availability of SA C and SA representatives to address D (VA Department of licensee needs.
Transportation (DOT), VA 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.
Participants SAFER SA Lead VA Departmnent of Health
( Rad iolog ica I Health)
Surry Escort Team Lead At the VA Emergency Operations Center (Richmond, VA):
Department of Emergency Management VA State Police VA DOT RRC Proof of Concept Objectives Staging Area "C" Richmond International Airport-Dominion Hangar Richmond, VA Objective Est Actual Expected Actions Time (Event Time)
Demonstrate the ability to
- SA Coordinator will provide essential services for Throughout establish essential services staging area personnel.
demonstration (lodging, food, shelter), see also Appendix 5C, step 5.
- Escort T earn Lead Demonstrate effective (0800- 2300) dispatched by On Shift staff coordination between the (prestaged at SA "C")
licensee and SA "C"
- safety brief
- escort arrangements
- planUroad conditions Demonstrate mobilization of
1145 "C" at the required time (handled by SCC SA (2100)
(pre-staged) and establish Coordinator) communications with the sec
- SA Lead simulates 1145-1215 establishing an operational (2100- 2300) staging area lAW with Demonstrate the ability to Appendix 50 and 5E.
establish and maintain staging
operational 1215
- Simulate the establishment (2300) of SA "D" for helicopter operations Demonstrate the ability to
- Aircraft arrive and unload at manage arriving transportation 1200 SAC (simulated) providers upon arrival at the (2200)
of trucks and equipment as 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.)
Participants Augmented ERO:
Shift Security Coordinator Shift Operations Supervisor Site Radiological Protection Supervisor Shift Maintenance Supervisor RRC Proof of Concept Objectives Staging Area "B" Surry Training Complex I Adjacent Parking Lot Surry, VA Objective Est Actual Expected Actions Time (Event Time)
- As directed by the SPOC, set up command and 0915-1145 control facility (simulated)
Establish staging area "B" and (0800 - 21 00)
- Establish communications demonstrate command and with the SPOC, the CERC, control logistics etc. (simulated)
Assessing and clearing of
- prioritizes & prepares to Throughout receive equipment at SA "B" access routes, preps to demonstration
- Security coordinates access receive shipment, coordination and escort arrangements with Security I RP (Protected for personnel entering Area requirements)
Protected Area
- equipment arrives at SA "B" 1400- 1430 (simulated I pre-staged)
(0300 - 0700,
- SAFER SA B personnel Simulate delivery I receipt and next day) direct rigging and turnover of equipment at offloading of equipment Staging Area (SA) "B" (simulated),
- 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
(T + 3 Days) required).
Participants sec Lead sec L&T Coordinator sec sA Coordinator RRC Proof of Concept Objectives SAFER Control Center Lynchburg, VA Objective Est Actual Time (Event Time}
Demonstrate the ability of the SAFER 24/7 notification point 0900 to receive a request for FLEX (0700)
Phase 3 equipment and to notify the SAFER SCC Lead within 15 minutes.
Demonstrate the ability of SAFER to notify SCC 0915 personnel to report to the (0715) demonstration sec.
Demonstrate the ability of SAFER to notify RRC 0915 personnel to report to the (0715) demonstration RRC.
Demonstrate the activation of 0915 the sec within 60 minutes (0800) from a utility request Demonstrate the activation of the Staging Area Coordinator 0915 function at the sec within 60 (0800) minutes from a utility request.
Demonstrate the activation of the L& T function at the SCC 0915 within 60 minutes from a utility (0800) request.
Demonstrate mobilization of 0915 staging area personnel.
(0-1)
Demonstrate command and 0915-1015 control of the SAFER (0800- 0900) response via the SCC Lead.
Expected Actions
- SAFER 24/7 contact receive a request, log the time and notify the SAFER Team within 15 minutes following receipt of a request for RRC equipment.
- sec personnel receive notification and respond.
- RRC personnel receive notification and respond.
- sec minimum staffing for activation is achieved within 60 minutes from a utility request and is documented in Appendix 2C of the SAFER Response Plan (SRP1
- The SA Coordinator arrives at the sec within the required time period as documented in SRP Appendix 2C.
- The L& T Coordinator arrives at the sec within the required time period as documented in SRP Appendix 2C.
- SA Coordinator identifies limited personnel and directs deployment to the staging area lAW SRP Appendix 5C.
- The following are completed within 60 minutes of arrival:
- SRP Appendix 2A (Facility Preparation)
- SRP Appendix 2D (Initial Contact Checklist)
o Periodic communications Demonstrate effective 0915-1145 with the SPOC occur communications via the sec (0800- 2100) regarding the assessment Lead and the site's Single and selection of staging Point of Contact (SPOC) until area and the associated the staging area is operational.
access route accessibility.
- 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 Demonstrate the ability to 0915-1000 the proposed travel routes assess travel route conditions (0800- 0900) and modes with the between the RRC and Staging transportation provider.
Areas 8, Cor D.
o L& T Coordinator-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 Demonstrate the ability to Throughout transportation providers.
coordinate the departure of demonstration o L& T Coordinator-Acquires shipments from the RRC and a status from transportation to maintain a status on the providers hourly or if there shipments.
is a change.
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).
If you have any questions, please contact me at 301-415-2365 or by e-mail at Stephen. Philpott@nrc.gov.
Docket Nos. 50-280 and 50-281
Enclosure:
Audit plan cc w/ encl: Distribution via Listserv DISTRIBUTION:
PUBLIC JLD R/F RidsNrrDorllp12-1 Resource RidsNrrPMSurry Resource RidsNrrLASLent Resource RidsAcrsAcnw_MaiiCTR Resource ADAMS Accession No ML14189A320 OFFICE NRR/JLD/JOMB/PM NAME SPhilpott DATE 07/08/14 OFFICE NRR/ JLD/JOMB/BC NAME JBowen DATE 07/08/14 Sincerely, IRA/
Stephen Philpott, Project Manager Orders Management Branch Japan Lessons Learned Division Office of Nuclear Reactor Regulation RidsRgn2MaiiCenter Resource SPhilpott, NRR/JLD JBowen, NRR/ JLD MHalter, NRR/JLD JPolickoski, NRR/JLD V Sreenivas, NRR/DORL NRR/JLD/JOMB/PM NRR/JLD/LA MHalter Slent 07/08/14 07/08/14 NRR/JLD/JOMB/PM SPhilpott 07/08/14 OFFICIAL AGENCY RECORD