ML14220A502

Request for Additional Information Regarding Title 10 of the Code of Federal Regulations 50.54(f) Recommendation 9.3 Phase 2 Staffing Assessment

ML14220A502
Person / Time
Site:	North Anna
Issue date:	08/21/2014
From:	Harris B Japan Lessons-Learned Division
To:	Heacock D Virginia Electric & Power Co (VEPCO)
Harris B, NRR/JLD, 415-2277
References
TAC MF4319, TAC MF4320
Download: ML14220A502 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 21, 2014 Mr. David A. Heacock President and Chief Nuclear Officer Virginia Electric and Power Company lnnsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

NORTH ANNA POWER STATION, UNITS 1 AND 2- REQUEST FOR ADDITIONAL INFORMATION REGARDING TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50, SECTION 50.54(F) RECOMMENDATION 9.3 PHASE 2 STAFFING ASSESSMENT (TAC NOS. MF4319 AND MF4320)

Dear Mr. Heacock:

By letter dated May 7, 2014, to the U.S. Nuclear Regulatory Commission (NRC) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14133A011), Virginia Electric and Power Company submitted its response for North Anna Power Station, Units 1 and 2 to the NRC's Request for Information issued on March 12, 2012 ADAMS Accession No. ML12053A340) pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, Section 50.54(f) regarding Near-Term Task Force [NTTF] Recommendations 2.1, 2.3, and 9.3.

The NRC staff is reviewing the information submitted and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). A response to these RAis within 30 days from the date of issuance of this letter will facilitate a more efficient review of your staffing submittal related to NTTF Recommendation 9.3.

D. Heacock If you have any questions related to the enclosed RAis or the requested submission date, please contact me at (301) 415-2277 or via email at Brian. Harris2@nrc.gov.

Sincerely, Bria~roject Manager Hazards Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION NEAR-TERM TASK FORCE RECOMMENDATION 9.3 STAFFING ASSESSMENT PHASE 2 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION. UNITS 1 AND 2 DOCKET NOS. 50-338 AND 50-339 On March 12, 2012 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a Request for information letter entitled "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." By letter dated May 7, 2014, to the NRC (ADAMS Accession No. ML14133A011), Virginia Electric and Power Company submitted its response for North Anna Power Station (North Anna), Units 1 and 2 to the NRC's request. The requested information associated with Recommendation 9.3, Emergency Preparedness, focused on Communications and Staffing and this request for additional information (RAI) focuses on the information requested for the Phase 2 staffing assessment.

In your Phase 2 Staffing Assessment dated May 7, 2014, you provided information that stated the following: (1) North Anna Power Station (NAPS) current on-shift staffing may not be sufficient to perform the FLEX Support Guidelines (FSGS) identified by therstation to support activities flowing a Beyond-Design-Basis External Event, (2) Shift personnel are not yet trained to perform FSG tasks, and (3) The qualification of on-shift auxiliary operators (AOs) requires further review to ensure their capabilities to implement the FSG strategies.

The NRC staff has reviewed your Staffing Assessment dated May 7, 2014, and requests the following information to complete its review:

RAI #1 Provide an update or supplement to the Phase 2 Staffing Assessment that indicates NAPS has determined that the current on-shift staffing is capable of performing all required FSG tasks and all associated required training has been provided. Include any actions taken to correct this issue, or justification as to why no action is required.

RAI#2 A review was also completed of the current security plan to identify the documented on shift security personnel (Revision 19). The following site specific information was reviewed from the North Anna staffing study submittal (P.6, 17, 18, 21, 22). These specific page numbers provided information concerning the use of security personnel during events that were Enclosure

described in the staffing study. The site specifically stated that, "security personnel perform both security contingency plan actions and EP tasks consisting of ERO notification and site personnel accountability. A representative of the North Anna Power Station Security Department analyzed the EP tasks assigned to on-shift security individuals. It was concluded that performance of the EP tasks did not cause an overlap with their tasks related to the security plan.

The following items were noted:

1) Security is tasked to remove debris and to configure certain site equipment for use.

2) The staffing analysis determined that these duties (i.e., FSGs) would not cause an overlap with the security tasks assigned in the site security plan.

3) In accordance with Appendix C to Part 73, Section 11.8.5(i), licensees shall establish and maintain written implementing procedures that provide specific guidance and operating details that identify the actions to be taken and decisions to be made by each member of the security organization who is assigned duties and responsibilities required for the effective implementation of the security plans and the site protective strategy.

The NRC staff has reviewed your Staffing Assessment dated May 7, 2014, and requests the following information to complete its review.

1) Has security received site specific training for removing and how to configure certain site equipment (e.g., equipment use, approaches to remove debris, associated procedures)?

What are the main components of this training? How often is this training provided to security personnel?

2) Describe in detail how the normal on shift security personnel are allocated to provide individuals to support EP functions simultaneously continuing to maintain their tasks related to the security plan. This description should address the tiered approach of the use of security personnel that is discussed in the NEI document, "Generic Basis for Responses to Staffing Assessment Questions Related to Use of Security Personnel during a BDB Event Response". The response to this question should be reviewed for the applicability of 10 CFR 73.21.

3) Have site procedures been developed for how security personnel are released from supporting beyond design basis event activities which would include the priority of their dismissal? Are detailed security site procedures developed to return security to a normal posture after beyond design basis events?

ML14220A502 *via email OFFICE NRR/JLD/JHMB/PM NRR/JLD/LA NRR/DORULPL2-1 /PM* JLD/JHMB/BC NRR/JLD/JHMB/PM NAME BHarris Slent VSreenivas SWhaley (RKuntz for) BHarris DATE 08/18/14 08/19/14 08/18/14 08/21/14 08/21/14