Text

Day Response to NRC Bulletin 2011-01, Mitigating Strategies
	ML11195A209
Person / Time
Site:	South Texas
Issue date:	07/07/2011
From:	Bowman C; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BL-11-001, NOC-AE-11002696
	Download: ML11195A209 (21)
	v • d • e

Nuclear Operating Company South Texas Prolect Electric GeneratingStation PO. Box 289 Wadsworth, Texas 77483 July 7, 2011 NOC-AE-1 1002696 10 CFR 50.54(0 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket No. STN 50-498, STN 50-499 60-Day Response to NRC Bulletin 2011-01, Mitigating Strategies

Reference:

Letter dated June 8, 2011 from C. T. Bowman, STP Nuclear Operating Company to NRC Document Control Desk, "30-Day Response to NRC Bulletin 2011-01, "Mitigating Strategies," (NOC-AE-1 1002675) (ML11165A095)

The Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies,"

dated May 11, 2011, to request each licensee to provide a comprehensive verification of their compliance with the regulatory requirements of 10 CFR 50.54(hh)(2).

In NRC Bulletin 2011-01, the NRC requested each licensee to submit a written response within 30 days of the date of the Bulletin, which was provided in the above referenced letter.

Pursuant to 10 CFR 50.54(f), the attachment to this letter provides the STP Nuclear Operating Company's (STPNOC) response requested within 60 days of the date of the Bulletin to provide information regarding mitigation strategies programs for 10 CFR 50.54(hh)(2).

The attachment includes information that addresses measures that are currently in place as well as an additional planned action with expected completion date. The additional planned action is considered a voluntary enhancement. There are no commitments in this letter.

If you have questions regarding this letter please contact either Robyn Savage (Licensing contact) at 361-972-7438 or me at 361-972-7454.

STI: 32897604

NOC-AE-I 1002696 Page 2 of 3 I declare under penalty of perjury that the foregoing is true and correct.

Executed on -T 7tU 1/

Charles T. Bowman General Manager Nuclear Safety Assurance rds

Attachment:

STPNOC 60-Day Response to Bulletin 2011-01

NOC-AE-1 1002696 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P.O. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

Attachment NOC-AE-1 1002696 Page 1 of 18 STPNOC 60-Day Response to Bulletin 2011-01 On May 11,2011, the NRC issued Bulletin 2011-01 'Mitigating Strategies'. Below is STP Nuclear Operating Company's (STPNOC) response to the 60 day information request.

Many of the items described below represent current station practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with established processes. Any changes involving commitments will be executed in accordance with NEI 99-04 Revision 0 "Commitment Management Guidelines".

NRC Request:

Within 60 days of the date of this bulletin, the NRC requests that licensees provide information regarding their mitigation strategies programs for 10 CFR 50.54(hh)(2).

In responding to the following questions, provide information that addresses measures that are currently in place, noting any additional planned actions with expected completion dates.

NRC Request 1:

Describe in detailthe maintenance of equipment procuredto support the strategiesand guidancerequiredby 10 CFR 50.54(hh)(2) in orderto ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.

b. Basis for establishingeach maintenance item (e.g., manufacturer'srecommendation, code or standard applicableto the craft). This should include considerationof storage environment impact on the maintenance necessary.

These examples are not meant to limit your response if you use other methods to addressthe issues described above.

STPNOC Response (1)

Currently STPNOC performs preventive maintenance as described in the table below to support the mitigating strategies required by 10 CFR 50.54(hh)(2) ensuring the equipment is functional when needed.

Equipment, such as fire hoses, the B.5.b Diesel Driven Portable Pump, and other components are stored in a dry environment to ensure full availability when needed.

The maintenance activities listed below have been established to ensure that the procured B.5.b equipment can perform its intended function.

Attachment NOC-AE-1 1002696 Page 2 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Equipment Preventive Maintenance Periodicity Basis B.5.b Diesel Driven Verify pump hours. If Every 4 Manufacturer recommended Portable Pump indicated hours are greater weeks maintenance than 250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months of operation then lubricate pump bearing.

B.5.b Diesel Driven Battery Float Charge Continuous Manufacturer Portable Pump -unless Recommendation for starting B.5.b Diesel reliability - maintain max Driven capacity Portable Pump in use B.5.b Diesel Driven 1) Lubricate pump Semi- Manufacturer recommended Portable Pump bearing every annual maintenance 250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months of operation, if required

2) service fire extinguisher

3) service battery

4) change engine oil and replace oil filter

5) check coolant pump weep hole foam filter B.5.b Diesel Driven 1) Lubricate pump Annual Manufacturer recommended Portable Pump bearing every inspection maintenance 250 hours0.00289 days 0.0694 hours 4.133598e-4 weeks 9.5125e-5 months of operation, if required

2) change engine oil and replace oil filter

3) check coolant pump weep hole foam filter

4) clean crankcase vent tube

5) check air intake hoses, connections and systems

6) replace fuel filter

Attachment NOC-AE-1 1002696 Page 3 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Equipment Preventive Maintenance Periodicity Basis element(s)

7) check belt tensioner and belt wear

8) check cooling system

9) coolant solution analysis - add supplemental coolant additives, as needed

10) pressure test cooling system

11) check engine speeds

12) check crankcase vibration damper

13) check engine ground connection

14) service fire extinguisher

15) service battery B.5.b Contingency Replace all of the Every 3 Station has elected to fire hoses contingency fire hoses. years replace B.5.b fire hoses rather than hydrostatically test every three years Pressure and Standard instrument Every 3 Industry Standard calibration Differential calibration years frequency. Frequency is the Pressure gauges same as pressure gauges used for Inservice Testing of Auxiliary Feedwater pumps, which is the system the gauges are used in.

Electronic flow Battery check Quarterly Normal inventory frequency gauges of emergency equipment.

Spent Fuel Pool Lubricate Every 3 Manufacturer recommended Spray Monitors years maintenance

Attachment NOC-AE-1 1002696 Page 4 of 18 STPNOC 60-Day Response to Bulletin 2011-01 NRC Request 2 Describe in detail the testing of equipmentprocuredto support the strategiesand guidancerequiredby 10 CFR 50.54(hh)(2) in orderto ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategieswere initially feasible.

b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

c. A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

STPNOC Response (2)

All strategies developed at South Texas Project (STP) are contained within an approved procedure or guideline. Per the Westinghouse Owners Group - Emergency Response Guidelines, as well as specific procedure processes, new strategies or changes to existing strategies contained within procedures are required to be validated. Subsequently, when new procedures or strategies contained within existing procedures are developed (that may contain Operator Time Critical Actions) the procedures are validated on the actual plant, if possible.

However, if it is not possible to actually perform a validation of a procedure due to regulatory or plant condition without an increase in risk, then a simulation, walk down, or mock up is performed using the procedure, prior to procedure approval.

In addition, training is provided to operating crews, during which, any further deficiencies may be noted and corrected.

The 10 CFR 50 Appendix B Corrective Action Program (CAP) is used to document failures, establish priorities for corrective actions and perform trending.

Any maintenance needed will follow the normal work flow process as described in normal station work flow guidelines and processes. As of the date of this response, there are no outstanding deficiencies that would render the strategies not viable.

Attachment NOC-AE-1 1002696 Page 5 of 18 STPNOC 60-Day Response to Bulletin 2011-01 The following table is a description of testing accomplished to ensure the strategies' initial feasibility.

Strategy Description Spent Fuel Pool External Time validation Makeup and External Spray Spent Fuel Pool Spray Spray pattern validation The following table describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Equipment Test Description Periodicity Basis B.5.b Diesel Driven Unloaded run Every 4 weeks Manufacturer Portable Pump recommended maintenance B.5.b Diesel Driven Flow Verification See Note1 Judgment based on Portable Pump operational considerations B.5.b Contingency Replace all of the Every 3 years Station procedures fire hoses B.5.b contingency hydrostatically test fire hoses fire hoses every 3 years. Station has elected to replace B.5.b Contingency fire hoses rather than hydrostatically test them.

Note:

The pump was initially flow-tested upon receipt and recently in April 2011. The pump was previously run at least annually during outages to pump out the circulating water piping. A decision was made to discontinue the use of the pump for this purpose in the future. CR 11-6657 was written to develop a preventive maintenance activity to perform a periodic pump flow test or vendor recertification of the pump on an 18 month frequency.

Planned Action/Exoected ComDletion Date Action: STPNOC plans to develop a preventive maintenance (PM) activity to perform periodic pump flow testing or vendor recertification of the pump every 18 months.

Expected Completion Date:August 31, 2011

Attachment NOC-AE-1 1002696 Page 6 of 18 STPNOC 60-Day Response to Bulletin 2011-01 NRC Request 3 Describein detail the controls for assuringthat the equipment is availablewhen needed.

Examples of the types of information to include when providing your response to Question (3) are:

a. A description of any inventory requirementsestablished for the equipment.

b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.

These examples are not meant to limit your response if you use other methods to addressthe issues described above.

STPNOC Response (3)

In addition to the controls described in Responses 1 and 2, procured non-permanently installed B.5.b equipment is inventoried quarterly in accordance with station processes or procedures.

This inventory assures the items are stored in the proper quantities and location, equipment shelf lives (foam, batteries, etc.), equipment is accessible, and storage locations are controlled.

(See Table below.)

Inventory procedures require deficiencies to be recorded and resolved. If any discrepancy cannot be corrected at the time of the inventory, then they are entered into the Corrective Action Program (CAP). As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.

Emergency Locker Inventory Equipment Inventory Special Items Verified (e.g. proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, equipment is accessible.)

Fire Hoses Quarterly Inside Item quantity verified and Buildings (dry accessible conditions)

Various lengths of Quarterly Locked Item quantity verified, inspected to rope closed ensure in good condition and Emergency accessible Lockers

Attachment NOC-AE-1 1002696 Page 7 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Equipment Inventory Special Items Verified (e.g. proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, equipment is accessible.)

Copies of Quarterly Locked Item quantity verified, inspected to applicable closed ensure in good condition and procedures: Emergency accessible Includes Lockers Emergency Operating Procedures (EOP's) Mitigation Strategies (OPOP10's)

Off Normal Procedures (OPOP04's)

Gated wyes at Quarterly Staged in Item quantity verified, inspected to each of the climate ensure in good condition, in installed fire controlled correct position, and accessible monitor's buildings Flashlights, Quarterly Locked Item quantity verified, inspected to Battle Lanterns, closed ensure in good condition, Portable Lanterns Emergency accessible, and verified functional Lockers batteries Keys Quarterly Locked Item quantity verified, inspected to closed ensure in good condition and Emergency accessible Lockers Wrenches and Quarterly Locked Item quantity verified, inspected to tools closed ensure in good condition and Emergency accessible Lockers Reducers and Quarterly Locked Item quantity verified, inspected to couplings closed ensure in good condition and Emergency accessible Lockers Flange and Quarterly Locked Item quantity verified, inspected to Gaskets closed ensure in good condition and Emergency accessible Lockers Breaker tools Quarterly Locked Item quantity verified, inspected to closed ensure in good condition and Emergency accessible Lockers

Attachment NOC-AE-1 1002696 Page 8 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Equipment Inventory Special Items Verified (e.g. proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, equipment is accessible.)

Differential Quarterly Locked Item quantity verified, inspected to pressure gauges closed ensure in good condition and with braided hoses Emergency accessible Lockers Pressure gauge with braided hose SG PORV Manual Quarterly Locked Item quantity verified, inspected to Hydraulic Pump closed ensure in good condition and with hoses, fittings Emergency accessible and wrench Lockers Electronic flow Quarterly Locked Item quantity verified, inspected to gauges with closed ensure in good condition and instructions Emergency accessible Lockers No calibration required Air jumper hoses Quarterly Locked Item quantity verified, inspected to with fittings and closed ensure in good condition and hose connectors Emergency accessible Lockers Bag of wood blocks Quarterly Locked Item quantity verified, inspected to for valve blocking closed ensure in good condition and devices Emergency accessible Lockers Safety Harnesses Quarterly Locked Item quantity verified, inspected to closed ensure in good condition and Emergency accessible Lockers Trailer mounted Weekly Inside Item quantity verified, inspected to firefighting monitor building (dry ensure in good condition and storage) accessible Required fire hose Weekly Inside Item quantity verified, inspected to lengths on trailer building (dry ensure in good condition and storage) accessible Foam educting Weekly Inside Item quantity verified, inspected to drum kit on trailer building (dry ensure in good condition and storage) accessible (19) 55-gallon Weekly Inside Item quantity verified, inspected to barrels of Aqueous building (dry ensure in good condition and Film Forming Foam storage) accessible (AFFF)

Attachment NOC-AE-1 1002696 Page 9 of 18 STPNOC 60-Day Response to Bulletin 2011-01 B.5.b Diesel Driven Fire Pump Inventory Equipment Inventory Special Items Verified (e.g.

Frequency Storage proper quantities, Controls locations, pressures, calibrations, shelf life, equipment is accessible.)

B.5.b Diesel Driven Quarterly Located in an Item quantity verified and Portable Pump, including enclosed metal accessible Pintle Hitch building Trailer with B.5.b Diesel Quarterly Located in an Item quantity verified and Driven Portable Pump enclosed metal accessible suction hoses building Fire hoses Quarterly Located in an Item quantity verified and enclosed metal accessible building Flange connections and Quarterly Located in an Item quantity verified and flange with reducer enclosed metal accessible building Rope, wrenches, and Quarterly Located in an Item quantity verified and gaskets enclosed metal accessible building Pump key not inserted in Quarterly Located in an Verified to assure battery switch enclosed metal not drained and remains building charged.

Pump Battery trickle charger connected and ON.

Pump Fuel Oil tank full Quarterly Located in an Verify fuel quantity enclosed metal building Gated Wyes Quarterly Located in an Item quantity verified and Double female fittings enclosed metal accessible Double male fittings building Current revision of Quarterly Located in an Item quantity verified and procedures for Spent Fuel enclosed metal accessible Pool Damage Mitigation building Strategies and Alternate Fire Protection System Operation

Attachment NOC-AE-1 1002696 Page 10 of 18 STPNOC 60-Day Response to Bulletin 2011-01 SFP Damage Control Kit Inventory Equipment Inventory Special Items Verified (e.g. proper Frequency Storage quantities, locations, Controls pressures, calibrations, shelf life, equipment is accessible.)

Damage Control Kits Quarterly Locked in Item quantity verified and (1 in each Unit) equipment accessible cages

Attachment NOC-AE-1 1002696 Page 11 of 18 STPNOC 60-Day Response to Bulletin 2011-01 NRC Request 4 Describein detail how configurationandguidance management is assuredso that strategiesremain feasible.

Examples of the types of information to include when providing your response to Question (4) are:

a. Measures taken to evaluate any plant configuration changes for theireffect on feasibility of the mitigatingstrategies.

b. Measures taken to validate that the proceduresor guidelines developed to support the strategiescan be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.

c. Measures taken to ensure procedures remain up-to-date and consistent with the current configurationof the plant.

d. A description of the trainingprogram implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.

These examples are not meant to limit your response if you use other methods to addressthe issues described above.

STPNOC Response (4)

Plant configuration changes are procedurally evaluated against the licensing basis, including the license conditions and their associated safety evaluation.

Initially, mitigating strategies were validated by walkdowns and engineering evaluations.

Subsequent procedure changes are validated to ensure that the guideline remains viable. In 2011, B.5.b mitigating strategies were revalidated by walkdowns. The training discussed below also validates that the associated mitigating strategies can be deployed.

The design change process requires a review for potential impacts on B.5.b mitigating strategies, including affects on procedures and any other necessary changes. The design change procedure directs the user to seek clarification from knowledgeable individuals familiar with B.5.b commitments and complete a special review form since the information may be sensitive and not readily available.

The mitigating strategy guidelines are controlled consistent with procedural controls under established administrative processes. All strategies developed at STP are contained within an approved procedure or guideline. Per the Westinghouse Owners Group - Emergency Response Guidelines, as well as specific procedure processes, new strategies or changes to existing strategies contained within procedures are required to be validated. Subsequently, when new procedures or strategies contained within existing procedures are developed that

Attachment NOC-AE-1 1002696 Page 12 of 18 STPNOC 60-Day Response to Bulletin 2011-01 may contain Operator Time Critical Actions the procedures are validated on the actual plant, if possible. However, if it is not possible to actually perform a validation of a procedure due to regulatory or plant condition without an increase in risk, then a simulation, walk down, or mock up is performed using the procedure, prior to procedure approval.

In addition, training is provided to operating crews, during which, any further deficiencies may be noted and corrected.

The following table describes the training program implemented in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Station Personnel Training Periodicity Evaluation Operations' Initial training and Licensed Written exams, continuing training as Operator Qualification process, described below continuing plant walkthroughs training - 2 and simulator years exercises Non-licensed - 4 years Fire Brigade Large accelerant fed fires - Live fire Written exams, drills classroom fundamentals training -

and techniques, live fire annual training practice and Classroom evaluation training -

biennial Emergency Initial and continuing 3 years Computer based Response Severe Accident training with read &

Organization (ERO) Management Guidelines sign Key Decision (SAMGs) training (SMG- acknowledgement Makers & 002/202) implementers' 2 Emergency Initial and continuing 3 years Computer based Response SAMGs training (SMG- training with read &

Organization 002/202) sign Evaluators 2 acknowledgement Emergency Initial and continuing 3 years Computer based Response training OPOP10 training with read &

Organization 2 Emergency Accident sign Mitigation Training (EPT- acknowledgement 512)

Attachment NOC-AE-1 1002696 Page 13 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Station Personnel Training Periodicity Evaluation Emergency Security/Emergency 6 Years Currently required to Response Response Integrated be performed every 6 Organization exercises years. A pilot drill was conducted May 19, 2009; however the exercise was observed but not evaluated by the NRC. Future exercises will be evaluated.

Engineering One time computer based One-time Written exam training for engineering personnel task qualified to perform design changes.

This training, in part, ensured students were knowledgeable of the procedural requirements that require additional review for design changes that may impact the station's ability to respond to B.5.b-related events by affecting mitigation strategies (ESP410018)

Engineering Initial Qualification for Initial Evaluated against engineering personnel (prior to standards for responsible for design completing a Qualification as part changes design of the mentoring change process based on package) satisfactory completion of a design change package using the current revision of the design change checklist.

Attachment NOC-AE-1 1002696 Page 14 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Station Personnel Training Periodicity Evaluation Security Initial and continuing Annual Security personnel training on Security receive classroom Instruction SI 2700, training related to Security Response to actions the security Airborne Threats force would take in the event of an airborne threat. The procedure is read and discussed.

General Site General Employee Training Annual Site specific training Population on response to an airborne material on individual threat response to aircraft threat is included in a computer based training module; however, there are currently no test questions on the material.

Notes:

1 Operations Plant Operators receive initial training related to local actions required in the event of extensive damage mitigation and other procedures in the POP10 series (B.5.b & Beyond Design Basis Mitigation Strategies). This is performed through walkthrough with qualified operators, and required prior to initial watch standing. Continuing training for Plant Operators is embedded in the Plant Operator Requalification (POR) Four-year Plan. This training includes plant walkthroughs and classroom discussion of the POP10 series. This continuing training is a required component of POR. All Plant Operators in watch standing positions are qualified to implement local actions of the POP1 0 procedure series.

Licensed Operators receive initial training related to all Emergency Operating Procedures (EOPs), all Off-normal Operating Procedures, Severe Accident Management Guidelines, Extensive Damage Mitigation Guidelines, and other procedures in the POP10 series. This training consists of a combination of classroom discussion and simulator practice. Continuing training for licensed operators is embedded in the Licensed Operator Requalification (LOR)

Two-year Plan and Emergency Planning continuing training. The LOR Two-year Plan contains tasks and objectives for continual training of security-related Off-normal procedures, EOPs related to station blackout, and the entire POP10 series. Emergency Planning ensures continuing training of Severe Accident Management Guideline training. Procedure OPGP03-ZT-0132, Licensed Operator Requalification, requires removal from watch standing duties if required training is not completed in a timely manner. All active licensed operators in Control

Attachment NOC-AE-1 1002696 Page 15 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Room watch standing positions are qualified to implement Emergency Operating Procedures, Off-normal Procedures, Severe Accident Management Guidelines, Extensive Damage Mitigation Guidelines, and other procedures in the POP10 series.

2 Selected ERO candidates only

Attachment NOC-AE-1 1002696 Page 16 of 18 STPNOC 60-Day Response to Bulletin 2011-01 NRC Request 5 Describein detail how you assureavailabilityof off-site support.

Examples of the types of information to include when providing your response to Question (5) are:

a. A listing of off-site organizationsyou rely on for emergency response.

b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractualarrangements. This should include a listing of periods of lapsed contractualarrangements.

c. A listing of any trainingor site familiarizationprovided to off-site responders. This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnoverand the passageof time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

STPNOC Response (5)

The agreements and procedures identified in the table below were re-confirmed in 2011 and are reviewed annually and renewed as necessary.

Currently there are no lapsed agreements with offsite support organizations.

STPNOC has not identified issues involving lapsed Letters of Agreement related to the B.5.b.

program requirements from 2008 to present.

Training requirements for offsite support organizations are described in site procedures.

Off-site Implementing Validation and Training/Familiarization Organization Document Periodicity Refresher /Periodicity Bay City Volunteer Letter of 12/20/2010 Offered Annually Fire Department Agreement Reviewed In conjunction with (BCVFD) Annually annual site familiarization training the BCVFD is invited to participate in a combination drill with the STP site fire brigade.

Bay City Police Letter of 1/12/2011 Offered Annually Department Agreement Reviewed Annually

Attachment NOC-AE-1 1002696 Page 17 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Off-site Implementing Validation and Training/Familiarization Organization Document Periodicity Refresher /Periodicity Matagorda County Letter of 11/15/2010 Offered Annually Agreement Reviewed Annually Matagorda County Matagorda 11/21/2008 Not Applicable Officials County All Reviewed every Bay City Volunteer Hazards Annexes 5 years Fire Department Annex F Bay City Mayor Firefighting Matagorda County Appendix 2 Sherriff STP Coordinated Firefighting Strategy Matagorda County Letter of 12/02/2010 Offered Annually EMS Agreement Reviewed Annually Matagorda County Letter of 11/17/2010 Offered Annually Hospital District Agreement Reviewed Annually Matagorda County Letter of 11/15/2010 Offered Annually Sheriffs Office Agreement Reviewed Annually Palacios Police Letter of 11/15/2010 Offered Annually Department Agreement Reviewed Annually Palacios Volunteer Letter of 4/25/2011 Offered Annually Fire Department Agreement Reviewed In conjunction with (PVFD) Annually annual site familiarization training the PVFD is invited to participate in a combination drill with the STP site fire brigade.

United States Coast Letter of 3/28/2011 Not Applicable Guard, Corpus Agreement Reviewed Christi Annually

Attachment NOC-AE-1 1002696 Page 18 of 18 STPNOC 60-Day Response to Bulletin 2011-01 Off-site Implementing Validation and Training/Familiarization Organization Document Periodicity Refresher /Periodicity Boots & Coots Large Fire 04/12/11 Not Applicable International Well support identified Phone numbers Control in site emergency in the Wild Well Control response Emergency implementing Communications ChemGuard procedure Directory (Large Fire Support) OERP01 -ZV- verified EF07 (Support Quarterly Organization Director Checklist) and contact numbers are maintained in Emergency Communications Directory