NOC-AE-12002867, Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML12163A344
Person / Time
Site:	South Texas
Issue date:	06/04/2012
From:	Rencurrel D South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-12002867
Download: ML12163A344 (11)

Text

Nuclear Operating Company South Teas Project Electric GeneratingStation PO. Box 289 Wadsworth. Texas 77483 A -

June 4, 2012 NOC-AE-12002867 10 CFR 50.54(f)

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 & 2 Docket Nos. STN 50-498, STN 50-499 Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f)

Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insiqhts from the Fukushima Dai-ichi Accident

References:

1. Letter, Eric Leeds to E. D. Halpin, "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," dated March 12, 2012 (ML12053A340)

2. Letter, D.W. Rencurrel to NRC, "60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated May 9, 2012 On May 9, 2012, STP Nuclear Operating Company (STPNOC) submitted our 60-day response to Reference 1 describing our alternative course of action (Reference 2). On May 31, 2012, we were notified by the Nuclear Regulatory Commission (NRC) staff that additional information was needed to make a determination regarding the adequacy of our proposed alternate course of action. Specifically, an estimated date for the first occurrence of our second refueling outage was needed. STPNOC provides our revised response described in Attachment 1 of this letter. The basis for our proposal is explained in Attachment 2. The appended information is shown by change bars in the right hand margin.

The only commitments in this letter are summarized in Attachment 3.

STI 33556993

NOC-AE-12002867 Page 2 of 3 If there are any questions regarding this letter, please contact Robyn Savage at (361) 972-7438 or me at (361) 972-7867.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 41/2012.-

D.W. Recrrela*

Chief Nuclear Officer Attachments: 1. Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request

2. Basis for Proposed Alternative Course of Action for Responding to EP Requested Information

3. List of Commitments rds

NOC-AE-12002867 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 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B13) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio Senior Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P. O. Box 289, Mail Code: MN116 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 Eric Leeds Richard A. Ratliff Director, Office of Nuclear Reactor Regulation Texas Department of State Health U.S. Nuclear Regulatory Commission Services One White Flint North (MS 13 H 16M) 11555 Rockville Pike Alice Rogers Rockville, MD 20852 Texas Department of State Health Services

Attachment 1 NOC-AE-12002867 Page 1 of 4 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Communications Request Estimated

1. Completion Requested Information Date 10/31/2012 Provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event meeting the conditions described in the NRC Request. The assessment should:

• Identify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies,

• Identify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies,

• Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and

• Provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all AC power 2 6/11/2012 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.

3 Two Dates Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.

09/28/12 Conduct the communications assessment.

10/31/2012 Provide an implementation schedule of the time needed to implement the results of the communications assessment.

Attachment 1 NOC-AE-12002867 Page 2 of 4 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Staffing Request Estimated

1. Completion Requested Information Date 1 Two Dates Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the NRC Request. This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:

• How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NTTF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654. Table B-1 such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

• New staff or functions identified as a result of the assessment.

• Collateral duties (personnel not being prevented from timely performance of their assigned functions).

4/30/2013 Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

4 months Provide onsite and augmented staffing assessment considering prior to the functions related to NTTF Recommendation 4.2. [Phase 2 staffing beginning of assessment]

2RE17 (Estimated date 614114)*

• As used within the context of NRC Order EA-12-049.

This date correspondsto 4 months prior to the beginning of the currently planned first occurrence of the second refueling outage (2RE17). The 2RE16 outage counts as the first refueling outage based on submitting the overall integrated plan on February28, 2013. 1RE19 outage will be the second refueling outage in the second Unit.

Attachment 1 NOC-AE-12002867 Page 3 of 4 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Request Estimated

1. Completion Requested Information Date 2 Four dates Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.

1. Conduct the onsite and augmented staffing assessment:

3/29/2013 The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

5 months prior The onsite and augmented staffing assessment considering to the functions related to NTTF Recommendation 4.2. [Phase 2 staffing beginning of assessment]

2RE17*

(Estimated date 514/14)*

2. A schedule of the time needed to implement changes will be provided as follows:

4/30/2013 Those associated with the Phase 1 staffing assessment.

4 months prior Those associated with the Phase 2 staffing assessment.

to the beginning of 2RE17*

(Estimated date 6/4/14)*

• As used within the context of NRC Order EA-12-049.

This date correspondsto 4 months prior to the beginning of the currentlyplanned first occurrence of the second refueling outage (2RE17). The 2RE16 outage counts as the first refueling outage based on submitting the overall integratedplan on February28, 2013. IRE19 outage will be the second refueling outage in the second Unit.

3 6/11/2012 Identify how the augmented staff would be notified given degraded communications capabilities.

Attachment 1 NOC-AE-12002867 Page 4 of 4 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Request Estimated

1. Completion Requested Information Date 4 6/11/2012 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.

5 6/11/2012 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.

6 Two Dates Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.).

Changes will be identified as follows:

4/30/2013 Those associated with the Phase 1 staffing assessment.

4 months Those associated with the Phase 2 staffing assessment.

priorto the beginning of 2RE17*

(Estimated

• As used within the context of NRC OrderEA-12-049.

date 614/14)* This date corresponds to 4 months prior to the beginning of the currently plannedfirst occurrence of the second refueling outage (2RE17). The 2RE16 outage counts as the first refueling outage based on submitting the overall integratedplan on February28, 2013. 1RE19 outage will be the second refueling outage in the second Unit.

Attachment 2 NOC-AE-12002867 Page 1 of 3 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information Communications There are two separate responses to the information requests related to communications. The alternative timing of responses to requests #1 and #3 proposed in this letter reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 2011 (76 Fed. Reg. 72,560). The proposed alternative timing is warranted as many of the licensee staff resources necessary for performing the communications assessment are the same resources involved in implementing the new EP Rule requirements, responding to Institute of Nuclear Power Operations (INPO) initiatives related to enhancing communications capabilities (e.g., IER 11-4), and maintaining existing EP communications equipment.

In addition, the estimated completion date assigned to information request #3 will promote alignment between the out-year budgeting/funding of future enhancements, and the development of an accurate and complete enhancement implementation schedule.

Staffing As presented in Attachment 1 of this letter, a 2-phase approach will be used to respond to the information requests associated with Staffing. The table below summarizes this approach.

Phase 1 Staffing Assessment Phase 2 Staffing Assessment Plant Type (for functions except those related (for functions related to NTTF to NTTF Recommendation 4.2) Recommendation 4.2)

Multi-unit plant 0 Perform staffing assessment Perform staffing assessment as and implement actions as requested by 50.54(f) letter using required by recent EP Rule NEI 12-01; provide results per using ISG and NEI 10-05 Attachment 1 of this letter

• Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01 and material from NEI 10-05; provide results per Attachment 1 of this letter The basis for this approach is discussed below.

The Phase 1 staffing assessment will be performed by March 29, 2013, and provided by April 30, 2013. This assessment will consider all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. An assessment considering these functions will be performed in Phase 2.

Attachment 2 NOC-AE-12002867 Page 2 of 3 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information The timing of the Phase 1 staffing assessment reflects the higher priority placed by the staff, and approved by the Commission is SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 2011 (76 Fed. Reg. 72,560). In particular,Section IV.A.9 of 10 CFR 50, Appendix E, requires that licensees complete a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. As stated in the EP Rule, this analysis must be completed by December 24, 2012.

Following completion of EP Rule staffing analysis, the staffing assessment associated with the NRC Letter will be performed. Based on staffing analysis experience to date, it is anticipated that a multi-unit staffing analysis will require approximately 3 months to complete and validate. One additional month is allotted for processing of an assessment submittal package.

As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 1 staffing assessment.

The Phase 2 staffing assessment will be performed approximately 5 months prior to the beginning of 2RE1 7 and provided 4 months prior to the beginning of 2RE1 7 (startof 2RE17 is scheduled for 10/4/14). This assessment will consider the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.

The Industry will be responding to multiple regulatory actions resulting from the recommendations contained in the Fukushima NTTF Report, as modified in related Commission Papers (SECY's) and Staff Requirements Memoranda (SRM). One of these actions, in particular, has the potential to impact emergency response staffing levels.

This action is associated with Fukushima NTTF Recommendation 4.2 and subsequently issued as NRC Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events EA-12-049 [the Order]. A summary of the Order is provided below.

The 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. 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.

Additional details on an acceptable approach for complying with the Order will be contained in final Interim Staff Guidance (ISG) scheduled to be issued by the NRC in August 2012.

In response to the Order, each licensee must develop new strategies for mitigating beyond-design-basis external events. To ensure accurate results, the staffing assessment for response

Attachment 2 NOC-AE-12002867 Page 3 of 3 Basis for Proposed Alternative Course of Action for Responding to EP Requested Information functions related to NTTF Recommendation 4.2 must be based on the actions delineated in procedures and guidelines developed in response to the Order. Once the site-specific actions associated with the new response strategies are defined (e.g., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.

Based on a review of the planned actions necessary to comply with the Order, an assessment of the staffing for the functions related to NTTF Recommendation 4.2 will be provided 4 months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage") as used within the context of NRC Order EA-12-049.

As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 2 staffing assessment.

The Phase 2 staffing assessment is one component of an overall licensee work plan necessary to implement the requirements of the Order. STP Nuclear Operating Company, as stated in the Order, "...shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31, 2016, whichever comes first." "Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies."

Attachment 3 NOC-AE-12002867 Page 1 of 1 List of Commitments The following table identifies those actions committed to by the STP Nuclear Operating Company (STPNOC) in this document. Any statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Robyn Savage at (361) 972-7438.

Commitment Scheduled Condition Due Date Report

1. STPNOC will perform an assessment of the current 10/31/12 12-11657-7 communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event. The assessment will be provided to the NRC.

2. STPNOC will provide an implementation schedule of the 10/31/12 12-11657-8 time needed to implement the results of the communications assessment.

3. STPNOC will perform an initial staffing assessment 4/30/13 12-11657-9 using NEI 12-01 and material from NEI 10-05. (Phase 1 Assessment). STPNOC will provide the NRC with the results of the Phase 1 assessment and an implementation schedule of the time needed to implement any changes.

4. STPNOC will perform a second staffing assessment as 4 months prior 12-11657-requested by the 50.54(f) letter using NEI 12-01 and to the 10 provide the results of the assessment to the NRC. beginning of (Phase 2 Assessment). STPNOC will provide the NRC 2RE17 with the results of the Phase 2 assessment and an (estimated date implementation schedule of the time needed to 6/4/14) implement any changes.

5. STPNOC will identify changes associated with the 4/30/13 12-11657-Phase 1 staffing assessment that have been made or 11 will be made to our emergency plan regarding the on-shift or augmented staffing changes including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.) and provide this to the NRC.

6. STPNOC will identify changes associated with the 4 months prior 12-11657-Phase 2 staffing assessment that have been made or to the 12 will be made to our emergency plan regarding the on- beginning of shift or augmented staffing changes including any new 2RE17 or revised agreements with offsite resource providers (estimateddate (e.g., staffing, equipment, transportation, etc.) and 6/4/14) provide this to the NRC.