PLA-7034, Response to Follow-Up Letter on Technical Issues for Resolution Regarding Licensees Communication Submittals

Response to Follow-Up Letter on Technical Issues for Resolution Regarding Licensees Communication Submittals

ML13179A449
Person / Time
Site:	Susquehanna
Issue date:	06/28/2013
From:	Rausch T Susquehanna
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML131820040	List: PLA-7034, Response to Follow-Up Letter on Technical Issues for Resolution Regarding Licensees Communication Submittals
References
PLA-7034, TAC ME7951
Download: ML13179A449 (5)

Text

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\ I I Timothy S. Rausch PPLSusquehann~LLC \ ' I I I Senior Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603

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Tel. 570.542.3345 Fax 570.542.1504 tsrausch @pplweb.com JUN 2 8 20t

' TM U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO FOLLOW-UP LETTER ON TECHNICAL ISSUES FOR RESOLUTION REGARDING LICENSEES COMMUNICATION SUBMITTALS Docket Nos. 50-387 PLA-7034 and 50-388

References:

1. NRC Letter, "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.

2. PLA-6852, "60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(!) 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," dated May 11, 2012.

3. PLA-6866, "Emergency Preparedness Information Requested by NRC Letter, "

dated June 11, 2012.

4. PLA -6927, "Requested Communications Assessment Results and Implementation Schedule per References 1 and 2," dated October 31, 2012.

5. NRC Letter, "Follow-Up Letter on Technical Issues for Resolution Regarding Licensee Communication Submittals associated with Near-Term Task Force Recommendation 9.3 (TAC NO. M£7951)," dated January 23, 2013.

6. PLA -6978, "Response to Follow-up Letter on Technical Issues for Resolution Regarding Licensees Communication Submittals, dated February 22, 2013." (ML13057A593)

7. PLA-6978, "Response to Follow-up Letter on Technical Issues for Resolution Regarding Licensees Communication Submittals, dated June 3, 2013." (ML13156A058)

The purpose of this letter is to supersede References 6 (PLA-6978, dated February 22, 2013, ML13057A593) and 7 (PLA-6978, dated June 3, 2013, ML13156A058) in their entirety. Per discussions with our NRC Project Manager, to Reference 6 was incorrectly marked as being withheld from public disclosure due to proprietary information. The Enclosure should have been marked to be withheld from public disclosure due to security information. Reference 7 was generated to correct the reason for withholding the information from public disclosure; however, an

Document Control Desk PLA-7034 incorrect version of Enclosure 1 was submitted. Except for the deletion of any reference to an affidavit and the correction to the request to withhold the information in Enclosure 1, the information in this letter is identical to that submitted in Reference 6. In addition, the following commitment has been completed since Reference 6 was issued:

"SSES will revise EP-RM-008, "Emergency Telephone Directory'~ to include satellite phone usage instructions."

On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued a 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," (Reference 1). Enclosure 5 of Reference 1 contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information request within 90 days from the date of letter.

Reference 1 also states that if an addressee cannot meet the requested response date, the addressee must provide a response within 60 days of the date of the letter and describe the alternative course of action that it proposes to take, including the basis of the acceptability of the proposed alternative course of action and estimated completion date.

After a carefqJ review of the requested actions and information, PPL Susquehanna, LLC (PPL) opted to take an alternative course of action as described in Enclosure 1 of Reference 2. The basis for PPL's alternative course of action was documented in of Reference 2. This alternative course of action was based on the industry standard guidance developed with the Nuclear Energy Institute (NEI).

Reference 4 provided PPL's Communications Assessment Results and Implementation Schedule for planned changes. Enclosure 1 to Reference 3 contains the results of the Communications Assessment in the format presented in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities." Enclosure 2 of Reference 4 contains a list of regulatory commitments regarding the changes PPL planned to make as a result of the Communications Assessment.

In Reference 5, the NRC identified eight (8) generic technical issues needing resolution to determine the licensee's communications capability regarding a multi-unit station blackout event. The NRC requested a response be provided within 30 days from the date of the letter.

The purpose of this letter and associated Enclosure 1 is to provide PPL' s response to Reference 5. PPL's response in Enclosure 1 is in a tabular format with three columns.

The table presents the NRC's Generic Technical Issues in the left hand column.

Document Control Desk PLA-7034 Information from PPL's Communications Assessment submittal (Reference 4) is presented in the center column. The right hand column provides additional information to fully respond to the NRC's Generic Technical Issues and augments PPL's original response (Reference 4).

PPL requests that Enclosure 1 to this letter be withheld from public disclosure. The information represents Security-Related information as defined by 10 CPR 2.390. to this letter contains a list of new regulatory commitments.

If you have any questions regarding the information contained in this letter, please contact Mr. John L. Tripoli, Manager, Nuclear Regulatory Affairs, at (570) 542-3100.

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

Executed on:

Senior Vice President & Chief Nuclear Officer

Enclosures:

1. PPL' s Response to the NRC's 8 Generic Technical Issues for RFI 9.3 Communications Assessment - Security-Related Information -

Withhold in Accordance with 10 CPR 2.390

2. List of Regulatory Commitments Copy: Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP Region I Administrator, NRC

Enclosure 2 to PLA -7034 List of Regulatory Commitments

Enclosure 2 to PLA-7034 List of Regulatory Commitments Item Description Due Date Tracking #

1 SSES will revise EP-RM-008, Complete 1671371 "Emergency Telephone Directory" to include satellite phone usage instructions.

2 NDAP-QA-0777, "PPL Susquehanna Complete 1499071 Emergency Preparedness Program" will be revised to include the "self-activation" expectation and guidance that SSES' NERO personnel have already been trained on.