PNP 2012-034, Entergy Nuclear Operations, Inc. 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments
| ML12135A289 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/11/2012 |
| From: | Vitale A Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2012-034 | |
| Download: ML12135A289 (13) | |
Text
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway
~Entergy Covert, MI 49043 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2012-034 May 11,2012 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Entergy Nuclear Operations, Inc. 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Reference:
NRC letter to Entergy, 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 (ADAMS Accession Number ML12056A046)
Dear Sir or Madam:
On March 12, 2012, the NRC issued a letter (Reference 1) 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. Enclosure 5 of the letter 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 requests within 90 days.
The letter states that if an addressee cannot meet the requested response date, then 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 careful review of the requested actions and information, Entergy Nuclear Operations, Inc. proposes to take the alternative course of action described in of this letter. The basis for the alternate proposal is provided in .
PNP 2012-034 Page 2 The new commitments contained in this submittal are summarized in Attachment 3.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May 11,2012.
Sincerely, 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 Emergency Preparedness Requested Information
- 3. List of Regulatory Commitments cc: Director of Office of Nuclear Regulation Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
Attachment 1 to PNP 2012-034 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request to PNP 2012-034 Page 1 of 3 Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request Communications Estimated Request Completion Requested Information Date 1 10/31/12 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 Discussion section of Enclosure 5 to the 10 CFR 50.54(f) letter. 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 alternating current (AC) power.
2 6/11/12 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 See dates Provide an implementation schedule of the time needed to below conduct and implement the results of the communications assessment.
9/28/12 Conduct the communications assessment.
10/31/12 Provide an implementation schedule of the time needed to implement the results of the communications assessment.
to PNP 2012-034 Page 2 of 3 Staffing A two-phase approach is proposed to respond to the information requests associated with Staffing. The table below summarizes this approach.
Estimated Request Completion Requested Information Date 1 See date Provide an assessment of the onsite and augmented staff below needed to respond to a large scale natural event meeting the conditions described in the Discussion section of Enclosure 5 to the 10 CFR 50.54(f} letter. 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 Near-Term Task Force (NTTF)
Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table 8-1 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).
12/19/14 Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2 (Phase 2 staffing assessment).
2 See dates Provide an implementation schedule of the time needed to below 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:
to PNP 2012-034 Page 3 of 3 Estimated Request Completion Requested Information Date 2 (con't) 11/19/14 The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2 (Phase 2 staffing assessment)
- 2. A schedule of the time needed to implement changes will be provided as follows:
12/19/14 Those associated with the Phase 2 staffing assessment 3 6/11/12 Identify how the augmented staff would be notified given degraded communications capabilities.
4 6/11/12 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 natu ral event.
S 6/11/12 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
6 See date Identify changes that have been made or will be made to below 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:
12/19/14 Those associated with the Phase 2 staffing assessment
Attachment 2 to PNP 2012-034 Basis for Proposed Alternative Course of Action for Responding to Emergency Preparedness Requested Information to PNP 2012-034 Page 1 of 3 Basis for Proposed Alternative Course of Action for Responding to Emergency Preparedness 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 Staff Requirements Memorandum (SRM)-SECY-12-002S, upon the completion of licensee actions necessary to comply with the Final Emergency Preparedness (EP) Rule issued on November 23, 2011 (76 Federal Register 72560). The proposed alternative timing is warranted because many of the licensee staff resources necessary for performing the communications assessment are the same resources involved in implementing new EP Rule requirements, responding to Institute of Nuclear Power Operations (INPO) initiatives related to enhancing communications capabilities (e.g., INPO Event Report 11-4), and maintaining existing EP communications equipment.
In addition, the estimated completion date assigned to information request #3 promotes 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 two-phase approach is proposed to respond to the information requests associated with Staffing. The table below summarizes this approach.
Phase 1 Staffing Assessment Phase 2 Staffing (for functions except those Assessment Plant Type related to Near-Term Task (for functions related to Force (NTTF) NTTF Recommendation 4.2)
Recommendation 4.2)
Single-unit plants Perform staffing assessment Perform staffing assessment and implement actions as as requested by the required by recent EP Rule 10 CFR SO.S4(f) letter using using Interim Staff Guidance NEI 12-01; provide results (ISG) and Nuclear Energy per Attachment 1 of this Institute (NEI) 10-05 letter The basis for this approach is discussed below.
to PNP 2012-034 Page 2 of 3
- Single-unit plants do not need to provide a Phase 1 staffing assessment in response to the 10 CFR 50.54(f) letter as performance of this activity is governed by the recent EP Rule and existing license requirements.
- The Phase 2 staffing assessment will be performed by November 19, 2014, and provided by December 19, 2014. This assessment will consider the requested functions related to Fukushima 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 (SECYs) and SRMs. 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 Modifying 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.
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 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 this Order are expected to be contained in the final 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 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.
to PNP 2012-034 Page 3 of 3 Based on a review of the planned actions necessary to comply with the Order, an assessment of the staffing for functions related to NTTF Recommendation 4.2 will be provided by December 19, 2014.
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 the overall work plan necessary to implement the requirements of the Order. Entergy, as stated in the Order, " ... shall complete full implementation no later than two 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 to PNP 2012-034 List of Regulatory Commitments
Attachment 3 to PNP 2012-034 Page 1 of 2 List of Regulatory Commitments The following table identifies those actions committed to by Entergy Nuclear Operations, Inc. in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
TYPE (Check One)
COMMITMENT SCHEDULED ONE- COMPLETION TIME CONTINUING DATE ACTION COMPLIANCE (If Required)
Provide an assessment of the current X* October 31, communications systems and 2012 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.
Describe any interim actions that have X* June 11, 2012 been taken 6r are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.
Conduct the communications X September 28, assessment. 2012 Provide an implementation schedule X* October 31, of the time needed to implement the 2012 results of the communications assessment.
Provide onsite and augmented staffing X* December 19, assessment considering functions 2014 related to NTIF Recommendation 4.2.
Conduct the onsite and augmented X November 19, staffing assessment considering 2014 functions related to NTIF Recommendation 4.2.
Provide a schedule of the time needed X* December 19, to implement changes associated with 2014 the Phase 2 staffing assessment.
to PNP 2012-034 Page 2 of 2 Identify how the augmented staff X* June 11,2012 would be notified given degraded communications capabilities.
Identify the methods of access (e.g., X* June 11,2012 roadways, navigable bodies of water and dockage, air/ift, etc.) to the site that are expected to be available after a widespread large scale natural event.
Identify any interim actions that have X* June 11, 2012 been taken or are planned prior to the completion of the staffing assessment.
Identify changes that have been made X* December 19, or will be made to the emergency plan 2014 regarding the on-shift or augmented staffing changes associated with the Phase 2 staffing assessment.
- NRC submittal