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#REDIRECT [[WO 12-0044, Operating Corporation - 60-Day Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima.]]
| number = ML12138A012
| issue date = 05/09/2012
| title = Wolf Creek Nuclear Operating Corporation - 60-Day Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fuku
| author name = Hedges S E
| author affiliation = Wolf Creek Nuclear Operating Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000482
| license number =
| contact person =
| case reference number = WO 12-0044
| document type = Letter
| page count = 13
| project =
| stage = RAI
}}
 
=Text=
{{#Wiki_filter:W$LF CREEK NUCLEAR OPERATING CORPORATION Stephen E. Hedges May 9, 2012 Site Vice President WO 12-0044 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555
 
==Reference:==
 
Letter dated March 12, 2012 from E. J. Leeds and M. R. Johnson, USNRC, to M. W. Sunseri, WCNOC, "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-lchi Accident"
 
==Subject:==
Docket No. 50-482: Wolf Creek Nuclear Operating Corporation's 60-day Response to Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident Gentlemen:
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-lchi Accident." Enclosure 5 of the letter contains specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness 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, Wolf Creek Nuclear Operating Corporation proposes to take the alternative course of action described in Attachment I of this letter. The basis for the proposal is explained in Attachment I1.P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET WO 12-0044 Page 2 of 3 Regulatory commitments made by Wolf Creek Nuclear Operating Corporation in this response are identified in Attachment III to this letter. If you have any questions concerning this matter, please contact me at (620) 364-4190 or Mr. Gautam Sen at (620) 364-4175.Sincerely, E. Hedges SEH/rlt Attachments:
I. Proposed Alternative Course of Action for Responding to Recommendation 9.3 Information Request I1. Basis for Proposed Alternative Course of Action for Responding to Emergency Plan (EP) Requested Information I1l. List of Regulatory Commitments cc: E. E. Collins (NRC), w/a J. R. Hall (NRC), w/a E. J. Leeds (NRC), w/a N. F. O'Keefe (NRC), w/a Senior Resident Inspector (NRC), w/a WO 12-0044 Page 3 of 3 STATE OF KANSAS COUNTY OF COFFEY))Stephen E. Hedges, of lawful age, being first duly sworn upon oath says that he is Site Vice President of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.By_ S--Stephen .e es Site ViceeP re;2'edent SUBSCRIBED and sworn to before me this day of ,2012.IRHONDA L. TIEMEER SO.IiA..L MY COMMISSION EXPIRES Notary Public 42 Expiration Date W/D/,W 11J/, +00 O'IJ Attachment I to WO 12-0044 Page 1 of 4 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].
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 6/11/12 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 Below Provide an implementation schedule of the time needed to 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.
Attachment I to WO 12-0044 Page 2 of 4 Staffing Estimated Request # Completion Requested Information Date 1 See Below Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described
[in the Discussion section].
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).
The Requested Information is applicable only to multi-unit sites and, therefore, is not applicable to Wolf Creek Nuclear Operating Corporation (WCNOC)Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
9/5/2014*Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
* This date corresponds to 4 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.
Attachment I to WO 12-0044 Page 3 of 4 2 See Below 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.i 1. Conduct the onsite and augmented staffing assessment:
+The Requested Information is applicable only to multi-unit sites and, therefore, is not applicable to WCNOC The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
8/5/2014*
The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
* This date corresponds to 5 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.2. A schedule of the time to needed to implement changes will be provided as follows: The Those associated with the Phase 1 staffing assessment.
Requested Information is applicable only to multi-unit sites and, therefore, is not applicable to WCNOC 9/5/2014*Those associated with the Phase 2 staffing assessment.
* This date corresponds to 4 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.3 6/11/12 Identify how the augmented staff would be notified given degraded communications capabilities.
4 6/11112 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.
Attachment I to WO 12-0044 Page 4 of 4 5 6/11/12 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
6 See Below 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: The Requested Information is applicable only to multi-unit sites and, therefore, is not applicable to WCNOC Those associated with the Phase 1 staffing assessment.
9/5/2014*Those associated with the Phase 2 staffing assessment.
* This date corresponds to 4 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.
Attachment II to WO 12-0044 Page 1 of 3 Basis for Proposed Alternative Course of Action for Responding to Emergency Plan (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. 72560). The proposed alternative timing is warranted as many of the Wolf Creek Nuclear Operating Corporation (WCNOC) 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., 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 I 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 I Staffing Assessment Phase 2 Staffing Assessment (for functions except those related Plant Type to Fukushima Near-Term Task (for functions related to NTTF Force (NTTF) Recommendation Recommendation 4.2)4.2)Single-unit plants Perform staffing assessment and Perform staffing assessment as implement actions as required by requested by 50.54(f) letter using recent EP Rule using Interim Staff NEI 12-01; provide results per Guidance (ISG) and NEI 10-05 Attachment I of this letter Multi-unit plants o 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 I of this letter e Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01 and material from NEI 10-05; provide results per Attachment I of this letter The basis for this approach is discussed below.* For multi-unit plants, the Phase 1 staffing assessment will be performed by March 29, 2013, and provided by April 30, 2013. This assessment will consider all requested Attachment II to WO 12-0044 Page 2 of 3 functions except those related to NTTF Recommendation 4.2. An assessment considering these functions will be performed in Phase 2.The timing of the Phase 1 staffing assessment 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. 72560). 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 50.54(f) letter (Reference
: 1) 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.
Single-unit plants do not need to provide a Phase 1 staffing assessment in response to the NRC 50.54(f) letter (Reference
: 1) 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 8/5/2014, and provided by 9/5/2014.
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 (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 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.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 ISG scheduled to be issued by the NRC in August 2012.In response to the Order, WCNOC must develop new strategies for mitigating beyond-design-basis external events. To ensure accurate results, the staffing assessment for Attachment II to WO 12-0044 Page 3 of 3 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.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 by 4 months prior to beginning of the second refueling outage (as used within the context of the Order).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. WCNOC, 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." and "Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies." Reference 1. Letter dated March 12, 2012 from E. J. Leeds and M. R. Johnson, USNRC, to M. W.Sunseri, WCNOC, "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-lchi Accident" Attachment III to WO 12-0044 Page 1 of 3 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Wolf Creek Nuclear Operating Corporation in this document.
Any other statements in this letter are provided for information purposes and are not considered regulatory commitments.
Please direct questions regarding these commitments to Mr. Gautam Sen, Manager Regulatory Affairs at Wolf Creek Generating Station, (620) 364-4175.REGULATORY COMMITMENT DUE DATE Provide an assessment of the current communications systems October 31, 2012 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].
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[Communications Request # 1]Describe any interim actions that have been taken or are June 11,2012 planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.[Communications Request # 2]Conduct the communications assessment.
September 28, 2012[Communications Request # 3]Provide an implementation schedule of the time needed to October 31, 2012 implement the results of the communications assessment.
[Communications Request # 3]
Attachment III to WO 12-0044 Page 2 of 3 REGULATORY COMMITMENT DUE DATE Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described
[in the Discussion section].
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).
Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
[Staffing Request # 1]September 5, 2014** This date corresponds to 4 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.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:
The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
[Staffing Request # 2]August 5, 2014** This date corresponds to 5 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.
Attachment III to WO 12-0044 Page 3 of 3 REGULATORY COMMITMENT DUE DATE 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.2. A schedule of the time to needed to implement changes will be provided as follows: Those associated with the Phase 2 staffing assessment.
[Staffing Request # 2]September 5, 2014** This date corresponds to 4 months prior to beginning of the second refueling outage, as used within the context of NRC Order EA-12-049, which is currently scheduled to begin in January, 2015.Identify how the augmented staff would be notified given June 11, 2012 degraded communications capabilities.
[Staffing Request # 3]Identify the methods of access (e.g., roadways, navigable June 11, 2012 bodies of water and dockage, airlift, etc.) to the site that are expected to be available after a widespread large scale natural event.[Staffing Request # 4]Identify any interim actions that have been taken or are planned June 11, 2012 prior to the completion of the staffing assessment.
[Staffing Request # 5]Identify changes that have been made or will be made to your September 5, 2014*emergency plan regarding the on-shift or augmented staffing
* This date changes necessary to respond to a loss of all AC power, multi- corresponds to 4 unit event, including any new or revised agreements with offsite months prior to resource providers (e.g., staffing, equipment, transportation, beginning of the etc.). second refueling Changes will be identified as follows: outage, as used Those associated with the Phase 2 staffing assessment.
within the context of NRC Order EA-12-[Staffing Request # 6] 049, which is currently scheduled to begin in January, 2015.}}

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