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| | author affiliation = NRC/NRR/JLD/PMB | | | author affiliation = NRC/NRR/JLD/PMB |
| | addressee name = Hanson B C | | | addressee name = Hanson B |
| | addressee affiliation = Exelon Generation Co, LLC | | | addressee affiliation = Exelon Generation Co, LLC |
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| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Rd Warrenville, IL 60555 April 12, 2016 | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 12, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Rd Warrenville, IL 60555 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| NINE MILE POINT NUCLEAR STATION, UNIT 2 -RESPONSE REGARDING PHASE 2 STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION | | NINE MILE POINT NUCLEAR STATION, UNIT 2 - RESPONSE REGARDING PHASE 2 STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 9.3 RELATED TO THE FUKUSHIMA DAl-ICHI NUCLEAR POWER PLANT ACCIDENT (CAC NO. MF7155) |
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| ===9.3 RELATED=== | | ==Dear Mr. Hanson:== |
| TO THE FUKUSHIMA DAl-ICHI NUCLEAR POWER PLANT ACCIDENT (CAC NO. MF7155)
| | |
| | By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340),*the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter), regarding Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident. With respect to Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of construction permits to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to determine the staff required to fill all necessary positions in response to a multi-unit event. |
| | The 50.54(f) letter, in part, requested licensee responses pursuant to the provisions of 10 CFR 50.54(f) pertaining to onsite and augmented staff availability to implement the strategies discussed in the emergency plan and plant operating procedures, including new staff or functions resulting from the assessment, identified collateral duties, an implementation schedule to perform the assessments, identified modifications, and any changes that have been made or will be made to the emergency plan regarding on-shift or augmented staffing. |
| | In addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current (ac) power (ELAP) event utilizing existing processes and procedures. The licensee responses to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and evaluated by the NRC staff. The NRC staff issued acknowledgement letters to all licensees with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 2014. |
| | |
| | B. Hanson Licensees were also requested to submit a Phase 2 staffing assessment for NRC staff review, which provides an assessment of the staffing necessary to perform the functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting NRC Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Accession No. ML12054A736). |
| | Licensees were requested to provide their Phase 2 staffing assessments to the NRC no later than four months prior to the beginning of their second refueling outage (as used in the context of NRC Order EA-12-049). By letter dated December 4, 2015 (ADAMS Accession No. ML15338A123), Exelon Generation Company, LLC (the licensee) submitted its Phase 2 staffing assessment for Nine Mile Point Nuclear Station, Unit 2 to the NRC in response to the 50.54(f) letter. |
| | The NRC staff reviewed the licensee's Phase 2 staffing assessment in accordance with the assumptions and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" (ADAMS Accession No. ML12125A412), |
| | which was endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No. ML12131A043). The NRC staff noted that the licensee assessed its current onsite minimum staffing levels to identify any enhancements needed to respond following a beyond-design-basis large-scale natural event, and to ensure that the strategies contained in the existing emergency plan and plant operating procedures, such as those used in response to a SBO, can be performed by the site staff. The licensee's assessment assumed that a large-scale natural event causes: (1) an ELAP, (2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of six hours. The licensee also assessed its capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049. |
| | The licensee conducted independent reviews and concluded, based on its staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power, multi-unit event response strategies, including those strategies developed to support the r~quirements of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties. |
| | The NRC staff reviewed the licensee's Phase 2 staffing submittal and confirmed that the licensee's existing emergency response resources, as described in its emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the multi-unit event response strategies that were developed in response to Order EA-12-049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions. |
| | As a result, the NRC staff concludes that the licensee's Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using its procedures and guidelines. The NRC staff will verify the implementation of the licensee's staffing capabilities through the inspection program. |
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| ==Dear Mr. Hanson:==
| | B. Hanson If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov. |
| By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12053A340),*the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter), regarding Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident.
| | Tony Brow , Acting Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-410 cc: Distribution via Listserv |
| With respect to Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of construction permits to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to determine the staff required to fill all necessary positions in response to a multi-unit event. The 50.54(f) letter, in part, requested licensee responses pursuant to the provisions of 1 O CFR 50.54(f) pertaining to onsite and augmented staff availability to implement the strategies discussed in the emergency plan and plant operating procedures, including new staff or functions resulting from the assessment, identified collateral duties, an implementation schedule to perform the assessments, identified modifications, and any changes that have been made or will be made to the emergency plan regarding on-shift or augmented staffing.
| | : ML16083A073 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSI R/DPR/N RLB/BC* NRR/JLD/JOMB/BC(A) |
| In addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF Recommendation 4.2 (mitigating strategies).
| | NAME SPhiloott Slent ARivera (CMurrav for) TBrown DATE 03/23/2016 03/23/2016 04/11/2016 04/12/2016}} |
| As a result of this dependency, licensees responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current (ac) power (ELAP) event utilizing existing processes and procedures.
| |
| The licensee responses to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and evaluated by the NRC staff. The NRC staff issued acknowledgement letters to all licensees with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 2014.
| |
| B. Hanson Licensees were also requested to submit a Phase 2 staffing assessment for NRC staff review, which provides an assessment of the staffing necessary to perform the functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting NRC Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Accession No. ML 12054A736).
| |
| Licensees were requested to provide their Phase 2 staffing assessments to the NRC no later than four months prior to the beginning of their second refueling outage (as used in the context of NRC Order EA-12-049).
| |
| By letter dated December 4, 2015 (ADAMS Accession No. ML 15338A123), Exelon Generation Company, LLC (the licensee) submitted its Phase 2 staffing assessment for Nine Mile Point Nuclear Station, Unit 2 to the NRC in response to the 50.54(f) letter. The NRC staff reviewed the licensee's Phase 2 staffing assessment in accordance with the assumptions and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" (ADAMS Accession No. ML 12125A412), which was endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No. ML 12131A043).
| |
| The NRC staff noted that the licensee assessed its current onsite minimum staffing levels to identify any enhancements needed to respond following a beyond-design-basis large-scale natural event, and to ensure that the strategies contained in the existing emergency plan and plant operating procedures, such as those used in response to a SBO, can be performed by the site staff. The licensee's assessment assumed that a large-scale natural event causes: (1) an ELAP, (2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of six hours. The licensee also assessed its capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049.
| |
| The licensee conducted independent reviews and concluded, based on its staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power, unit event response strategies, including those strategies developed to support the of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties. The NRC staff reviewed the licensee's Phase 2 staffing submittal and confirmed that the licensee's existing emergency response resources, as described in its emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the multi-unit event response strategies that were developed in response to Order EA-12-049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions.
| |
| As a result, the NRC staff concludes that the licensee's Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using its procedures and guidelines.
| |
| The NRC staff will verify the implementation of the licensee's staffing capabilities through the inspection program.
| |
| B. Hanson If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov. | |
| Docket No. 50-410 cc: Distribution via Listserv Tony Brow , Acting Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation B. Hanson If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov.
| |
| Docket No. 50-410 cc: Distribution via Listserv DISTRIBUTION: | |
| PUBLIC JOMB R/F RidsNrrDorllpl1-1 JPaige, NRR RidsOgcMailCenter RidsNrrLASLent VWilliams, NSIR TTate, NRR ADAMS Accession No:: ML 16083A073 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NAME SPhiloott Slent DATE 03/23/2016 03/23/2016 Sincerely, IRA/ Tony Brown, Acting Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation RidsNrrPMNineMilePoint CMurray, NSIR RidsRgn1 MailCenter ARivera, NSIR TBrown, NRR SPhilpott, NRR *via email NSI R/DPR/N RLB/BC* NRR/JLD/JOMB/BC(A)
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| ARivera (CMurrav for) TBrown 04/11/2016 04/12/2016 OFFICIAL RECORD COPY}} | |
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MONTHYEARML16083A0732016-04-12012 April 2016 Response Regarding Phase 2 Staffing Submittal Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-ichi Nuclear Power Plant Accident Project stage: Other 2016-04-12
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Category:Letter
MONTHYEARNMP1L3570, Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-02-0101 February 2024 Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation IR 05000220/20230042024-02-0101 February 2024 Integrated Inspection Report 05000220/2023004 and 05000410/2023004 NMP1L3569, CFR 50.46 Annual Report2024-01-26026 January 2024 CFR 50.46 Annual Report ML24004A2122024-01-0808 January 2024 Senior Reactor and Reactor Operator Initial License Examinations ML23354A0012024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0059 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines NMP1L3566, Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station2023-12-14014 December 2023 Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station IR 05000410/20243012023-12-14014 December 2023 Initial Operator Licensing Examination Report 05000410/2024301 ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 NMP1L3564, Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements ML23291A4642023-12-0707 December 2023 Issuance of Amendment No. 251 Regarding the Adoption of Title 10 the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of SSC for Nuclear Power Plants ML23289A0122023-12-0606 December 2023 Issuance of Amendment No. 250 Regarding the Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b NMP1L3563, Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-12-0404 December 2023 Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) IR 05000220/20234022023-11-28028 November 2023 Security Baseline Inspection Report 05000220/2023402 and 05000410/2023402 NMP1L3557, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000220/20234202023-11-0101 November 2023 Security Baseline Inspection Report 05000220/2023420 and 05000410/2023420 ML23305A0052023-11-0101 November 2023 Operator Licensing Examination Approval IR 05000220/20230032023-10-25025 October 2023 Integrated Inspection Report 05000220/2023003 and 05000410/2023003 IR 05000220/20235012023-10-17017 October 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000220/2023501 and 05000410/2023501 IR 05000220/20230112023-10-16016 October 2023 Comprehensive Engineering Team Inspection Report 05000220/2023011 and 05000410/2023011 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans NMP1L3554, Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases2023-10-0606 October 2023 Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases C IR 05000220/20233032023-09-20020 September 2023 Retake Operator Licensing Examination Report 05000220/2023303 ML23250A0822023-09-19019 September 2023 Regulatory Audit Summary Regarding LARs to Adopt TSTF-505, Rev. 2, and 10 CFR 50.69 ML23257A1732023-09-14014 September 2023 Requalification Program Inspection IR 05000220/20230052023-08-31031 August 2023 Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2023005 and 05000410/2023005) RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs NMP2L2851, Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations2023-08-25025 August 2023 Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations ML23151A3472023-08-21021 August 2023 Issuance of Amendments to Adopt TSTF-295-A, Modify Note 2 to Actions of PAM Table to Allow Separate Condition Entry for Each Penetration NMP1L3534, License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2023-08-18018 August 2023 License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation ML23220A0262023-08-0808 August 2023 Licensed Operator Positive Fitness-for-Duty Test IR 05000220/20234012023-08-0808 August 2023 Cyber Security Inspection Report 05000220/2023401 and 05000410/2023401 (Cover Letter Only) NMP1L3545, Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems .2023-08-0404 August 2023 Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems . RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor IR 05000220/20230022023-08-0101 August 2023 Integrated Inspection Report 05000220/2023002 and 05000410/2023002 ML23207A0762023-07-14014 July 2023 EN 56557 - Update to Part 21 Report Re Potential Defect with Trane External Auto/Stop Emergency Stop Relay Card Pn: XI2650728-06 NMP1L3544, Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations2023-07-14014 July 2023 Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations ML23186A1642023-07-0606 July 2023 Operator Licensing Retake Examination Approval NMP2L2846, Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications2023-07-0505 July 2023 Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications ML23192A0622023-06-30030 June 2023 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance, Report No. 10CFR21-0136, Rev. 0 IR 05000220/20230102023-06-29029 June 2023 Biennial Problem Identification and Resolution Inspection Report 05000220/2023010 and 05000410/2023010 ML23131A4242023-06-23023 June 2023 Issuance of Amendment No. 249 Regarding the Revision to Technical Specification 3.3.1 to Adopt Technical Specifications Task Force Traveler TSTF-568 RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations NMP1L3539, Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-06-0909 June 2023 Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) ML23159A0052023-06-0505 June 2023 56557-EN 56557 - Paragon - Redlined RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling IR 05000410/20233022023-05-15015 May 2023 Initial Operator Licensing Examination Report 05000410/2023302 2024-02-01
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 12, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Rd Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT 2 - RESPONSE REGARDING PHASE 2 STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 9.3 RELATED TO THE FUKUSHIMA DAl-ICHI NUCLEAR POWER PLANT ACCIDENT (CAC NO. MF7155)
Dear Mr. Hanson:
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340),*the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter), regarding Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident. With respect to Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of construction permits to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to determine the staff required to fill all necessary positions in response to a multi-unit event.
The 50.54(f) letter, in part, requested licensee responses pursuant to the provisions of 10 CFR 50.54(f) pertaining to onsite and augmented staff availability to implement the strategies discussed in the emergency plan and plant operating procedures, including new staff or functions resulting from the assessment, identified collateral duties, an implementation schedule to perform the assessments, identified modifications, and any changes that have been made or will be made to the emergency plan regarding on-shift or augmented staffing.
In addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current (ac) power (ELAP) event utilizing existing processes and procedures. The licensee responses to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and evaluated by the NRC staff. The NRC staff issued acknowledgement letters to all licensees with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 2014.
B. Hanson Licensees were also requested to submit a Phase 2 staffing assessment for NRC staff review, which provides an assessment of the staffing necessary to perform the functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting NRC Order EA-12-049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Accession No. ML12054A736).
Licensees were requested to provide their Phase 2 staffing assessments to the NRC no later than four months prior to the beginning of their second refueling outage (as used in the context of NRC Order EA-12-049). By letter dated December 4, 2015 (ADAMS Accession No. ML15338A123), Exelon Generation Company, LLC (the licensee) submitted its Phase 2 staffing assessment for Nine Mile Point Nuclear Station, Unit 2 to the NRC in response to the 50.54(f) letter.
The NRC staff reviewed the licensee's Phase 2 staffing assessment in accordance with the assumptions and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" (ADAMS Accession No. ML12125A412),
which was endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No. ML12131A043). The NRC staff noted that the licensee assessed its current onsite minimum staffing levels to identify any enhancements needed to respond following a beyond-design-basis large-scale natural event, and to ensure that the strategies contained in the existing emergency plan and plant operating procedures, such as those used in response to a SBO, can be performed by the site staff. The licensee's assessment assumed that a large-scale natural event causes: (1) an ELAP, (2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of six hours. The licensee also assessed its capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049.
The licensee conducted independent reviews and concluded, based on its staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power, multi-unit event response strategies, including those strategies developed to support the r~quirements of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties.
The NRC staff reviewed the licensee's Phase 2 staffing submittal and confirmed that the licensee's existing emergency response resources, as described in its emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the multi-unit event response strategies that were developed in response to Order EA-12-049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions.
As a result, the NRC staff concludes that the licensee's Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using its procedures and guidelines. The NRC staff will verify the implementation of the licensee's staffing capabilities through the inspection program.
B. Hanson If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov.
Tony Brow , Acting Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-410 cc: Distribution via Listserv
- ML16083A073 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSI R/DPR/N RLB/BC* NRR/JLD/JOMB/BC(A)
NAME SPhiloott Slent ARivera (CMurrav for) TBrown DATE 03/23/2016 03/23/2016 04/11/2016 04/12/2016