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| | number = ML16013A467 | | | number = ML16013A467 |
| | issue date = 02/07/2016 | | | issue date = 02/07/2016 |
| | title = Davis-Besse Nuclear Power Station, Unit 1- Response Regarding Phase 2 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident | | | title = Response Regarding Phase 2 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident |
| | author name = Bowman G T | | | author name = Bowman G |
| | author affiliation = NRC/NRR/JLD | | | author affiliation = NRC/NRR/JLD |
| | addressee name = Boles B D | | | addressee name = Boles B |
| | addressee affiliation = FirstEnergy Nuclear Operating Co | | | addressee affiliation = FirstEnergy Nuclear Operating Co |
| | docket = 05000346 | | | docket = 05000346 |
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| | page count = 4 | | | page count = 4 |
| | project = TAC:MF6786 | | | project = TAC:MF6786 |
| | | stage = Other |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Brian D. Boles Site Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760 February 7, 2016 SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 -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 (TAC NO. MF6786) Dear Mr. Boles: 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. 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. Licensees were not requested to submit Phase 1 staffing assessments for single-unit sites. Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, 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 Modifying Licenses with Regard to Requirements for Mitigation Strategies B. Boles -2 -for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Package 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 October 2, 2015 (ADAMS Accession No. ML 15275A292), FirstEnergy Nuclear Operating Company (the licensee) submitted its Phase 2 staffing assessment for Davis-Besse Nuclear Power Station, Unit 1 to the NRC in response to the 50.54(f) letter. The NRC staff reviewed your 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 you assessed your 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. Your 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. You also assessed your capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049. You conducted independent reviews and concluded, based on your staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power event response strategies, including those strategies developed to support the requirements of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties. The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the event response strategies that were developed in response to NRC 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 your Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using your procedures and guidelines. The NRC staff will verify the implementation of your staffing capabilities through the inspection program. | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7, 2016 Mr. Brian D. Boles Site Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760 |
| B. Boles -3 -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. 50-346 cc: Distribution via Listserv Sincerely, / Gregory T. Bowman, Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation B. Boles -3 -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. 50-346 cc: Distribution via Listserv DISTRIBUTION: PUBLIC JOMB R/F RidsNrrDorllpl3-2 JHughey, NRR RidsOgcMailCenter RidsNrrLASLent VWilliams, NSIR JPoole, NRR ADAMS Accession No.: ML16013A467 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NAME SPhilpott Slent DATE 1/26/2016 1/4/2016 Sincerely, IRA/ Gregory T. Bowman, Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation RidsNrrPMDavisBesse RidsRgn3MailCenter GBowman, NRR NSIR/DPR/NRLB/BC* A Rivera 1/26/2016 CMurray, NSIR ARivera, NSIR SPhilpott, NRR *via email NRR/JLD/JOMB/BC GBowrnan 2/7/2016 OFFICIAL RECORD COPY | | |
| }} | | ==SUBJECT:== |
| | DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - 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 (TAC NO. |
| | MF6786) |
| | |
| | ==Dear Mr. Boles:== |
| | |
| | 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. Licensees were not requested to submit Phase 1 staffing assessments for single-unit sites. |
| | Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, 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 Modifying Licenses with Regard to Requirements for Mitigation Strategies |
| | |
| | B. Boles for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Package 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 October 2, 2015 (ADAMS Accession No. ML15275A292), FirstEnergy Nuclear Operating Company (the licensee) submitted its Phase 2 staffing assessment for Davis-Besse Nuclear Power Station, Unit 1 to the NRC in response to the 50.54(f) letter. |
| | The NRC staff reviewed your 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 you assessed your 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. Your 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. You also assessed your capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049. You conducted independent reviews and concluded, based on your staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power event response strategies, including those strategies developed to support the requirements of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties. |
| | The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the event response strategies that were developed in response to NRC 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 your Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using your procedures and guidelines. |
| | The NRC staff will verify the implementation of your staffing capabilities through the inspection program. |
| | |
| | B. Boles If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov. |
| | Sincerely, |
| | / |
| | Gregory T. Bowman, Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-346 cc: Distribution via Listserv |
| | |
| | ML16013A467 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSIR/DPR/NRLB/BC* NRR/JLD/JOMB/BC NAME SPhilpott Slent A Rivera GBowrnan DATE 1/26/2016 1/4/2016 1/26/2016 2/7/2016}} |
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Category:Letter
MONTHYEARIR 05000346/20243012024-02-0202 February 2024 NRC Initial License Examination Report 05000346/2024301 IR 05000346/20230042024-01-31031 January 2024 Integrated Inspection Report 05000346/2023004 ML23313A1352024-01-17017 January 2024 Authorization and Safety Evaluation for Alternative Request RP 5 for the Fifth 10 Year Interval Inservice Testing Program ML23353A1192023-12-19019 December 2023 Operator Licensing Examination Approval Davis Besse Nuclear Power Station, January 2024 L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23338A3172023-12-0606 December 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001 IR 05000346/20234032023-11-0202 November 2023 Security Baseline Inspection Report 05000346/2023403 ML23293A0612023-11-0101 November 2023 Letter to the Honorable Marcy Kaptur, from Chair Hanson Responds to Letter Regarding Follow Up on Concerns Raised by Union Representatives During the June Visit to the Davis-Besse Nuclear Power Plant L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000346/20234012023-09-13013 September 2023 Security Baseline Inspection Report 05000346/2023401 (Public) L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual IR 05000346/20230112023-08-30030 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000346/2023011 ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000346/20230052023-08-24024 August 2023 Updated Inspection Plan for Davis-Besse Nuclear Power Station (Report 05000346/2023005) L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000346/20230502023-08-0303 August 2023 Special Inspection Report 05000346/2023050 IR 05000346/20230902023-08-0101 August 2023 EA-23-002 Davis-Besse Nuclear Power Station - NRC Inspection Report No. 05000346/2023090 (Public) ML23178A2742023-08-0101 August 2023 Letter to the Honorable Marcy Kaptur from Chair Hanson Responds to Letter Regarding the License Transfer Application for the Davis-Besse Nuclear Power Station L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program IR 05000346/20230022023-07-27027 July 2023 Integrated Inspection Report 05000346/2023002 ML23193A7842023-07-13013 July 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III ML23160A2342023-06-13013 June 2023 Confirmation of Initial License Examination L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models IR 05000346/20235012023-06-13013 June 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000346/2023501 L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) ML23131A2732023-05-15015 May 2023 Notification of NRC Supplemental Inspection 95001 and Request for Information L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection IR 05000346/20230102023-05-0909 May 2023 Commercial Grade Dedication Inspection Report 05000346/2023010 ML23123A1272023-05-0303 May 2023 Information Request to Support Upcoming Problem Identification and Resolution Inspection at Davis-Besse Nuclear Power Station IR 05000346/20230012023-05-0101 May 2023 Integrated Inspection Report 05000346/2023001 and 07200014/2022001 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 ML23111A1972023-04-26026 April 2023 Information Meeting with Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Davis-Besse Nuclear Power Plant Station ML23114A1062023-04-25025 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments CP-202300157, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-14014 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23096A1382023-04-11011 April 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage ML23066A2892023-03-14014 March 2023 Request for Threshold Determination Under 10 CFR 50.80 and 10 CFR 72.50 for an Amendment to the Voting Agreement ML23066A2592023-03-14014 March 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2, Davis Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 2024-02-02
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7, 2016 Mr. Brian D. Boles Site Vice President FirstEnergy Nuclear Operating Company c/o Davis-Besse NPS 5501 N. State Route 2 Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - 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 (TAC NO.
MF6786)
Dear Mr. Boles:
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. Licensees were not requested to submit Phase 1 staffing assessments for single-unit sites.
Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, 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 Modifying Licenses with Regard to Requirements for Mitigation Strategies
B. Boles for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Package 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 October 2, 2015 (ADAMS Accession No. ML15275A292), FirstEnergy Nuclear Operating Company (the licensee) submitted its Phase 2 staffing assessment for Davis-Besse Nuclear Power Station, Unit 1 to the NRC in response to the 50.54(f) letter.
The NRC staff reviewed your 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 you assessed your 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. Your 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. You also assessed your capability to perform the site-specific functions related to the strategies developed in response to Order EA-12-049. You conducted independent reviews and concluded, based on your staffing assessment, that the existing on-shift minimum staff is sufficient to implement the loss of all ac power event response strategies, including those strategies developed to support the requirements of Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties.
The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the event response strategies that were developed in response to NRC 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 your Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using your procedures and guidelines.
The NRC staff will verify the implementation of your staffing capabilities through the inspection program.
B. Boles If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov.
Sincerely,
/
Gregory T. Bowman, Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No. 50-346 cc: Distribution via Listserv
ML16013A467 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSIR/DPR/NRLB/BC* NRR/JLD/JOMB/BC NAME SPhilpott Slent A Rivera GBowrnan DATE 1/26/2016 1/4/2016 1/26/2016 2/7/2016