ML121600122

Fort Calhoun Station, Unit 1 - Review of 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near Term Task Force Review of Fukushima Dai-ichi Accident (TAC No. ME8714)

ML121600122
Person / Time
Site:	Fort Calhoun
Issue date:	06/11/2012
From:	Wilkins L E Plant Licensing Branch IV
To:	Bannister D J Omaha Public Power District
Wilkins L E
References
TAC ME8714
Download: ML121600122 (8)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555*0001 June 11, 2012 Mr. David J. Bannister Vice President and CNO Omaha Public Power District Fort Calhoun Station 444 South 16th St. Mall Omaha, NE 68102-2247 FORT CALHOUN STATION, UNIT NO.1 -REVIEW OF 60-DAY RESPONSE TO REQUEST FOR INFORMATION REGARDING RECOMMENDATION 9.3 OF THE NEAR-TERM TASK FORCE RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NO. ME8714) Dear Mr. Bannister: By letter dated March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a Request for Information pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph SO.S4(f) which included the Near Term Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged Station Blackout (SBO) event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date. By letter dated May 9,2012, Omaha Public Power District, the licensee for Fort Calhoun Station, Unit 1, submitted its 60-day response proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. As discussed in the enclosed NRC staff evaluation, the licensee's alternative approach outlined in its 60-day response letter is consistent with the guidance of industry document Nuclear Energy Institute (NEI) 12-01, "Guidance for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,,,1 and the direction of the Commission. In addition, the NRC staff concludes that the licensee provided an adequate basis for its proposed alternative to responding to the SO.S4(f) Request for Information regarding communications and staffing for NTTF Recommendation 9.3. In its letter dated May 9,2012, the licensee identified its proposed alternative course of action, as provided in the attachment to the enclosure to this letter. The licensee did not make any regulatory commitments as defined by industry guidance NEt 99-04, "Guidelines for Managing NRC Commitments." NRC staff determined NEI 12-01 to be an acceptable approach in a letter dated May 1S, 2012 (ADAMS Accession No. ML 12131A043).

D. Bannister -2:' If you have any questions, please contact me at 301-415-1377 or via e-mail at Iynnea.wilkins@nrc.gov. J;vlf. Lynnea E. Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285 Enclosure: As stated cc w/encl: Distribution via Listserv NUCLEAR REGULATORY COMMISSION STAFF EVALUATION INFORMATION REQUEST MADE UNDER 10 CFR 50.54(f) REGARDING NEAR-TERM TASK FORCE RECOMMENDATION 9.3 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT 1 DOCKET NO. 50-285 By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 12073A348), the U.S. Nuclear Regulatory Commission (NRC or Commission) issued a Request for Information pursuant to Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.54(f) which included the Near-Term Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness (EP). Specifically, licensees were requested to assess their means to power communications equipment onsite and offsite during a prolonged Station Blackout (SBO) event and to perform a staffing study to determine the staff required to fill all necessary positions in response to a multi-unit event. If a licensee could not meet the requested 90-day response, then that licensee was required to provide a response within 60 days of the issuance of the letter describing an alternative course of action and estimated completion date. By letter dated May 3,2012 (ADAMS Accession No. ML 12125A410), the Nuclear Energy Institute (NEI) submitted NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012. The NRC staff reviewed NEI 12-01 and found it to be an acceptable method for licensees to use when responding to the NRC's 10 CFR 50.54(f) Request for Information regarding communications and staffing for EP. This staff evaluation is focused specifically on the licensee's response to the 10 CFR 50.54(f) letters and not on the associated Orders. By letter dated May 9,2012 (ADAMS Accession No. ML 12131A539), Omaha Public Power District, the licensee for Fort Calhoun Station, Unit 1, submitted its 60-day response to the 10 CFR 50.54(f) Request for Information proposing an alternative course of action based upon the higher priority to complete the implementation of the revised EP Rule. The NRC staff reviewed the licensee's proposed alternative against the guidance contained in NEI 12-01. In addition, the NRC staff also considered the direction given by the Commission in the Staff Requirements Memorandum (SRM) to SECY 12-0025, "Proposed Orders and Requests for Information in Response to Lessons Learned from Japan's March 11, 2011, Great Tohoku Earthquake and Tsunami," dated March 9,2012 (ADAMS Accession No. ML 120690347). This SRM stated, in part, that Completing implementation activities associated with the rule we have already promulgated has greater safety significance and also involves the coordinated actions of our partners in State and local governments. Substantial public credibility benefits accrue from continuing these activities as a priority. Enclosure

-2 The NRC staff considers the existing EP framework and regulations provides reasonable assurance of adequate protection of public health and safety in the event of a radiological emergency. The revised EP rule that was promulgated on November 23, 2011, initiated a number of activities that will enhance EP programs, including conducting a staffing analysis and enhancing public notification systems. The implementation of the EP rule was given priority by the Commission and the NTTF recommendations should not displace ongoing work that has greater safety benefit, higher priority, or is necessary for continued safe operation of nuclear power plants. The NTTF Report concluded that continued operation and continued licensing activities do not pose an imminent risk to the public health and safety and are not inimical to the common defense and security. The phased approach to responding to the 10 CFR 50.54(f) letters, combined with the definition of new response requirements associated with Fukushima NTTF Recommendation 4.2, as subsequently modified by the NRC staff and issued as NRC Order EA-12-049 (ADAMS Accession No. ML 12054A736), will ensure that enhancements will be made to staffing and communications by licensees. It should be noted that the 10 CFR 50.54(f) letter and implementation of the Order includes completion of actions related to response assignments, staffing changes, issuance of new or revised procedures or guidelines, and training. Activities are ongoing by both the NRC and industry to initiate interim actions as a result of lessons learned from the events which will be provided in the 90-day response such as:

• Methods to access the site

• Notification of staff

• Interim actions taken to date Given the above and that the licensee's approach was found to be consistent with the guidance of NEI 12-01 and the direction of the Commission, the NRC staff concludes that the licensee has provided an adequate basis for its proposed alternative responding to the 10 CFR 50.54(f) letters regarding communications and staffing for Recommendation 9.3. In its letter dated May 9, 2012, the licensee identified its proposed alternative course of action, as provided in the attachment to this staff evaluation. The licensee did not make any regulatory commitments as defined by industry guidance NEI 99-04, "Guidelines for Managing NRC Commitments."

PROPOSED ALTERNATIVE COURSE OF ACTION PROVIDED IN OMAHA PUBLIC POWER DISTRICT'S LETTER DATED MAY 9,2012 The following two tables provide the proposed alternative course of action related to Communications and Staffing items found in Enclosure 5 of the March 12, 2012, request for information. ,_._-_._--_.Request Estimated # Completion Date Requested Information Provide an assessmen t of the current communications systems and equipmen t used during an emergency event to identify any enhancem ents that may be needed to ensure communications are m aintained during a large scale natural event meeting the con ditions described [in the Discussion section]. The assessm ent should:

• Identify any pia nned or potential improvements to existing onsite communications systems and their 1 10/31/12

• required normal andlor backup power supplies, Identify any pia nned or potential improvements to communications systems and their existing offsite and/or backup power supplies, required normal

• Provide a descr iption of any new communications system(s) or technologies that will be deployed based upon the assum ed conditions described above, and

• iption of how the new and/or improved Provide a descr wer supplies will be able to providesystems and po !--, for communicati _ons loss ctions that have been taken or are Describe any interim a 2 06/11/12 enhance existing communications planned to be taken to systems power supplie s until the communications ._-_.. assessment and the re suiting actions are complete . Provide an implementation schedule of the time needed to the results of the communications conduct and implement assessment. 3 09/28/12 Conduct the communic ations assessment. 10/31/12 Provide an implementation schedule of the time needed to implement the results 0 f the communications assessment. Attachment

---2 StaffiInJJ Request Estimated Completion Date # Information 1 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 NRC 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). 4 months prior to Provide onsite and augmented staffing assessment beginning of considering functions related to NTTF Recommendation 4.2. second refueling [Phase 2 staffing assessment] outage1 1 As used within the context of NRC Order EA-12-049 (expected to occur in the fall of 2015).

-Request # Estimated Completion Date Requested Information 2 05/01/14 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 the time to implement the changes. 1. Conduct the onsite and augmented staffing assessment: The onsite and augmented staffing assessment considering functions related to NTIF Recommendation 4.2. [Phase 2 staffing assessment] 4 months prior to beginning of second refueling outage2 2. A schedule of the time needed to implement changes will be provided as follows: Those associated with the Phase 2 staffing assessment. 3 06/11/12 Identify how the augmented staff would be notified given degraded communications capabilities 4 06/11/12 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 large-scale natural event. 5 6-11-12 Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment. 6 4 months prior to beginning of second refueling outage2 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: Those associated with the Phase 2 assessment. 2 As used within the context of NRC Order EA-12-049 (expected to occur in the fall of 2015).

--D. Bannister -2 If you have any questions, please contact me at 301-415-1377 or via e-mail at Iynnea. wilkins@nrc.gov. Docket No. 50-285 Staff cc w/encl: Distribution via Listserv DISTRIBUTION: PUBLIC RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMFortCalhoun Resource RidsNsirDpr Resource RidsOgcRp Resource RidsRgn4MailCenter Resource CMurray, NSIR JShea. NRRI ..ILD JKratchman. NRR/JLD ADAMS Accession No. ML 121600122 Sincerely. IRN Lynnea E. Wilkins, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation *concurrence via email NSIR/DPRIDDEPE/NRLB/BCNRR/DORLlLPL4/PM INRRIDORL/LPL4/LAOFFICE '-KWilliams*NAME LWilkins IJBurkhardt 5/24/12DATE 6/8/12 J6/8/12 NRR/DORLlLPL4/PMNRR/JLD/PMB/BC INRR/DORLlLPL4/BCOFFICE LWilkinsNAME RPascarelli --l MMarkley . DATE 61111126/8/12 16111/12 OFFICIAL RECORD