ML14268A247

North Anna Units 1 & 2, March 12, 2012 Information Request Response to Request for Additional Information Regarding Phase 2 Staffing Assessment Report Recommendation 9.3 (TAC Nos. MF4319 and MF4320)

ML14268A247
Person / Time
Site:	North Anna
Issue date:	09/22/2014
From:	Stoddard D G Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-435, TAC MF4319, TAC MF4320
Download: ML14268A247 (7)

Text

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261September 22, 2014U.S. Nuclear Regulatory Commission Serial No. 14-435Attention: Document Control Desk NL&OS/GDM ROWashington, DC 20555 Docket Nos. 50-338/339License Nos. NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANYNORTH ANNA POWER STATION UNITS 1 AND 2MARCH 12. 2012 INFORMATION REQUESTRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING PHASE 2 STAFFING ASSESSMENT REPORTRECOMMENDATION 9.3 (TAC NOS. MF4319 AND MF4320)By letter dated May 7, 2014 (ADAMS Accession No. ML14133A011), Virginia Electric andPower Company (Dominion) submitted the Phase 2 Staffing Assessment Report for NorthAnna Power Station Units 1 and 2 in response to the Nuclear Regulatory Commission (NRC)March 12, 2012 Information Request. In a letter dated August 21, 2014, the NRC transmitteda request for additional information (RAI) related to the submittal. Dominion's response to theRAI is provided in the attachment.As noted in the implementation schedule provided in the May 7, 2014 letter, re-evaluation ofthe staffing assessment using the final approved versions of the FLEX Support Guidelinesprocedures and the final approved on-shift communications equipment, Dominion intends torevise and resubmit the staffing assessment report by January 30, 2015.If you have any questions regarding this information, please contact Wanda Craft at(804) 273-4687.Sincerely,Daniel G. Stoddard vicki L HullNO'mRy PUBLICSenior Vice President -Nuclear Operations Commonwealth of VirginiaVirginia Electric and Power Company Reg. # 140542 IMy Commission Expires May 31, 2018COMMONWEALTH OF VIRGINIA)COUNTY OF HENRICOThe foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today byDaniel G. Stoddard, who is Senior Vice President -Nuclear Operations of Virginia Electric and Power Company. He hasaffirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, andthat the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this 42 ~day of ( 2014.My Commission Expires: .A A -(, Q0/9Notary Public Serial No. 14-435Docket Nos. 50-338/339Page 2 of 2Commitments made in this letter: NoneAttachment:Response to Request for Additional Information Regarding Phase 2 Staffing AssessmentReportcc: U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257Dr. V. Sreenivas, NRC Project Manager -North AnnaU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Ms. Karen Cotton, NRC Project Manager -SurryU. S. Nuclear Regulatory CommissionOne White Flint NorthMail Stop 08 G9A11555 Rockville PikeRockville, Maryland 20852Brian K. HarrisProject ManagerU.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 11 F111555 Rockville PikeRockville, MD 20852-2738NRC Senior Resident InspectorNorth Anna Power Station

.tSerial No. 14-435Docket Nos. 50-338/339ATTACHMENTRESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGPHASE 2 STAFFING ASSESSMENT REPORTVIRGINIA ELECTRIC AND POWER COMPANY(DOMINION)NORTH ANNA POWER STATION UNITS 1 AND 2 Serial No. 14-435Docket Nos. 50-338/339Attachment, Page 1 of 4Response to Request for Additional InformationPhase 2 Staffing Assessment ReportNorth Anna Power Station Units 1 and 2By letter dated May 7, 2014, (ADAMS Accession No. ML14133A011), Virginia Electricand Power Company (Dominion) submitted the Phase 2 Staffing Assessment Report forNorth Anna Power Station Units 1 and 2 in response to the Nuclear RegulatoryCommission (NRC) March 12, 2012 Information Request. In a letter dated August 21,2014, the NRC transmitted a request for additional information (RAI) related to thesubmittal. Dominion's response to the NRC RAI is provided below.NRC Question IIn your Phase 2 Staffing Assessment dated May 7, 2014, you provided information thatstated the following: (1) North Anna Power Station (NAPS) current on-shift staffing maynot be sufficient to perform the FLEX Support Guidelines (FSGS) identified by thestation to support activities following a Beyond-Design-Basis External Event, (2) Shiftpersonnel are not yet trained to perform FSG tasks, and (3) The qualification of on-shiftauxiliary operators (AOs) requires further review to ensure their capabilities toimplement the FSG strategies.Provide an update or supplement to the Phase 2 Staffing Assessment that indicatesNAPS has determined that the current on-shift staffing is capable of performing allrequired FSG tasks and all associated required training has been provided. Include anyactions taken to correct this issue, or justification as to why no action is required.Dominion ResponseThe NEI 12-01 Phase 2 Staffing Assessment that Dominion submitted to the NRC onMay 7, 2014 (Serial No.14-199, ML14133A011) contained four items that requiredfollow-up action based on the results of the assessment (reference Attachment 2 of theMay 7, 2014 letter). The four follow-up action items have been resolved and their statusis provided below:1. Initial FSG task training for site personnel has been completed and FSG tasktraining requirements have been incorporated into the applicable departmentaltraining programs.2. A final NEI 12-01 Phase 2 Staffing Assessment table top exercise was conductedon August 27, 2014 using the final, approved FSGs and Emergency OperatingProcedures (EOPs). The table top exercise validated that the FSG strategiescould be successfully implemented using the current on-shift staff. Thepersonnel participating in the table top exercise had previously received finaltraining on the FSGs/EOPs.

Serial No. 14-435Docket Nos. 50-338/339Attachment, Page 2 of 4An additional task identified subsequent to the tabletop requires a backupmethod for plant announcements. A Chemistry Technician has been assigned toperform this task.3. FSG task qualification training has been provided to the Auxiliary Operators. Inaddition, FSG task qualification requirements have been incorporated into theoperator training program.4. Dominion intends to revise the staffing assessment report to incorporate thisupdated information. As previously committed in the May 7, 2014 letter, a finalrevision of the Dominion NEI 12-01 Phase 2 Staffing Assessment Report will besubmitted to the NRC by January 30, 2015.NRC Question 2A review was also completed of the current security plan to identify the documented onshift security personnel (Revision 19). The following site specific information wasreviewed from the North Anna staffing study submittal (P.6, 17, 18, 21, 22). Thesespecific page numbers provided information concerning the use of security personnelduring events that were described in the staffing study. The site specifically stated that,"security personnel perform both security contingency plan actions and EP tasksconsisting of ERO notification and site personnel accountability. A representative of theNorth Anna Power Station Security department analyzed the EP tasks assigned to on-shift security individuals. It was concluded that performance of the EP tasks did notcause an overlap with their tasks related to the security plan.The following items were noted:1) Security is tasked to remove debris and to configure certain site equipment foruse.2) The staffing analysis determined that these duties (i.e., FSGs) would not causean overlap with the security tasks assigned in the site security plan.3) In accordance with Appendix C to Part 73,Section II.B.5(i), licensees shallestablish and maintain written implementing procedures that provide specificguidance and operating details that identify the actions to be taken and decisionsto be made by each member of the security organization who is assigned dutiesand responsibilities required for the effective implementation of the security plansand the site protective strategy.The NRC staff has reviewed your Staffing Assessment dated May 7, 2014, andrequests the following information to complete its review.

Serial No. 14-435Docket Nos. 50-338/339Attachment, Page 3 of 41) Has security received site specific training for removing [debris] and how toconfigure certain site equipment (e.g., equipment use, approaches to removedebris, associated procedures)? What are the main components of this training?How often is this training provided to security personnel?Dominion ResponseSecurity Officers qualified as Fire Brigade Members (FBMs) (extra positions above theminimum security plan staffing requirements) have received site specific training asbeyond design basis (BDB) Equipment Operators for: 1) debris removal from haulpaths, and 2) staging BDB equipment. Following a Job and Task Analysis conductedby the Nuclear Training Department, a new role as BDB Equipment Operator and twonew tasks were added for the Security Officers qualified as FBMs. The two new tasksare as follows:" Deliver equipment using a tow tractor." Clean debris using a wheel loader.Using the systematic approach to training, a training program has been developed andimplemented to initially train and qualify the Security Officers-FBMs as BDB EquipmentOperators. These Security Officers will be enrolled in a continuing training program tobe retrained on these two tasks on an annual basis.An additional task identified subsequent to the tabletop requires deployment ofcommunications equipment. As they become available before or after debris removal,the Security Officers -FBMs are assigned to support this task. An equipment operatingaid will be used for deployment of the communications equipment.2) Describe in detail how the normal on shift security personnel are allocated toprovide individuals to support EP functions [while] simultaneously continuing tomaintain their tasks related to the security plan. This description should addressthe tiered approach of the use of security personnel that is discussed in the NEIdocument, "Generic Basis for Responses to Staffing Assessment QuestionsRelated to Use of Security Personnel during a BDB Response". The response tothis question should be reviewed for the applicability of 10 CFR 73.21.Dominion ResponseThe Security Shift Supervisor and/or other on-shift security personnel perform SecurityContingency Plan tasks and Emergency Plan (EP) tasks [i.e., Emergency ResponseOrganization (ERO) notification and personnel accountability] during an Extended Lossof AC Power (ELAP) event. The security personnel perform the EP tasks from theirassigned location which does not interfere with their assigned tasks related to theSecurity Plan. The EP tasks were previously validated as part of the site's review for Serial No. 14-435Docket Nos. 50-338/339Attachment, Page 4 of 4NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing andCapabilities. The validation concluded performance of EP tasks did not cause anoverlap with their tasks relative to the Security Plan. In addition, Emergency PlanImplementing Procedures (EPIPs) contain guidance to perform the EP tasks, andSecurity personnel demonstrate effectiveness through EP training/drills and HostileAction Based exercises.The Security Officers -FBMs discussed in the response above are extra positionsabove the minimum security plan staffing requirements and do not have a requiredsecurity role during an ELAP event which allows them to perform assigned FSG taskswithout impacting the implementation of the Security Plan.In NEI document, "Generic Basis for Responses to Staffing Assessment QuestionsRelated to Use of Security Personnel during a BDB Response," two criteria consideredfor the tiered approach in the use of security personnel to apply are: 1) the securitypersonnel being used are credited in the security plan, and 2) the security personnel areperforming BDB tasks. The security personnel performing the EP tasks of EROnotification and personnel accountability are not performing BDB tasks so the NEIdocument does not apply to these individuals. The Security Officers -FBMs whoperform the BDB tasks of debris removal and equipment staging are extra securitypositions above the minimum security plan staffing requirements and do not have arequired security role during an ELAP event; therefore, the NEI document does notapply to these individuals.3) Have site procedures been developed for how security personnel are releasedfrom supporting beyond design basis event activities which would include thepriority of their dismissal? Are detailed security site procedures developed toreturn security to a normal posture after beyond design basis events?Dominion ResponseSite procedures describing the release of security personnel from supporting BDB eventactivities for an ELAP event, which would include the priority of their dismissal, are notrequired to control the use of the two Security Officers -FBMs. These two individualsare in positions above the minimum security plan staffing requirements and do not havea required security role during an ELAP event.