Text

Responses to Request for Information, Per 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
	ML16028A329
Person / Time
Site:	Wolf Creek
Issue date:	01/18/2016
From:	Reasoner C; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EA-12-049, WO 16-0003
	Download: ML16028A329 (31)
	v • d • e

W6LFl CREEK "rNUCLEAR OPERATING CORPORATION Cleveland Reasoner Site Vice President January 18, 2016 WO 16-0003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

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"

2) Letter WO 12-0044, dated May 9, 2012, from S. E. Hedges, WCNOC, to USNRC, '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 Fukushima Dai-lchi Accident"

3) Letter WO 12-0049, dated June 6, 2012, from S. E. Hedges, WCNOC, to USNRC, "Wolf Creek Nuclear Operating Corporation 90-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"

4) Letter WO 14-0023, dated March 31, 2014, from R. A. Smith, WCNOC, to USNRC, "Request for Schedule Relaxation of NRC Order EA-12-049, Requirement IV.A.2, at Wolf Creek Generating Station"

5) Letter dated May 20, 2014, from E. J. Leeds, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events"'"

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation Fukushima Staffing Gentlemen:

This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Nuclear Regulatory Commission (NRC) requests for information (RFI) one, two, and six made in Enclosure #5, Recommendation 9.3: Emergency Preparedness, Staffing of Reference 1. The responses to RFIs three, four, and five were previously provided in Reference 3 that provided ,"

WCNOC's 90 day response to Reference 1. k/

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 /

An Equal Opportunity Employer M/F/HCNVET .*.

WO 16-0003 Page 2 of 3 In Reference 2 WCNOC committed to providing this remaining information four to five months prior to the second refueling outage after the issuance of the Order as defined in NRC Order EA-12-049. Schedule relaxation was subsequently requested (Reference 3), and granted (Reference 4), that extended the due date for these items to be four to five months prior to Wolf Creek Generating Station Refueling Outage 21, scheduled to begin in September 2016.

The Attachment to this letter provides a description of RFIs one, two, and six and WCNOC's responses.

The Enclosure provides the FLEX Staffing Study supporting these responses.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4171, or Cynthia R. Hafenstine (620) 364-4204.

Sincerely, Cleveland Reasoner CO R/rlt

Attachment:

Wolf Creek Nuclear Operating Corporation's Responses to Request for Information Pursuant to 10 CER 50.54(f) Regardng Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident

Enclosure:

FLEX Staffing Study cc: M. L. Dapas (NRC), w/a, w/e C. F. Lyon (NRC), w/a, w/e N. H. Taylor (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

WO 16-0003 Page 3 of 3 STATE OF KANSAS )

)ss COUNTY OF COFFEY )

Cleveland Reasoner, 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.

Cleveland Reasoner Site Vice President SUBSCRIBED and sworn to before me this !*/t~ay of(W* L , 2016.

] *.:"'RHO* in etExi res fyApp ll Notary rublic (

I '":*"**:'*i'J January11, 2Q, 18 Expi rat ion D t* 2J*,Y/])* *;

Attachment to WO 16-0003 Page 1 of 1 Wolf Creek Nuclear Operating Corporation's Responses to Request for Information Pursuant to 10 CFR 50.54(f) Regardng Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident Original request shown in italics.

I. It is requested that addressees provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described above. 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 reactoras 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-I, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operationalaccident assessment, as appropriate.

New staff or functions identified as a result of the assessment.

Collateralduties (personnel not being prevented form timely performance of their assigned functions).

Response: The staffing assessment was conducted in November 2015 using draft FLEX Support Guidelines. The FLEX Staffing Report is enclosed with this submittal. The assessment concluded that the current on-shift minimum staffing designated in the Emergency Plan is sufficient to perform the tasks associated with a beyond design basis natural event and implement the Emergency Plan.

2. 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.

Response: The staffing assessment was conducted in November 2015 using draft FLEX Support Guidelines. The assessment will need to be validated when the final FLEX Support Guidelines are approved. Final FLEX implementation is scheduled for December 2016.

6. Identify changes that have been made or will be made to your emergency plan regarding 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.).

Response: No changes need to be made to the Emergency Plan regarding on-shift or augmented staffing necessary to respond to a beyond design basis natural event and implement the Emergency Plan.

Enclosure to Letter WO 16-0003 FLEX Staffing Study (26 Pages)

Al V

FLEX Staffing Study 12/14/2015 Enercon Services Inc.

Bill Chausse

TABLE OF CONTENTS 1.0 Introduction................................................................................................ 2 2.0 Analysis Summary....................................................................................... 3 3.0 Analysis Overview....................................................................................... 5 4.0 Assumptions............................................................................................... 5 6.0 Event Staffing Analysis ................................................................................. 7 Attachments Attachment I - Acronyms................................................................................... 14 - References ................................................................................. 15 - NEI 10-05 Tables..................................................................... 16 - Participants .......................................................................... 25 1

1. Introduction In May, 2012, NEI published NEI 12-01, "Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and CommunicationsCapabilities". This guideline provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, 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-Ichi Accident, dated March 12, 2012. As discussed in SECY-1 1-0 137, "Prioritizationof Recommended Actions to be taken in Response to Fukushima Lessons Learned",

dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions.

Recommendation 4.2 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 the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site 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.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor licensees shall perform "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." The Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NHI 10-05, "Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities"to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. The methodology provided in this guidance was used to perform the Wolf Creek Nuclear Operating Corporation (WCNOC) On-Shift Staffing Assessment (OSSA), conducted in November 2015..

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This report provides the staffing assessment results for Wolf Creek Nuclear Plant as required by the US Nuclear Regulatory Commission (NRC) letter, 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-Ichi Accident, dated March 12, 2012.

2. Analysis Summary The assessment concluded that the on-shift staff as defined in the current Wolf Creek Emergency Plan and augmented ERG is adequate to implement existing and planned BDBEE and ELAP strategies while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. Gaps identified during the Staffing Assessment process should be addressed through the Wolf Creek Corrective Action Program.

Gaps identified:

a. The staffing assessment was not performed with the final approved versions of procedures and guidelines that will be used during an ELAP. (CR00050727-01-10)

b. FLEX Support Guideline task training/qualification is not yet developed and incorporated into the appropriate training programs. (CR00050727-0 1-10)

c. Current drill and exercise procedures do not include objectives or demonstration criteria for FLEX implementation. (CR00066747-02-46)

3. Analysis Overview Staffing Analysis Scope The Wolf Creek Nuclear Plant staffing assessment was performed using the guidance of NEI 12-01 to conduct the staffing assessment. This assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

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Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

2. Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before Extended Loss of AC Power (ELAP) is declared.

3. Evaluate the EOPs and FSGs for responding to an ELAP affecting the unit. (Note:

Draft FSGs were used.)

4. Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.

5. Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

The staffing level determined as a result of the Phase 2 assessment will be verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed. Validation will be performed at a date after the submittal of the staffing assessment report per NEI guidance "FLEX Beyond Design Basis Validation Process" dated July 18, 2014.

Necessary corrective actions will be tracked using the WCNOC corrective action program if the validation determines the assumed resources cannot complete a time sensitive action within the constraints identified in the Overall Integrated Plan (OIP) per NRC Order EA-12-049.

Methodology A tabletop assessment was performed to determine what operational and emergency response actions were procedurally required during an ELAP. Representatives from Wolf Creek Operations, Maintenance, Radiation Protection, Chemistry, Procedure Writers, Engineering, Security, and Emergency Preparedness met with an industry consultant in a tabletop exercise in November 2015. The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing.

Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step. Because the FSGs were not 4

finalized, the results of the assessment are preliminary and will require validation prior to FLEX implementation. All gaps identified will be addressed through the Wolf Creek corrective action program.

The team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Table 5.1) recording the tasks and the approximate time at which they were performed following the event. In reviewing on-shift staffing tasks, the team was alert to identify instances where staff members were assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Plan responsibilities.

The assessment team used the guidance of NEI 10-05 to determine if the number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables (Attachment 3) were modified to include tasks associated with FLEX strategies.

4. Assumptions NEI 12-0 1 Assumptions for Staffing Analysis The set of standard assumptions that were used in the development of this report:

1. A large-scale external event occurs that results in:

all on-site units affected

extended loss of AC power

impeded access to the units

2. All on-site reactors are operating at full power and are successfully shut down.

3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

4. The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

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C. Post event time: 24+ hours - lImproved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

5. The on-shift personnel complement is limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), use the staffing with the smallest total number of personnel.

NEI 10-05 Applicable Assumptions In accordance with this guidance, the following assumptions and limitations apply to the Phase 20OSSA:

1. On-shift personnel can report to their assigned response locations within the timeframes sufficient to allow for performance of assigned actions.

2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.

3. Personnel assigned to the major response area of Plant Operations and Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown.

Note: Staff performance within this area was not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.

4. Performance of the on-site security organization's function is regularly analyzed through other station programs and was not evaluated in the OSSA, unless a role or function from another major response area was assigned as a collateral duty.

5. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.

6. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an 6

Offsite Response Organization (ORO) or the NRC. Communications methods will be different, i.e. Satellite phones instead of dedicated phone lines. Satellite phones require clear view of southern sky and therefore the communicator must go outside or set up an outside antenna. As such the communication to the State, Counties and the NRC will be done in series as each phone must be dialed separately. The satellite phones have simple usage cards with each phone and the use is similar to the use of a Cellular phone within the capability of the communicator.

7. The task of performing a peer check had minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.

8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

5. Event Staffing Analysis Minimum On-Shift Staffing The shift staffing requirements for Wolf Creek are listed in the table below. The methodology of NEL 12-01 requires that only personnel required to be on-shift can be credited in the staffing analysis.

AP 06-002, Radiological Emergency Response Plan, WCGS Minimum Staffing for Emergencies Position On-Shift Shift Manager (SRO) 1 Control Room Supervisor (CRS) 1 Reactor Operator (RO#1 & RO#2) 2 Nuclear Station Operator (NSO AB) 1 Nuclear Station Operator (NSO TB) 1 Nuclear Station Operator (NSO Site) 1 Nuclear Station Operator (NSO FBL) 1 Nuclear Station Operator (NSO OFN 16) 1 Shift Technical Advisor (STA) 1 HP Personnel (HP#1, HP#2 & HP#3) 3 Chemistry Personnel (Chem #1 & Chem #2) 2 Communicators (Comm #1 & Comm #2) 2 Total 17 Security Per Security Plan 7

Scenario Overview The BDBEE assumes a loss of off-site power combined with a failure of the emergency diesel generators to load. All remaining power is supplied by the station batteries. The loss of AC power to emergency buses initially results in the declaration of a Site Area Emergency. When it becomes apparent that power will be unavailable for a prolonged period, the event classification is escalated to a General Emergency.

Wolf Creek utilizes a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase utilizes installed equipment and resources to monitor, maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase uses offsite resources to sustain those functions indefinitely. Portable and off-site equipment location and operation during the Transition and Final Phases is addressed through the FSG's.

EMG E-O and EMG C-O are the governing procedures for the BDBEE initial response. Actions are focused on response to the unit trip, restoration of electrical power and establishing ventilation in different areas of the plant.

FLEX strategies are focused on maintaining or restoring key plant safety functions and are not tied to any specific damage state or mechanistic assessment of external events.

Staffing Analysis Summary Tables 5.1 & 5.2 provide the results of the actions taken to the BDBEE transient using installed plant and portable equipment and the available staffing complement.

The on-shift staff performed actions required by operating and emergency plan procedures in the 6-hour period, relying oniy on installed structures, systems and components available in the Initial Phase of the response.

The assessment concluded that the on-shift staff as defined in the current Wolf Creek Emergency Plan and augmented ERO is adequate to implement existing and planned BDBEE and ELAP strategies while continuing to perform required Emergency Planning tasks without unacceptable collateral duties.

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Table 5.1 On-Shift Staff Actions (Within the first seven hours)

Resources Tasks by Time (min)I Shift Manager (SM)

Shift Technical Advisor (STA)

Control Room Supervisor (CRS)

Reactor Operator RatrOperator Nuclear Systems Operator (NSO TB)

Nuclear Systems Operator (NSO Site) 9

x----------

Nuclear Systems Operator (NSO FBL)

Nuclear Systems Operator (NSO OFN 16)

Health Physics Technician (HP 1)

Health Physics Technician (HP 2)

Health Physics Technician (HP 3) iChemistry Technician I (Chem 1)

Chemistry Technician (Chem 2)

Communicator I

(Comm 1)

Communicator (Comm 2)

Security Note :Numbers in this table refer to the task numbers in Table 5.2 Task Listing 10

Task Table 5.2 Task Listing Time Performer

Task Description

1. Emergency Coordinator (Control Room) Duration SM

2. Engineering Oversight (Control Room) Duration STA Emergency Procedures Implementation!/Monitoring and Drto R!R

3. Control (Control Room)

4. Emergency Communications Duration Communicators Dose Assessment Duration Chem 1 Locally close the RCS and pressurizer sample line isolation 1 0(B

6. valves at 3 locations in the aux building 1 O(B Attempt to start EDG' s locally!/Attempt to restore electrical

7. power to at least one emergency bus 10 Min SO (TB) 8.Isolate RCP seals 5Min SO (AB)

9. Manually start the diesel fire pump 15 Min SO (Site)

TSC diesel -local start 20 Min SO (FBL) 11 Emergency ventilation - TDAFW doors opened 5 Min SO (TB)

Emergency ventilation - Cabinet doors in the control 1 mR

12. building15MnR1 1.Check DC bus loads (Load shed) 1 i O(B SO (TB)

14. Damage assessment of buildings!/equipment 30Min SO (AB)

Debris Removal (as required) - Including gate removal!/0M O(F 6

15. access 11

Task Table 5.2 Task Listing Time Performer

Task Description

16. Deploy cables!/generator 480 VAC generator 30 Min SO (Site)

SO (OFN 16)

17. SFP Ventilation 60Min HP1 Security

18. SFP Hose- to SFP location 45 Min SO (AB)

19. Deploy SFP hose 30Min SO (AB)

Deploy 120 VAC generator, 4 ventilation panels and

20. associated cables (two trips with Polaris!/one trip with the 30 Min SO (Site) truck)

Load Centers NG-0 1 thru 4/ - open circuit breakers (FSG-4, 20MSO(B

21. Attachment A) 2 i O(B SO (TB)

22. Run cables!/hook up to panels 45 Min SO (FBL)

Tasks Performed Following First Six Hours!/Augmented Staff Available Energize NG-01 load center from FLEX generator 60(TB)

23. (Attachment B), generator running, ready to load the bus 60M SO (TB)

24. Energize loads (Attachment C) 90 Min SO (FBL)

SO (OFN 16)

25. Control Building Ventilation deployment 90 Min HP 12

SO 2.Deploy FLEX Air Compressors 6 i 1 Aug Deploy FLEX Core Cooling Pump -includes deployment 30 MinS

27. and three hoses 1 Aug 2 SO

28. Place FLEX Core Cooling pump in service 60 Min 1 Aug

29. Refueling of portable equipment endr tocAug 3.FLEX RCS Make-Up Pump - calculations required 60 Min RO Deploy RCS Make-up suction & discharge path (pump pre- 60 Min 2 SOs

31. staged)

Place CST Make-Up pump rn service - stage (pump pre- 20M u

32. staged) hoses24Mi6Au HP surveys will be required when cooldown commences 600 Min HP 3.One chemist will be in control room for dose assessment Ento CHIEM Accumulator isolation from control room (prior to R

35. cooldown to 120#) or vent to containment SO

36. CR HP Coverage miutsHP#

Notes:

S Draft versions of the FSG' s were utilized for the staffing analysis.

S Security will be present for Task #17 as part of normal response to the roll-up door S

RO#l assists with emergency ventilation by opening cabinet doors in the control building 0

Augmented staff utilized after 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months when site access is partially restored (Task #26) 13

Attachment 1 Acronyms AOP Abnormal Operating Procedure BDBEE Beyond Design Basis External Event CFR Code of Federal Regulations EDG Emergency Diesel Generator EOP Emergency Operating Procedure ERO Emergency Response Organization HP Health Physics Technician NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NTTF Near Term Task Force RCP Reactor Coolant Pump RCS Reactor Coolant System SAMG Severe Accident Management Guidelines SBO Station Blackout SFP Spent Fuel Pool SO System Operator TSC Technical Support Center 14

Attachment 2 References

1. EMG C-O, Loss of All AC Power

2. EMG E-0, Reactor Trip or Safety Injection

3. OFN K J-032, Local Emergency Diesel Startup

4. QFN NB-030, Loss of AC Emergency Bus NB01 (NB02)

5. STN KAT-001, TechnicaJ Support Diesel Generator Operation

6. SYS SY-1 20, Sharpe Diesel Operation and Alignment to Site

7. FSG-1 Long Term Inventory Control

8. FSG-3 Alternate Low Pressure Feedwater

9. FSG-4 ELAP DC Load Shed/ Management

10. FSG-5 Initial Assessment and FLEX Equipment Staging

11. FSG-6 Alternate CST Makeup

12. FSG-7 Loss of Vital Instrumentation or Control Power

13. FSG-8 Alternate RCS Boration

14. FSG-9 Low Decay Heat Temperature Control

15. FSG-10 Passive RCS Injection Isolation

16. FSG-11lAlternate SEP Makeup and Cooling

17. FSG-1 2Alternate Containment Cooling

18. FSG-13Transition from FLEX Equipment

19. NEI 10-05 (Rev. 0), "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities"

20. NEI 12-01 (Rev. 0), Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities 15

Attachment 3 NET 10-05 Table 1 - On-Shift Positions Augmentation Role in Unanalyzed TMS Line On-Shift Position Emergency Plan Reference Elapsed Time Table#/'Line Task? Required?

mrinm 1 Shift Manager Radiological Emergency Response NA T2/L1 No No Plan, Figure 2, "Minimum Shift T5/L1 Staffing" & Attachment D, "WCGS T5/L2 Minimum Staffing for T5/L3 Emergencies" T5/L4 T5/L5 T5/L8 T5/L10 T5/L13 Shift Technical Radiological Emergency Response NA T2/L3 No No 2 Advisor Plan, Figure 2, "Minimum Shift T5/L11 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 3 Control Room Radiological Emergency Response NA T2/L2 No No Supervisor Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 4 Reactor Operator #i1 Radiological Emergency Response N/A T2/L4 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS

___________________Minimum Staffing for_________________________

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Emergencies" Reactor Operator #2 Radiological Emergency Response N/A T2/L4 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Station Operator #1 Radiological Emergency Response N/A T2/L6 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Station Operator #2 Radiological Emergency Response N/A T2/L7 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Station Operator #3 Radiological Emergency Response N/A T2/L8 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Station Operator #4 Radiological Emergency Response N/A T2/L9 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 17

Station Operator #5 Radiological Emergency Response N/A T2/ L10 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Chemistry Radiological Emergency Response 60 T2/ Li1 No No Technician #1 Plan, Figure 2, "Minimum Shift T4/L5 Staffing" & Attachment D, "WCGS T4/L6 Minimum Staffing for Emergencies" Chemistry Radiological Emergency Response 60 T2/ L12 No No Technician #2 Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" HP Tech #1 Radiological Emergency Response T2/ L13 No No Plan, Figure 2, "Minimum Shift T4/L1 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" HP Tech #2 Radiological Emergency Response T2/ L14 No No Plan, Figure 2, "Minimum Shift T4/ L2 Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" HP Tech #3 Radiological Emergency Response T2/Li15 No No Plan, Figure 2, "Minimum Shift T41/L3

______________Staffing" & Attachment D, "WCGS 18

Minimum Staffing for Emergencies" 16 Communicator #1 Radiological Emergency Response T2/ L16 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 17 Communicator #2 Radiological Emergency Response T2/ L17 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" Security Radiological Emergency Response N/A T5/L15 No No Plan, Figure 2, "Minimum Shift Staffing" & Attachment D, "WCGS Minimum Staffing for Emergencies" 19

Attachment 3 NET 10-05 TABLE 2 - Plant Operations, Safe Shutdown & FLEX Operations Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Control Room Supervisor Operations Training 3 Shift Technical Advisor Shift Technical Advisor Operations Training 4 Reactor Operator #1 Reactor Operator #1 Operations Training 5 Reactor Operator #2 Reactor Operator #2 Operations Training 6 Station Operator #1 Station Operator (AB) Operations Training 7 Station Operator #2 Station Operator (TB) Operations Training 8 Station Operator #3 Station Operator (Site) Operations Training 9 Station Operator #4 Station Operator (FBL) Operations Training 10 Station Operator #5 Station Operator (OFN 16) Operations Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Chemistry Tech #1 Chemistry Technician Chemistry Training 12 Chemistry Tech #2 Chemistry Technician Chemistry Training 13 Health Physics Tech #1 Health Physics Technician Health Physics Training 14 Health Physics Tech #2 Health Physics Technician Health Physics Training 15 Health Physics Tech #3 Health Physics Technician Health Physics Training 16 Communicator #1 As assigned Emergency Plan Training 17 Communicator #2 As assigned Emergency Plan Training 18 Security N/A Security Training 20

Attachment 3 NET 10-05 TABLE 3 - Firefighting Line Performed By Task Analysis Controlling Method 1 N/A - there is no fire N/A

___associated with this event.

2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A 21

Attachment 3 NEI 10-05 TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Emergency Declaration (minutes)

Line Position 0- 5- 10- 15 25 35 45 55 65 75- 85-performing 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 90 Function!/Task 1 In-Plant Survey On-Shift Position: X X X X X X X X X X X X X X HP Tech Surveys ____ __ ____

2 On-Site Survey On-Shift N/A The performance of an on-site survey is not necessary for implementation of the Emergency Plan and Position: is not required by any procedure. No radiological release for this event.

3 Personnel Monitoring X X X X X X X X X X X X On-Shift Position:

CR HP Tech 4 Job Coverage On-Shift X XX X X X X X X X X X Position:

HP Tech As needed 5 Offsite Radiological X XX X X X X X X X X X X X X X X Assessment On-Shift Position:

___Chemistry Tech. ______ ___________ ___________

22

Attachment 3 NEI 10-05 TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position Task Analysis Controlling Method 1 Declare the Emergency Operations Training ClssfiatonLeel(EL)Shift Manager EP Training/Drill Program 2 Approve Offsite Protective Action Operations Training Recommendations and Shift Manager EP Training/Drill Program 3 Approve content of State/local Operations Training notifications SitMngrand Shif MangerEP Training/Drill Program 4 Approve extension to allowable Operations Training dose limits SitMngrand Shift anagerEP Training/Drill Program 5 Notification and direction to On- Operations Training shift staff (e.g., to assemble, SitMngrand evacuate, etc.) hitMngrEP Training/Drill

______________________Program 6 ERO notification Operations Training Statin Opeator EP Training/Drill

________Program 7 Abbreviated NRC notification for NAfrti vn /

DBT event NAfrti vn /

8 Complete State/local notification Operations Training Form and FomShift Manager EP Training/Drill Program 9 Perform State/local notifications Operations Training Statin Opeator EP Training/Drill Program 10 Complete NRC event notification Operations Training form Shift Manager and EP Training/Drill

________ _______________________ _______________Program 11 Activate ERDS TSC ERIE Computer EP Training/ Drill

___________________Operator Program 23

12 Offsite radiological assessment Chemistry Training N/A - Table 4an EP Training/Drill Chemistry TechPrga 13 Perform NRC notifications Maintenance Training Communicatoran EP Training/Drill Program 14 Perform other site-specific event Operations Training notifications (e.g., INPO, ANI, Stto prtrand etc.) Stto prtrEP Training/Drill Program 15 Personnel accountability SeuiySainSecurity Training and Secuity StaionEP Training/Drill Operator Program 24

Attachment 4 Tabletop Participants Rick Foust Engineering Chad Carmen Chemistry Joe Franks FLEX Procedure Writer Jim Gilmore FLEX Procedure Writer Monty Thomas Security Marcus Stice Operations Frank Buchman Emergency Planning John Schepers Radiation Protection 25

W6LFl CREEK "rNUCLEAR OPERATING CORPORATION Cleveland Reasoner Site Vice President January 18, 2016 WO 16-0003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

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"

2) Letter WO 12-0044, dated May 9, 2012, from S. E. Hedges, WCNOC, to USNRC, '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 Fukushima Dai-lchi Accident"

3) Letter WO 12-0049, dated June 6, 2012, from S. E. Hedges, WCNOC, to USNRC, "Wolf Creek Nuclear Operating Corporation 90-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"

4) Letter WO 14-0023, dated March 31, 2014, from R. A. Smith, WCNOC, to USNRC, "Request for Schedule Relaxation of NRC Order EA-12-049, Requirement IV.A.2, at Wolf Creek Generating Station"

5) Letter dated May 20, 2014, from E. J. Leeds, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station Unit 1 - Relaxation of the Schedule Requirements for Order EA-12-049 'Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events"'"

Subject:

Docket No. 50-482: Wolf Creek Nuclear Operating Corporation Fukushima Staffing Gentlemen:

This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Nuclear Regulatory Commission (NRC) requests for information (RFI) one, two, and six made in Enclosure #5, Recommendation 9.3: Emergency Preparedness, Staffing of Reference 1. The responses to RFIs three, four, and five were previously provided in Reference 3 that provided ,"

WCNOC's 90 day response to Reference 1. k/

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 /

An Equal Opportunity Employer M/F/HCNVET .*.

WO 16-0003 Page 2 of 3 In Reference 2 WCNOC committed to providing this remaining information four to five months prior to the second refueling outage after the issuance of the Order as defined in NRC Order EA-12-049. Schedule relaxation was subsequently requested (Reference 3), and granted (Reference 4), that extended the due date for these items to be four to five months prior to Wolf Creek Generating Station Refueling Outage 21, scheduled to begin in September 2016.

The Attachment to this letter provides a description of RFIs one, two, and six and WCNOC's responses.

The Enclosure provides the FLEX Staffing Study supporting these responses.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4171, or Cynthia R. Hafenstine (620) 364-4204.

Sincerely, Cleveland Reasoner CO R/rlt

Attachment:

Wolf Creek Nuclear Operating Corporation's Responses to Request for Information Pursuant to 10 CER 50.54(f) Regardng Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident

Enclosure:

FLEX Staffing Study cc: M. L. Dapas (NRC), w/a, w/e C. F. Lyon (NRC), w/a, w/e N. H. Taylor (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

WO 16-0003 Page 3 of 3 STATE OF KANSAS )

)ss COUNTY OF COFFEY )

Cleveland Reasoner, 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.

Cleveland Reasoner Site Vice President SUBSCRIBED and sworn to before me this !*/t~ay of(W* L , 2016.

] *.:"'RHO* in etExi res fyApp ll Notary rublic (

I '":*"**:'*i'J January11, 2Q, 18 Expi rat ion D t* 2J*,Y/])* *;

Attachment to WO 16-0003 Page 1 of 1 Wolf Creek Nuclear Operating Corporation's Responses to Request for Information Pursuant to 10 CFR 50.54(f) Regardng Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident Original request shown in italics.

I. It is requested that addressees provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described above. 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 reactoras 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-I, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operationalaccident assessment, as appropriate.

New staff or functions identified as a result of the assessment.

Collateralduties (personnel not being prevented form timely performance of their assigned functions).

Response: The staffing assessment was conducted in November 2015 using draft FLEX Support Guidelines. The FLEX Staffing Report is enclosed with this submittal. The assessment concluded that the current on-shift minimum staffing designated in the Emergency Plan is sufficient to perform the tasks associated with a beyond design basis natural event and implement the Emergency Plan.

2. 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.

Response: The staffing assessment was conducted in November 2015 using draft FLEX Support Guidelines. The assessment will need to be validated when the final FLEX Support Guidelines are approved. Final FLEX implementation is scheduled for December 2016.

6. Identify changes that have been made or will be made to your emergency plan regarding 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.).

Response: No changes need to be made to the Emergency Plan regarding on-shift or augmented staffing necessary to respond to a beyond design basis natural event and implement the Emergency Plan.

Enclosure to Letter WO 16-0003 FLEX Staffing Study (26 Pages)

Al V

FLEX Staffing Study 12/14/2015 Enercon Services Inc.

Bill Chausse

TABLE OF CONTENTS 1.0 Introduction................................................................................................ 2 2.0 Analysis Summary....................................................................................... 3 3.0 Analysis Overview....................................................................................... 5 4.0 Assumptions............................................................................................... 5 6.0 Event Staffing Analysis ................................................................................. 7 Attachments Attachment I - Acronyms................................................................................... 14 - References ................................................................................. 15 - NEI 10-05 Tables..................................................................... 16 - Participants .......................................................................... 25 1

1. Introduction In May, 2012, NEI published NEI 12-01, "Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and CommunicationsCapabilities". This guideline provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, 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-Ichi Accident, dated March 12, 2012. As discussed in SECY-1 1-0 137, "Prioritizationof Recommended Actions to be taken in Response to Fukushima Lessons Learned",

dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions.

Recommendation 4.2 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 the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site 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.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor licensees shall perform "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." The Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NHI 10-05, "Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities"to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. The methodology provided in this guidance was used to perform the Wolf Creek Nuclear Operating Corporation (WCNOC) On-Shift Staffing Assessment (OSSA), conducted in November 2015..

2

This report provides the staffing assessment results for Wolf Creek Nuclear Plant as required by the US Nuclear Regulatory Commission (NRC) letter, 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-Ichi Accident, dated March 12, 2012.

2. Analysis Summary The assessment concluded that the on-shift staff as defined in the current Wolf Creek Emergency Plan and augmented ERG is adequate to implement existing and planned BDBEE and ELAP strategies while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. Gaps identified during the Staffing Assessment process should be addressed through the Wolf Creek Corrective Action Program.

Gaps identified:

a. The staffing assessment was not performed with the final approved versions of procedures and guidelines that will be used during an ELAP. (CR00050727-01-10)

b. FLEX Support Guideline task training/qualification is not yet developed and incorporated into the appropriate training programs. (CR00050727-0 1-10)

c. Current drill and exercise procedures do not include objectives or demonstration criteria for FLEX implementation. (CR00066747-02-46)

3. Analysis Overview Staffing Analysis Scope The Wolf Creek Nuclear Plant staffing assessment was performed using the guidance of NEI 12-01 to conduct the staffing assessment. This assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

3

Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.