NRC 2012-0027, NextEra Energy Point Beach, LLCs - 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1.2.3, and 9.3, of the Near-Term Task Force Review of In
| ML12131A664 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/10/2012 |
| From: | Meyer L Point Beach |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2012-0027 | |
| Download: ML12131A664 (8) | |
Text
POINT BEACH May 10,201 2 NRC 201 2-0027 I 0 CFR 50.54(f)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 1 1555 Rockville Pike Rockville, MD 20852 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 NextEra Energv Point Beach, LLC's 60-Day Response to NRC Letter, Request for lnformation Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regardinq Recommendations 2.1.2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident: dated March 12,2012
References:
(1)
U.S. Nuclear Regulatory Commission, "Request for lnformation 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,"
March 12,2012 (ML12053A340)
Via Reference (I), the Nuclear Regulatory Commission (NRC) issued a request for information pursuant to 10 CFR 50.54(f). Enclosure 5 of Reference (I) contains specific Requested Actions and Requested lnformation associated with Recommendation 9.3 for Emergency Preparedness (EP) programs. In accordance with 10 CFR 50.54(f), addressees were requested to submit a written response to the information requests within 90 days.
Reference (1) states that if an addressee cannot meet the requested response date, the addressee must provide a response within 60 days of the date of the letter and describe the alternative course of action that it proposes to. take, including the basis of the acceptability of the proposed alternative course of action and estimated completion date. After a careful review of the requested actions and information, NextEra Energy Point Beach, LLC (NextEra) proposes to take the alternative course of action described in Enclosure 1. The basis for the proposed alternate course of action is provided in Enclosure 2.
This letter contains no new Regulatory Commitments and no revisions to existing Regulatory Commitments.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241
Document Control Desk Page 2 If you have any questions, please contact Mr. James Costedio, Licensing Manager, at 9201755-7427.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on May 10,2012.
Very truly yours, NextEra Energy Point Beach, LLC fl"*
Site Vice President Enclosures Administrator, Region I I I, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Director of Office of Nuclear Reactor Regulation, USNRC
ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 PROPOSED ALTERNATIVE COURSE OF ACTIONS FOR RESPONDING TO RECOMMENDATION 9.3 INFORMATION REQUEST Communications Page 1 of 3 Requested Information Provide an assessment of the current communications systems and equipment used during an emergency event to identify any enhancements that may be needed to ensure communications are maintained during a large scale natural event meeting the conditions described in the Reference for this enclosure's transmittal letter. The assessment should:
ldentify any planned or potential improvements to existing onsite communications systems and their required normal and/or backup power supplies, ldentify any planned or potential improvements to existing offsite communications systems and their required normal and/or backup power supplies, Provide a description of any new communications system(s) or technologies that will be deployed based upon the assumed conditions described above, and Provide a description of how the new and/or improved systems and power supplies will be able to provide for communications during a loss of all AC power.
Describe any interim actions that have been taken or are planned to be taken to enhance existing communications systems power supplies until the communications assessment and the resulting actions are complete.
Provide an implementation schedule of the time needed to conduct and implement the results of the communications assessment.
Conduct the communications assessment.
Provide an implementation schedule of the time needed to implement the results of the communications assessment.
Request 1
2 3
Estimated Completioq Date 10/31/2012 611 112012 Two dates 9/28/2012 10/31/2012
Staffing Page 2 of 3 Request 1
Estimated Completion Date Two dates 4/30/2013 Four blonths prior to the beginning of 1 R35*
Requested Information Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Reference for this enclosure's transmittal letter.
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 B-I, 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).
Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- As used within the context of NRC Order EA-12-049
Page 3 of 3 Requested Information 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.
- 1. Conduct the onsite and augmented staffing assessment:
The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]
The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]
- 2. A schedule of the time needed to implement changes will be provided as follows:
Those associated with the Phase 1 staffing assessment.
Those associated with the Phase 2 staffing assessment.
- As used within the context of NRC Order EA-12-049 Identify how the augmented staff would be notified given degraded communications capabilities.
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 widespread large scale natural event.
Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.
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 1 staffing assessment.
Those associated with the Phase 2 staffing assignment.
- As used within the context of NRC Order EA-12-049 Request 2
3 4
5 6
Estimated Completion Date Four dates 3/29/2013 Five Months prior to the beginning of 1 R35 413012013 Four Months prior to the beginning of 1 R35*
611 112012 611 112012 611 112012 Two dates 413012013 Four Months prior to the beginning of 1 R35*
ENCLOSURE 2 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 BASIS FOR PROPOSED ALTERNATIVE COURSE OF ACTION FOR RESPONDING TO EP REQUESTED INFORMATION Communications There are two separate responses to the information requests related to communications. The alternative timing of responses to Requests # I and #3 proposed in this letter reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 201 1 (76 Fed. Reg. 72,560). The proposed alternative timing is warranted as many of the licensee staff resources necessary for performing the communications assessment are the same resources involved in implementing new EP Rule requirements, responding to Institute of Nuclear Power Operations (INPO) initiatives related to enhancing communications capabilities (e.g., IER 11-4), and maintaining existing EP communications equipment.
In addition, the estimated completion date assigned to lnformation Request #3 will promote alignment between the out-year budgetinglfunding of future enhancements, and the development of an accurate and complete enhancement implementation schedule.
Staffing As presented in Enclosure I of this letter, a two-phase approach will be used to respond to the lnformation Requests associated with Staffing. The table below summarizes this approach.
The basis for this approach is discussed below.
For multi-unit plants, the Phase 1 staffing assessment will be performed by March 29, 201 3, and provided by April 30, 201 3. This assessment will consider all requested functions except those related to Fukushima Near-Term Task Force (NTTF)
Phase 2 Staffing Assessment (for functions related to NTTF Recommendation 4.2)
Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01; provide results per of this letter.
Plant Type Multi-unit plants Page 1 of 3 Phase 1 Staffing Assessment (for functions except those related to NTTF Recommendation 4.2)
Perform staffing assessment and implement actions as required by recent EP Rule using ISG and NEI 10-05.
Perform staffing assessment as requested by 50.54(f) letter using NEI 12-01 and NEI 10-05; provide results per of this letter.
Recommendation 4.2. An assessment considering these functions will be performed in Phase 2.
The timing of the Phase 1 staffing assessment reflects the higher priority placed by the staff, and approved by the Commission in SRM-SECY-12-0025, upon the completion of licensee actions necessary to comply with the Final EP Rule issued on November 23, 201 1 (76 Fed. Reg. 72,560). In particular,Section IV.A.9 of 10 CFR 50, Appendix E, requires that licensees complete 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. As stated in the EP Rule, this analysis must be completed by December 24,2012.
Following completion of EP Rule staffing analysis, the staffing assessment associated with the NRC letter will be performed. Based on staffing analysis experience to date, it is anticipated that a multi-unit staffing analysis will require approximately three months to complete and validate. One additional month is allotted for processing of an assessment submittal package.
As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 1 staffing assessment.
The Phase 2 staffing assessment will be performed five months prior to the beginning of refueling outage 1 R35, and provided four months prior to the beginning of refueling outage 1 R35. This assessment will consider the requested functions related to Fukushima NTTF Recommendation 4.2.
The industry will be responding to multiple regulatory actions resulting from the recommendations contained in the NTTF Report, as modified in related Commission Papers (SECYs) and Staff Requirements Memoranda (SRM). One of these actions, in particular, has the potential to impact emergency response staffing levels. This action is associated with Fukushima NTTF Recommendation 4.2 and subsequently issued as NRC Order to Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events EA-12-049 [the Order]. A summary of the Order is provided below.
This Order 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 core cooling, containment and spent fuel pool (SFP) cooling. The transition phase requires providing sufficient, portable, onsite 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.
Additional details on an acceptable approach for complying with this Order will be contained in final Interim Staff Guidance (ISG) scheduled to be issued by the NRC in August 2012.
In response to the Order, each licensee must develop new strategies for mitigating beyond-design-basis external events. To ensure accurate results, the staffing assessment for response functions related to NTTF Recommendation 4.2 must be Page 2 of 3
based on the actions delineated in procedures and guidelines developed in response to the Order. Once the site-specific actions associated with the new response strategies are defined (e.g., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.
Based on a review of the planned actions necessary to comply with the Order, an assessment of the staffing for the functions related to NTTF Recommendation 4.2 will be provided by four months prior to the first occurrence of a second refueling outage at the site (i.e., "the first "second refueling outage") as used within the context of NRC Order EA-12-049.
As requested, an implementation schedule for any modifications that are determined to be appropriate will be included with the Phase 2 staffing assessment.
The Phase 2 staffing assessment is one component of the overall work plan necessary to implement the requirements of the Order. NextEra Energy Point Beach, LLC (NextEra), as stated in the Order, "...shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31, 201 6, whichever comes first." "Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies."
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