Response to NRC Information Requests for NTTF Recommendation 9.3 Sue Perkins-Grew Director, Emergency Preparedness NEI

Presentation Overview 2 EP Response Overview Staffing Information Communications Information Summary of Responses

3 3 Overview of EP Response  For this presentation, refer to the: – 50.54(f) Letter and Enclosure 5 – Letter response template for Emergency Preparedness (EP) requests  Copies are available in your handouts

Overview of EP Response  Information Request Justification for EP on page 5 provides the EP-related topics – required staff to fill all necessary positions responding to a multi-unit event – ensure that the communication equipment relied upon to coordinate the event response during a prolonged SBO can be powered 4

Overview of EP Response  Some information cannot be provided within the requested 90-day period  NEI has developed a generic template for responding to the EP information requests – Send in within 60 days of Letter date May 11, 2012 – Proposes an “alternative course of action” and provides a basis 5

Overview of EP Response  Alternative course of action – Allows additional time to provide responses (assessments, schedules, etc.) Aligns EP responses with work being performed to address other regulatory actions Considers resource impacts from the recently issued EP Rule and INPO IERs 6

Presentation Overview 7 Communications Information Staffing Information Summary of Responses EP Response Overview

Requested Information for Communications During an Extended Loss of AC Power Steve Sawtschenko EP Manager Palo Verde Nuclear Generating Station

9 Communications  Requested Action – Assess current communications systems and equipment using the given assumptions – Consider enhancements to emergency plan with respect to communications requirements in light of the assumptions – Consider means necessary to power the communications equipment during a multi- unit event, with a loss of all AC power

10 Request is applicable to single unit plants Request is applicable to multi-unit plants

Communications  Assumptions – Large-scale natural event causing: A loss of all AC power Extensive damage to normal and emergency communications systems both onsite and in the area surrounding the site (e.g., AC power may not be available to cell and other communications infrastructures) 11

12 Communications  Review of responses to requested information – Will review in the order in which they are due – Refer to the Enclosure 1 of the letter response template

Communications  Requested Information #2 – Provide interim actions taken prior to completion of communications assessment – Due 90-days from Letter date [by 6/11/12]  Requested Information #3 – Conduct communications assessment Due September 28,

Communications  Requested Information #1 and #3 – Provide the communications assessment – Provide an implementation schedule – Both due October 31,

Communications  NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities  Developed by 2 industry task force teams – Staffing and Communications  Reviewed by NEI EP Working Group  Guidance aligned with standard response template 15

Communications  NEI 12-01, Section 4 provides communications assessment guidance  Defines required functions  Provides related assessment criteria – Equipment storage – Performance characteristics – Quality and maintenance requirements – Federal and vendor support considerations 16

Presentation Overview Staffing Information Summary of Responses EP Response Overview Communications Information

Requested Information for Event Response Staffing Paul Driehaus Senior EP Specialist Exelon Nuclear

19  Requested Action – Assess current staffing levels and determine the appropriate staff to fill all necessary positions for responding to a multi-unit event during a beyond design basis natural event – Determine appropriate enhancements – Single unit sites should provide the requested information as it pertains to an extended loss of all ac power, and impeded site access Event Response Staffing

20 Some requests not applicable to single unit plants All requests applicable to multi-unit plants

21 Event Response Staffing  Assumptions – Large-scale natural event resulting in: all units affected extended loss of all AC power, and impeded access to the units

Event Response Staffing  Recommendation 4.2/Order EA – Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events – Impacts staffing assessment – Site-specific response actions will not be defined by requested assessment date of 60 days after issuance of Order ISG – 2-phase approach to staffing assessment 22

23 Event Response Staffing  Phase 1 staffing assessment – Includes all requested functions except those related to NTTF Recommendation 4.2/the Order – Assume SBO affecting all units and response based on existing coping strategies – Response not required for single-unit plants; performance governed by EP Rule

24 Event Response Staffing  Phase 2 staffing assessment – Includes functions related to NTTF Recommendation 4.2/the Order – Response required from all plants (single and multi-unit)  Review of responses to requested information – Will review in the order in which they are due – Refer to the Enclosure 1 of the letter response template

Event Response Staffing  Requested Information #3, #4 and #5 – Response required from all plants – Provide information on augmented staff notifications, methods of site access and any interim actions taken prior to completion of staffing assessment – Due 90-days from Letter date [by 6/11/12] – Include in same transmittal as response to Communications Requested Information #2 25

Event Response Staffing  Requested Information #2 – Phase 1 – Performance required by multi-unit plants Single-unit plants governed by the recent EP Rule and existing license requirements – Conduct the Phase 1 staffing assessment Considers all requested functions except those related to NTTF Recommendation 4.2/the Order (i.e., FLEX strategies and actions) – Due March 29,

Event Response Staffing  Requested Information #1, #2 and #6 – Phase 1 – Performance required by multi-unit plants Single-unit plants governed by the recent EP Rule and existing license requirements – Provide phase 1 staffing assessment, implementation schedule and emergency plan changes – Due April 30,

Event Response Staffing  Requested Information #2 – Phase 2 – Performance required by all plants – Conduct the Phase 2 staffing assessment Considers functions related to NTTF Recommendation 4.2/the Order (i.e., FLEX strategies and actions) – Licensee selects a due date that supports the required submittal date [of no later than four (4) months prior to the beginning of the second refueling outage] 28

Event Response Staffing  Requested Information #1, #2 and #6 – Phase 2 – Response required from all plants – Provide phase 2 staffing assessment, implementation schedule and emergency plan changes – Due no later than four (4) months prior to the beginning of the second refueling outage 29

Event Response Staffing  NEI 12-01, Section 3 provides staffing assessment guidance  Conceptual framework  Functions requiring assessment – Unit-specific support in the key areas of accident assessment and mitigation  Staffing of positions  Staff activation and mobilization 30

31 Presentation Overview Summary of Responses Staffing Information EP Response Overview Communications Information

Summary of Responses 32 3/12/12 5/11/12 6/11/12 Letter issued Transmit 60-day response: Alternative course of action and basis Transmit 90-day response: Communications #2 and Staffing #3, 4 & 5

33 Summary of Responses 9/28/12 10/31/12 Complete the communications assessment using NEI Provide response to Communications #1 and #3

34 Summary of Responses 3/29/13 4/30/13 Complete the phase 1 staffing assessment using NEI and material from NEI Provide response to Staffing #1, #2 and #6; phase 1 for multi-unit plants

35 Summary of Responses Provide response to Staffing #1, #2 and #6; phase 2 for all plants No later than four (4) months prior to the beginning of the second refueling outage

NEI Technical Contacts  Sue Perkins-Grew – Director, EP – (202) –  David Young – Senior Project Manager, EP – (202) – 36

Questions 37