ML20153A785
| ML20153A785 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 06/01/2020 |
| From: | Holtec |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML20153A783 | List: |
| References | |
| 5025054 | |
| Download: ML20153A785 (4) | |
Text
Attachment 1 to Holtec Letter 5025054 Holtec Responses to NRC Clarification Questions on Emergency Plan RAI EP-3-S: Justify the inclusion of additional Emergency Action Levels (EALs) into the ISFSI EAL scheme for the HI-STORE CISF Emergency Response Plan (ERP)
In its response to RAI EP-3, the applicant revised Table 3.1.B of the ERP, CIS Facility Malfunction Initiating Condition Matrix, to accommodate the conditions/requirements listed in the Nuclear Energy Institute (NEI) document, NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 21, 2013 (ADAMS Accession No. ML13091A209).
Although Table 3.1B, and Appendix C, Facility Emergency Action Levels, have been revised to incorporate the guidance of NEI 99-01, Revision 6, some of the emergency action levels (EALs) added to the table are more applicable to a non-passive light water reactor and are not consistent with the guidance for an ISFSI.
The guidance in Section 8 of NEI 99-01-, Revision 6, states, in part:
E-HU1, Damage to a loaded cask CONFINEMENT BOUNDARY, covers the spectrum of credible natural and man-made events included within the scope of an ISFSI design.
Table 3.1B of the ERP includes a proposed E-HU1 EAL, similar to that provided in Section 8 of NEI 99-01, Rev. 6. In addition, the Basis discussion for E-HU1 in Section 8 of NEI 99-01 provides for the inclusion of security-related events for ISFSIs, which the applicant included in Table 3.1B of the ERP as proposed H-HU1 and H-HA1. However, the following EALs proposed in Table 3.1B are not described in Section 8 of NEI 99-01, Revision 6:
H-HU2 - Seismic event greater than OBE [operating basis earthquake],
H-HU3 - Hazardous event, H-HU4 - Fire potentially degrading the level of safety of the facility, and H-HA6 - Primary Alarm Station evacuation resulting in transfer of plant control to alternate locations.
This information is necessary to determine compliance with 10 CFR 72.32(a)(3).
Holtec Response:
Initiating Conditions/Emergency Action Levels H-HU2, H-HU3, H-HU4, and H-HU6 have been removed from Table 3.1B and Appendix C. As mentioned, E-HU1 covers the spectrum of credible natural and man-made events considered in the HI-STORE FSAR. IC/EALs H-HU1 and H-HA1 are included to cover Security related events for HI-STORE per chapter 8 of NEI 99-01 R6.
Additionally, ICs/EALs H-HU7 and H-HA7 are included to allow the Emergency Coordinator to declare an Unusual Event or Alert for site conditions that do not fit the other ICs/EALs, but in their judgement, warrant such declaration.
Attachment 1 to Holtec Letter 5025054 Holtec Responses to NRC Clarification Questions on Emergency Plan RAI EP-5-S: Provide justification why the duties of the Site Emergency Director (SED),
identified in Section 4.3.3 of the ERP, do not include the notification to the offsite response organizations and the NRC for the declaration of an Unusual Event classification.
In its response to RAI EP-5, the applicant updated Section 4.2.1 of the ERP to remove the list of duties, and to include a statement referencing Section 4.3.3 [Site Emergency Director (SED)] for the list of duties for the Site Emergency Director. This list of duties was revised to include decision to declare an Unusual Event and decision to escalate to an Alert. Specifically, Section 4.3.3 states, in part:
These duties include:
- Decision to declare an Unusual Event
- Decision to escalate to an Alert.
- Activation of onsite emergency response organization.
- Prompt notification of offsite response authorities to inform them that an Alert has been declared (normally within 15 minutes of declaring an Alert).
- Notification to the NRC Operations Center at 301-816-5100 immediately after notification of offsite authorities, and in any case within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the declaration of an Alert.
Although the regulations only require the Alert classification, the proposed ERP proposes a classification for an Unusual Event. However, the SED duties do not include a notification to the offsite response organizations and the NRC for the declaration of an Unusual Event classification.
This information is necessary to determine compliance with 10 CFR 72.32(a)(3).
Holtec Response:
Section 4.3.3 has been revised to include notification to offsite response authorities and the NRC upon declaration of an Unusual Event or Alert.
Attachment 1 to Holtec Letter 5025054 Holtec Responses to NRC Clarification Questions on Emergency Plan RAI EP-24-S: Supplement the Appendix D of the proposed ERP to address the following observations:
- 1. There are no agreements in Appendix D, or a commitment to establish such agreements, for the Maljamar, New Mexico; Monument, New Mexico, and Eunice City Fire Departments.
- 2. While there is an agreement with the Eddy County Fire Service, this agency is not identified as a responder in the ERP.
- 3. While there is an agreement in Appendix D for Lea Regional Medical Center, there are no agreements, or a commitment to establish such agreements, for the Carlsbad Medical Center or Permian Regional Medical Center.
- 4. There is no agreement in Appendix D, or a commitment to establish such agreement, for the City of Hobbs Ambulance Service.
- 5. There are no agreements, or a commitment to establish such agreements, in Appendix D for the Eddy County Sheriffs Department, nor the New Mexico State Police.
In its response to RAI EP-24, the applicant included appropriate MOUs [memoranda of understanding] as an appendix to the Emergency Response Plan. However, in several sections of the proposed ERP, the applicant identifies several additional organizations with emergency response responsibilities for which an MOU, or a commitment to establish such agreement, has not been provided. The specific organizations and ERP sections referenced are discussed below:
Section 4.3.11, Local Off-site Assistance, states the following:
The Maljamar Fire Department in Maljamar, New Mexico is located approximately 28 miles from the site. The Monument, New Mexico and the Eunice, New Mexico Fire Departments are located 36 miles and 38 miles respectively from the CIS Facility. Each of these departments are equipped to respond to structural fires, oil well fires, and chemical tank explosions.
Section 5.3.1 Mitigation of Fires, states, The Eunice Fire Department may also respond and is also known for fighting large fires and has worked with other firefighting teams in the field. Radiological response training will be offered to the Maljamar, New Mexico, Monument, New Mexico, and Eunice City Fire Department as a precaution.
Section 4.3.11 further provides the following:
Carlsbad Medical Center, located in Carlsbad, New Mexico is the first choice for incidents involving radiologically contaminated individuals; unless life threatening injuries are present. Life threatening injuries would be treated at Lea Regional Medical Center or Permian Regional Medical Center.
Section 4.3.11 further provides the following:
The City of Hobbs, New Mexico has ambulance service available for the CIS Facility.
Ambulance services are capable of handling incidents involving radiologically contaminated individuals.
Section 5.3.1, further states in part,
Attachment 1 to Holtec Letter 5025054 Holtec Responses to NRC Clarification Questions on Emergency Plan
[]the Lea and Eddy County Sheriffs Departments and/or the New Mexico State Police are responsible for directing traffic and limiting access of the general public to the affected area.
This information is necessary to determine compliance with 10 CFR 72.32(a)(15).
Holtec Response:
- 1. Maljamar, Monument, and Eunice Fire departments are under the jurisdiction of Lea County Emergency Management and would be dispatched under their authority. The MOU with Lea County Emergency Management covers these responding organizations.
A statement has been added to section 4.3.11 noting this.
- 2. Eddy County Fire is not expected to be a responding organization, the MOUs have been removed from the Emergency Plan.
- 3. Carlsbad Medical Center and Permian Regional Medical Center have been removed as responding organizations from the Emergency Plan.
- 4. City of Hobbs ambulance is covered under the City of Hobbs MOU and is explicitly stated within the MOU. Additionally, the Lea County Emergency Management MOU provides for EMS services.
- 5. Eddy County Sheriffs office has been removed from the emergency plan. New Mexico State Police will be notified in the event of an emergency. However, Lea County Sheriff is the designated response organization.