ML20316A021
| ML20316A021 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 11/10/2020 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Marlone Davis NextEra Energy Duane Arnold |
| Wall S | |
| References | |
| L-2020-LLA-0113 | |
| Download: ML20316A021 (6) | |
Text
From:
Wall, Scott Sent:
Tuesday, November 10, 2020 3:14 PM To:
Davis, J.Michael Cc:
Laura Swenzinski (Laura.Swenzinski@nexteraenergy.com); Weaver, Tracy
Subject:
Final RAI - Duane Arnold - Duane Arnold Amendment for Proposed Defueled EP and EAL Scheme (EPID: L-2020-LLA-0113)
Dear Mr. Davis,
By letter dated May 15, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20136A438), NextEra Energy Duane Arnold, LLC (NEDA, the licensee) requested an amendment to the license for the Duane Arnold Energy Center (DAEC).
The proposed amendment would revise the DAEC Emergency Plan, referred to hereafter as the permanently defueled emergency plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10CFR Part 50, Appendix E, Section IV.B.2.
The NRC staff has reviewed the submittals and determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). During a telephone calls on November 10, 2020, the NEDA staff indicated that a response to the RAIs would be provided by December 11, 2020.
If you have questions, please contact me at 301-415-2855 or via e-mail at Scott.Wall@nrc.gov.
Scott P. Wall, LSS BB, BSP Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov Docket No. 50-331
Enclosure:
Request for Additional Information cc: Listserv RAI-NSIR REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST
PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331 INTRODUCTION By letter dated May 15, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML20136A438), NextEra Energy Duane Arnold, LLC (NEDA, the licensee) requested an amendment to the license for the Duane Arnold Energy Center (DAEC).
The proposed amendment would revise the DAEC Emergency Plan, referred to hereafter as the permanently defueled emergency plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10CFR Part 50, Appendix E, Section IV.B.2.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the application and has determined that the following additional information is required in order to complete the review.
Applicable Regulation and Guidance The NRC staff has reviewed the license amendment request, using the guidance contained in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980) (NUREG-0654), as applicable to support an emergency plan for a permanently shut down and defueled power reactor facility with spent fuel stored in a spent fuel pool or an independent spent fuel storage installation.
RAI-NSIR-01 Section E, Notification Methods and Procedures, Sub-Section 1.1.2, State and Local Government Notification, of the proposed PDEP states, in part:
Notification to the responsible State and County authorities is required within 60 minutes of the emergency classification.
Although there is a letter of acknowledgement provided in the application, there is no documentation that this specific change for notification timing has been discussed with the offsite response organizations (OROs).
Please clarify that this specific change has been discussed with the OROs.
RAI-NSIR-02 The guidance in Section E.4 of NUREG-0654, as applicable for a shutdown facility, states, in part:
The licensee, in coordination with State and local organizations, shall establish the contents of the emergency messages to be sent from the nuclear facility.
These messages shall contain the following information if it is known and appropriate:
- a. location of incident and name and telephone number (or communications channel identification) of caller;
- b. date/time of incident;
- c. class of emergency;
- k. licensee emergency response actions underway;
- m. request for any needed onsite support by offsite organizations; and
- n. prognosis for worsening or termination of event based on plant information.
However, Section E, Sub-Section 1.1.2, of the proposed PDEP states, in part:
DAEC, in coordination with the State of Iowa and Linn County, have established the contents of the initial emergency messages to be sent from DAEC in the event an emergency is declared. These messages contain such information as the class of emergency and whether a release is taking place.
Follow-up emergency messages incorporate elements as determined necessary by the State of Iowa.
Although there is a letter of acknowledgement provided in the application, there is no documentation that the content of the initial and follow-up messages have been specifically discussed with the OROs.
Please clarify that this specific change has been discussed with the OROs and provide where the content of these messages is documented.
RAI-NSIR-03 The guidance in Section F.2 of NUREG-0654, as applicable for a shutdown facility, states, in part:
Each licensee shall ensure that a coordinated communication link for medical support exists.
The NRC staff reviewed a revision of the DAEC Emergency Plan (ADAMS Accession No. ML042360073). Section F, Emergency Communications, Section 2.7, Medical Communications, which states:
Communications with the primary and secondary medical facilities will be accomplished through the use of commercial telephone system.
Communications with the ambulance will be accomplished through the use of the Linn County fire frequency radio network.
However, this information is not included in the proposed PDEP.
Please clarify that a coordinated communication link for medical support exists.
RAI-NSIR-04 Section K, Radiological Exposure Control, Sub-Section 1.2, Exposure Control, in the proposed PDEP states, in part:
Table K-1 [Emergency Exposure Criteria] contains the guidelines for emergency exposure criteria, which is consistent with the, Response Worker Guidelines, provided in the EPA [U.S. Environmental Protection Agency] PAG [Protective Action Guides] Manual.
The information in this section appears to be referencing an older vision of the EPA PAG Manual.
Please explain why the current version of the EPA PAG Manual is not referenced or revise accordingly.
RAI-NSIR-05 The guidance in Section H.10.b of NUREG-0654, as applicable for a shutdown facility, states, in part:
Communication systems shall be functionally tested as follows: State/local and NRC (ENS) communication systems shall be tested monthly.
This is not the same as a communication drill as stated in N.2.
The guidance in Section N.2 of NUREG-0654, as applicable for a shutdown facility, states, in part, Communication Drills: Communications with State and local governments shall be drilled annually. Communications with the NRC shall be drilled annually.
Communication drills shall also include the aspect of understanding the content of messages.
However, Section N, Exercises and Drills, Section 1.2.6, Communications Tests, of the proposed PDEP states, in part:
The following communication systems, as detailed in Section F.1.2. are used on a frequent basis. Therefore, periodic testing of these systems is not necessary:
- i. DAEC Paging System ii. Commercial Telephone System iii. Portable Radios The purpose of these communications drills is not only to verify that the communications equipment is operable, but it is also to verify the phone numbers, appropriateness of the recipient, content of messages, etc.
Please clarify and/or correct the PDEP to include the communication drills with State and local governments and the NRC, as identified in the NRC guidance, or provide additional justification for omission.
Hearing Identifier:
NRR_DRMA Email Number:
883 Mail Envelope Properties (MN2PR09MB5019A35B55A1B652524247E792E90)
Subject:
Final RAI - Duane Arnold - Duane Arnold Amendment for Proposed Defueled EP and EAL Scheme (EPID: L-2020-LLA-0113)
Sent Date:
11/10/2020 3:14:16 PM Received Date:
11/10/2020 3:14:17 PM From:
Wall, Scott Created By:
Scott.Wall@nrc.gov Recipients:
"Laura Swenzinski (Laura.Swenzinski@nexteraenergy.com)" <Laura.Swenzinski@nexteraenergy.com>
Tracking Status: None "Weaver, Tracy" <Tracy.Weaver@nexteraenergy.com>
Tracking Status: None "Davis, J.Michael" <J.Michael.Davis@nexteraenergy.com>
Tracking Status: None Post Office:
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