ML21049A263
| ML21049A263 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  |
| Issue date: | 02/04/2021 |
| From: | Andrew Hon NRC/NRR/DORL/LPL2-2 |
| To: | Zaremba A Duke Energy Carolinas |
| References | |
| L-2020-LLA-0198 | |
| Download: ML21049A263 (17) | |
Text
From: Hon, Andrew Sent: Thursday, February 4, 2021 10:19 AM To: Zaremba, Arthur H.; Duc, Joshua Brian Cc: Hoffman, Raymond; norris, michael; Shoop, Undine
Subject:
Request for additional information - Duke Energy Fleet License Amendment Request to Revise Emergency Plan (EPID: L-2020-LLA-0198)
By application dated September 3, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20247J468), Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (collectively referred to as Duke Energy) submitted a license amendment request for Commission review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulation. The proposed amendment would revise the emergency plans for the Catawba Nuclear Station Units 1 and 2, McGuire Nuclear Station Units 1 and 2, Oconee Nuclear Station Units 1, 2, and 3, Brunswick Steam Electric Plant Units 1 and 2, Shearon Harris Nuclear Power Plant, Unit 1, and H. B. Robinson Steam Electric Plant, Unit 2 based on the guidance in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2 (ADAMS Accession No. ML19347D139).
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The proposed questions below were discussed by telephone with your team on February 4, 2021. Your team confirmed that the request for additional information (RAI) was understood, it does not contain the proprietary information, and agreed to provide a response by March 12, 2021.
The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if you do not respond to this request by the agreed-upon date or provide an acceptable alternate date, we may deny your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If circumstances result in the need to revise the agreed upon response date, please contact me.
Andy Hon, PE Project Manager (Brunswick Nuclear Plant 1 & 2, Duke Energy Progress Fleet)
Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-8480 OWFN O8E06 Mail Stop O8B1A andrew.hon@nrc.gov REQUESTS FOR ADDITIONAL INFORMATION
RAI-1
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (BNP only) Item # 23 of Attachment 1B, Common to Site Emergency Plan Comparison Review, provides that there are several organizations not identified in the proposed BNP site-specific annex as having Letters/Memorandums of Agreement that are identified in the current plan (as listed below).
- Yaupon Beach Volunteer Fire Department
- Boiling Spring Lakes Volunteer Fire Department
- Oak Island Fire and Rescue Department
- Sunny Point Fire Department The justification for the removal is Administrative change -Reformatted information.
However, item # 44 of Attachment 1B further provides the following:
3.7.2.2 Fire Assistance Agencies with fire protection resources in the vicinity of Brunswick are as follows:
- Southport Fire Department
- Boiling Spring Lakes Volunteer Fire Department
- Yaupon Beach Volunteer Fire Department
- Oak Island Fire and Rescue Department
- Sunny Point Fire Department The Southport Fire Department is the primary fire protection response agency for the Brunswick Plant and will coordinate assistance activities, if required, of the other above agencies.
Request: Please clarify whether this information will be applicable for the proposed BNP site-specific annex and should be identified in the annex.
RAI-2
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (CNS only) Item # 13 of Attachment 2B, Common to Site Emergency Plan Comparison Review, provides that there are two organizations not identified in the proposed CNS site-specific annex as having Letters/Memorandums of Agreement that are identified in the current plan (see below).
- Center for Emergency Medicine (Rock Hill, SC)
- York County Sheriff The justification for the removal is Administrative change - Removed LOAs for government agencies that have an Emergency Plan in place.
However, item # 162 of Attachment 2B further provides the following:
Medical Support -
- Local - Center for Emergency Medicine.
(Agreement #9 App. 5)
Request: Please clarify whether the reference to the Center for Emergency Medicine will be applicable for the proposed CNS site-specific annex and should be identified in the annex. Further, please provide justification for the removal of York County Sheriff.
RAI-3
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (HNP only) Item # 16 of Attachment 3B, Common to Site Emergency Plan Comparison Review, provides that there are two organizations not identified in the proposed HNP site-specific annex as having Letters/Memorandums of Agreement that are identified in the current plan (see below).
- Town of Holly Springs Dept. Of Public Safety, Division of Municipal Fire Services
- Apex Rescue Squad The justification for the removal is Agencies within same county are being consolidated into a single county MOUs.
However, item 165 of Attachment 3B provides the following:
- 4) Medical Transportation The Apex Rescue Squad has agreed to respond to emergency calls from the plant, including transporting persons with injuries involving radioactive contamination. This service is available on a 24-hour-per-day basis. In cases not involving severe injury, one of the plant vehicles may be used to transport injured individuals. The Apex Rescue Squad is included in Annex A, Agreements.
Additionally, Section L.4 of the HNP site-specific annex provides the following:
The Wake County EMS [Emergency Medical Service] is used to provide ambulance service for individuals transported from HNP.
Request: Please clarify whether the information for the Apex Rescue Squad will be applicable for the proposed HNP site-specific annex and should be identified in the annex and whether the Wake County EMS has a Letter/Memorandum of Agreement. Also, as applicable, please provide justification for the removal of these organizations.
RAI-4
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning
Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (MNS only) Item # 15 of Attachment 4B, Common to Site Emergency Plan Comparison Review, provides that there is one organization not identified in the proposed MNS Site Specific Annex as having Letters/Memorandum of agreement that are identified in the current plan (see below).
- Cornelius Fire Department The justification for the removal is Administrative change - Removed LOAs for government agencies that have an Emergency Plan in place and organization no longer used.
Further, item # 7 of Attachment 4B provides, B.9.f Fire-Fighting
- 1. Cornelius Fire Department (Cornelius, NC)
- 2. Huntersville Fire Department (Huntersville, NC)
Request: Please clarify whether the information for the Cornelius Fire Department will be applicable for the proposed MNS site-specific annex and should be identified in the annex or provide justification for removal.
RAI-5
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (ONS only) Item # 15 of Attachment 5B, Common to Site Emergency Plan Comparison Review, provides that there are several organizations not identified in the proposed ONS site-specific annex as having Letters/Memorandums of Agreement that are identified in the current plan (see below).
- Pickens County Sheriffs Department
- Greenville Health System
- Six-Mile Volunteer Fire Department
- Keowee-Ebenezer Volunteer Fire Department
- Corinth-Shiloh Volunteer Fire Department The justification for the removal is Administrative change - Removed LOAs for government agencies that have an Emergency Plan in place.
Further, item # 7 of Attachment 5B provides the following:
FIRE FIGHTING -
Oconee County Emergency Services Fire/Chemical Spill Keowee-Ebenezer Fire Department Corinth-Shiloh Fire Department Six-Mile Fire Department Keowee Fire Department Additionally, item # 162 of Attachment 5B provides the following:
Medical Support - (Agreements located in Appendix 5)
Local - Greenville Health System Request: Please clarify whether the information for these identified organizations will be applicable for the proposed ONS site-specific annex and should be identified in the annex. Pease provide justification, if applicable, for the removal of the identified organizations.
RAI-6
Requirement:
- 10 CFR 50.47(b)(1) requires that the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones (EPZs) have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
- Associated guidance in NUREG-0654,Section II.A, Evaluation Criterion A.4 states that written agreements with the support organizations having an emergency response role within the EPZs are referenced.
Issue: (RNP only) Item # 17 of Attachment 6B, Common to Site Emergency Plan Comparison Review, provides that there are several organizations not identified in the proposed RNP site-specific annex as having Letters/Memorandums of agreement that are identified in the current plan (see below).
- Darlington County Emergency Medical Services
- Hartsville Rescue Squad
- Hartsville Fire Department
- Medshore Ambulance Service The justification for the removal is Agencies within same county are being consolidated into a single county MOUs.
Additionally, Section L.4 of the RNP site-specific annex provides the following:
The Darlington County Emergency Medical Service is used to provide ambulance service for individuals transported from RNP.
Request: Please provide justification for the removal of the identified organizations and whether the Darlington County Emergency Medical Service has a Letter/Memorandum of Agreement.
RAI-7
Requirement:
- 10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- 10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.
- Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific emergency response organization (ERO) is developed.
- NRC Document, Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization, dated August 24, 2017 (ADAMS Accession No. ML16117A427).
Issue: NUREG-0654 guidance specifies augmentation from an Alert or higher for two (2) onsite Field Monitoring Team personnel at 60 minutes, two (2) offsite Field Monitoring Team personnel at 60 minutes and two (2) offsite Field Monitoring Team personnel at 90 minutes.
Five of the Duke Energy sites currently have the capability to perform either onsite/near site surveys or offsite surveys at 45 minutes from an Alert emergency declaration. Additionally, BNP has a third Radiation Protection (RP) Personnel on-shift that the NRC staff would consider available to perform onsite/near site surveys if needed.
Duke is proposing to extend the timing to performing onsite/near site surveys or offsite surveys to 75 minutes.
Duke Power Company (DPC) previously proposed to eliminate reference to the 45-minute responders from the emergency plans for McGuire Nuclear Station Units 1 and 2, Oconee
Nuclear Station Units 1, 2, and 3, and Catawba Nuclear Station Units 1 and 2. In a letter dated November 12, 1996 (ADAMS Accession No. ML15238A321) for the CNS, MNS and ONS, the NRC staff stated:
Duke Power also proposes to relax the response time for one RP technician used for performing plume surveys inside the protected area but outside of the power block (out-of-plant onsite surveys).
The relaxation of the offsite survey response from 45 minutes to 75 minutes places greater importance on the need to perform early onsite external surveys. This proposal, therefore, is not acceptable.
The technical basis document for NUREG-0654 provides that onsite Field Monitoring Team should be staffed within 60-minutes of an Alert emergency classification level (ECL), or greater, in order to be ready to respond to a radiological release, or to detect radiation in the field thus confirming and quantifying the release. This supports the applicable protective action recommendation (PAR) decision-makers in developing effective PARs.
Request: Provide additional justification for extending the capability to perform onsite/near site surveys or offsite surveys at 60 minutes from an Alert emergency declaration. This justification should not rely on the two on-shift RP technicians who would be expected to have an increasing RP burden at 60 minutes which will be compounded by augmenting RP technicians not arriving until 75 minutes after the classification of an Alert ECL.
RAI-8
Requirement:
- 10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- 10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.
- Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific emergency response organization (ERO) is developed.
- NRC Document, Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization, dated August 24, 2017.
Issue: The site-specific Enclosures of the Duke Energy LAR provided an evaluation of proposed reduction in effectiveness 9 (RIE 9) that states in part:
For the purposes of Table B-1, RP Qualified Individuals are task qualified to fulfill the Radiation Protection functions.
RIE 9 further provided that in 2011, the NRC approved this change for Catawba, McGuire, and Oconee Nuclear Stations (CNS, MNS, and ONS). Although a similar change was approved for CNS, MNS, and ONS, the safety evaluation for that change in wording specifically provided the following:
Based on the maintenance of the level of training for the RP Qualified Personnel to the standards of training and qualifications to the RP Technicians, the NRC staff finds the change in RP staffing during emergency response events from RP Technicians to RP qualified individuals to be acceptable.
It was not clear to the NRC staff that the use of task qualified, as used in the proposed Duke Energy Common Emergency Plan, was equivalent to a level of training and qualifications of a RP technician. Considering that the eight RP personnel identified on Table B-1 of NUREG-0654 are performing RP functions which includes providing qualified radiation protection coverage for responders accessing potentially unknown radiological environments during emergency conditions, those individuals performing this function are expected to meet the standards of training and qualifications of RP Technicians.
Request: Provide additional details regarding the level of training for RP qualified individuals, such that it is clear to the NRC staff that RP qualified individuals will have the appropriate training to perform the tasks at an equivalent level of RP Technicians.
RAI-9
Requirement:
- 10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- 10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.
- Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific emergency response organization (ERO) is developed.
- NRC Document, Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization, dated August 24, 2017.
Issue: Section 3.4.1.3, Key Function: Radiation Protection, of each site-specific Enclosure of the Duke Energy LAR provided, in part:
In addition, the proposed 75-minute augmentation time for the maintenance staff described in Item 9 of this section (Repair Team function) eliminates the need for RP coverage of the repair team prior to 75 minutes.
Section 3.4.1.9, Repair Team Activities, of each site-specific Enclosure of the Duke Energy LAR provided, in part:
The Diverse and Flexible Coping Strategies (FLEX) Program provides additional equipment and guidelines that can be used by qualified on-shift personnel for mitigating emergency conditions.
Duke Energy has provided that the Duke sites have the equipment, procedures, and training to implement FLEX strategies. However, it was not clear to the NRC staff that proposed RP staffing would support the implementation of FLEX strategies until proposed RP augmentation of 75 minutes from an Alert ECL.
Request: Provide additional information that demonstrates the following:
- a. Proposed RP on-shift and augmentation staffing changes would not place an undue burden on the on-shift RP staff during the implementation of FLEX strategies until the proposed augmentation at 75 minutes from an Alert ECL.
- b. Implementation of FLEX strategies would not reasonably require the capabilities provided by the augmenting ERO, such as support to either move or install FLEX equipment that might be provided by either maintenance or other augmentation personnel.
RAI-10
Requirement:
- 10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.
- 10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.
- Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific emergency response organization (ERO) is developed.
- NRC Document, Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization, dated August 24, 2017.
Issue: Section 3.2.1.10, Key Function: Supervision of Repair Team Activities, of each site-specific Enclosure of the Duke Energy LAR provided, in part:
The current ERO structure allows for the management of craft personnel under a single supervisor hierarchy. A single maintenance supervisor can effectively manage the maintenance resources, as demonstrated by OSC [Operations Support Center]
performance under this organizational structure in numerous drills and evaluated exercises. The major tasks are aligned with those stated in NUREG-0654 Rev. 2 guidance.
Section 3.4.1.10, Supervision of Repair Team Activities, of each site-specific Enclosure of the Duke Energy LAR provided, in part:
Furthermore, although the current BNP Emergency Plan does not provide an on-shift position for the Supervision of Repair Team function, it is noted that historic drill and exercise evaluations do not indicate performance issues with regard to on-shift task overburden or overlap related to this function as a result of the currently implemented 75 minute response time.
Based on an NRC staff review of the Duke Energy LAR, it appears that the primary basis for providing a single augmenting Maintenance Supervisor and not a separate Mechanical Supervisor, an Electrical Supervisor, and an Instrument and Control (I&C) Supervisor is the current ERO structure and historic drill evaluations. Considering that both the current Duke Energy ERO staffing and historic drill and exercise evaluations are based on guidance of NUREG-0654, Revision 1 that existed prior to the development of NUREG-0654 Revision 2, it would not be reasonable to assume that observations or evaluations based on previous guidance would adequately justify the proposed difference from updated guidance provided by NUREG-0654 Revision 2.
Request: Provide additional information that addresses the following:
- a. Demonstrates that the Duke Energy ERO, as augmented, will have the capability for a Mechanical Supervisor to provide oversight of OSC activities related to mechanical equipment.
- b. Supports combining the Electrical and the I&C Supervisor functions such that the capability to provide oversight of OSC activities related to electrical and I&C equipment is maintained.
RAI-11
Requirement:
- 10 CFR 50.47(b)(12) requires that arrangements are made for medical services for contaminated injured individuals.
- 10 CFR Part 50, Appendix E.IV.E.5 requires arrangements for medical service providers qualified to handle radiological emergencies onsite.
- Associated guidance in NUREG-0654,Section II.L, Evaluation Criterion L.2 states that arrangements for the medical treatment of contaminated, injured onsite personnel are described.
Issue: (BNP only) Item # 44 of Attachment 1B, provides that the current BNP Emergency Plan has the following statement:
In addition, medical assistance is available on, or offsite from physicians in the Southport area who have agreed to provide medical assistance to contaminated patients.
However, the proposed BNP site annex does not include above statement.
The justification for the removal is Administrative change - Wording change more clearly meets element, does not change intent or level of commitment.
Request: Provide further technical justification for removal of this medical assistance from the approved emergency plan.
RAI-12
Requirement:
- 10 CFR 50.47(b)(5) requires that the means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
- 10 CFR Part 50, Appendix E.IV.D.1 requires the description shall include identification of the appropriate officials, by title and agency, of the State and local government agencies within the EPZs.
- Associated guidance in NUREG-0654,Section II.E, Evaluation Criterion E.2 states the alert and notification systems (ANSs) used to alert and notify the general public within the plume exposure pathway EPZ and methods of activation are described. This description includes the administrative and physical means, the time required for notifying and providing prompt instructions to the public within the plume exposure pathway EPZ, and the organizations or titles/positions responsible for activating the system.
Issue: Section E, Notification Methods and Procedures, of each proposed Site-Specific Annex states:
Detailed information on the FEMA approved system used to alert and notify the general public is maintained in [site specific] Alert and Notification System Design Report.
However, there are site-specific details from the existing site emergency plans that should be included in the applicable site-specific annex. For example:
The current BNP Emergency Plan states that,
- The Coast Guard will be used in notifying people along the coast and other large bodies of water where appropriate and necessary.
- Sirens will not be sited in the Sunny Point Army Terminal. Brunswick County will notify the terminal which will alert its personnel using on-site warning methods.
- Activation of the sirens will be accomplished from the Brunswick and New Hanover Counties Emergency Operation Centers. The sirens in each county are independently controlled but may be activated by Duke Energy with permission from the counties.
The HNP Emergency Plan states that,
- Patrol boats will be used in alerting people on Jordan Lake and Harris Lake in accordance the North Carolina Emergency Response Plan in support of the Shearon Harris Nuclear Power Plant Annex G. Supplemental sirens are provided for alerting boaters on Harris Lake.
- Activation of the sirens for warning of the public will be accomplished from the Wake County Emergency Operations Center or the Wake County Warning Point.
The sirens can also be activated from the Harris Nuclear Plant or the Public Safety Communications Centers of Harnett, Lee and Chatham Counties.
The RNP Emergency Plan states that,
- Aircraft and patrol boats will be used in notifying people in wooded areas and on Lake Robinson where appropriate and necessary.
- Activation of the sirens will be performed by County Emergency Management Personnel. At the request of the responsible county authorities, HBRSEP may activate any part of the siren system.
Request: Please provide additional detail in the proposed Section E of each proposed site-specific annex to address licensee requirements in Section IV.D.1 to Appendix E of 10 CFR Part 50.
RAI-13
Requirement:
- 10 CFR 50.47(b)(6) requires provisions or prompt communications among principal response organizations to emergency personnel and to the public.
- 10 CFR Part 50, Appendix E.IV.E.9.c requires provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- Associated guidance in NUREG-0654,Section II.F, Evaluation Criterion F.1 states that each principal response organization establishes redundant means of communication.
Issue: (BNP only) Item # 70 of Attachment 1B, provides that the current BNP Emergency Plan has the following statement:
The EVS [Emergency Voice System] is dedicated for Emergency Preparedness (EP) communications, and consists of phones placed in the Control Room, TSC, OSC and the Simulator. Phones on this system also include sets that are dedicated for communicating with the plant load dispatcher, and for use on the NRC Emergency Telecommunications System (ETS).
However, the proposed BNP site annex does not include above statement.
Request: Provide justification why this system is not described in the BNP site-specific Annex.
RAI-14
Requirement:
- 10 CFR 50.47(b)(6) requires provisions or prompt communications among principal response organizations to emergency personnel and to the public.
- 10 CFR Part 50, Appendix E.IV.E.9.c requires provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- Associated guidance in NUREG-0654,Section II.F, Evaluation Criterion F.1 states that each principal response organization establishes redundant means of communication.
Issue: (HNP only) Item # 61 of Attachment 3B, provides that the current HNP Emergency Plan has the following statement:
A. The Harris E&E [Energy & Environmental] Center (HE&EC) PABX [private automatic branch exchange] telephone system However, the proposed HNP site annex does not include above statement.
Request: Provide justification why this system is not described in the HNP site-specific annex as it is an offsite communication system identified in the NRC approved HNP emergency action levels (ML16057A838) for a Loss of all onsite or offsite communications capabilities.
RAI-15
Requirement:
- 10 CFR 50.47(b)(6) requires provisions or prompt communications among principal response organizations to emergency personnel and to the public.
- 10 CFR Part 50, Appendix E.IV.E.9.c requires provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations
facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- Associated guidance in NUREG-0654,Section II.F, Evaluation Criterion F.1 states that each principal response organization establishes redundant means of communication.
Issue: (ONS only) Item # 63 of Attachment 5B, provides that the current ONS Emergency Plan has the following statement:
EOF Communication System [EOF phone system]
However, the proposed ONS site annex does not include above statement.
Request: Provide justification why this system is not described in the ONS site-specific annex as it is an offsite communication system identified in NRC approved ONS emergency action levels (ML16109A093) for a Loss of all onsite or offsite communications capabilities.
RAI-16
Requirement:
- 10 CFR 50.47(b)(6) requires provisions or prompt communications among principal response organizations to emergency personnel and to the public.
- 10 CFR Part 50, Appendix E.IV.E.9.c requires provision for communications among the nuclear power reactor control room, the onsite technical support center, and the emergency operations facility; and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams.
- Associated guidance in NUREG-0654,Section II.F, Evaluation Criterion F.1 states that each principal response organization establishes redundant means of communication.
Issue: (RNP) Item # 62 of Attachment 6B, provides that the current RNP Emergency Plan has the following statement:
Corporate Telephone Communications System (VoiceNet)
However, the proposed RNP site annex does not include above statement.
Request: Provide justification why this system is not described in the RNP site-specific annex as it is an offsite communication system identified in NRC approved RNP emergency action levels (ML16061A472) for a Loss of all onsite or offsite communications capabilities.
RAI-17
Requirement:
- 10 CFR 50.47(b)(8) requires adequate emergency facilities and equipment to support the emergency response are provided and maintained.
- Associated guidance in NUREG-0654,Section II.F, Evaluation Criterion H.1 states that a Technical Support Center (TSC) is established, using current Federal guidance, from which nuclear power plant conditions are evaluated and mitigative actions are developed.
- Associated guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, provides guidance for the TSC.
Issue: (CNS, MNS, ONS and RNP) Item # 69 of Attachment 2B, item # 75 of Attachment 4B, item # 73 of B, and item #74 of attachment 6B, respectively provide:
Site specific details of the TSC are described in the site-specific annexes to the Duke Energy Common Emergency Plan.
However, the site-specific details in these site-specific annexes do not address some of the functional criteria in NUREG-0696 (i.e., size, structure, habitability, and instrumentation, data system equipment and power supplies).
Request: Provide justification for not addressing all of the functional criteria in these site-specific annexes.
Hearing Identifier: NRR_DRMA Email Number: 1020 Mail Envelope Properties (SA0PR09MB61569DAA6178BE0BEAC9142F99B39)
Subject:
Request for additional information - Duke Energy Fleet License Amendment Request to Revise Emergency Plan (EPID: L-2020-LLA-0198)
Sent Date: 2/4/2021 10:18:30 AM Received Date: 2/4/2021 10:18:30 AM From: Hon, Andrew Created By: Andrew.Hon@nrc.gov Recipients:
"Hoffman, Raymond" <Raymond.Hoffman@nrc.gov>
Tracking Status: None "norris, michael" <Michael.Norris@nrc.gov>
Tracking Status: None "Shoop, Undine" <Undine.Shoop@nrc.gov>
Tracking Status: None "Zaremba, Arthur H." <Arthur.Zaremba@duke-energy.com>
Tracking Status: None "Duc, Joshua Brian" <Joshua.Duc@duke-energy.com>
Tracking Status: None Post Office: SA0PR09MB6156.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 34012 2/4/2021 10:18:30 AM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: