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EPID:L-2021-LLA-0047, Nuclear Generating Plant - Correction to Safety Evaluation Related to the Issuance of Amendment No. 259 Approving the Independent Spent Fuel Storage Installation Only Emergency Plan (License No. DPR-72, Docket Nos. 50-302 & 72-1035) (Approved, Closed) |
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Category:Letter
MONTHYEARML23342A0942024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML23354A0632023-12-22022 December 2023 Cover Letter - Crystal River License Termination Plan Request for Additional Information ML23345A1882023-12-0606 December 2023 Fws to NRC Crystal River Species List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected by Your Proposed Project ML23320A2592023-11-17017 November 2023 STC-23 077 Notification of the Crystal River Unit 3 Generating Plant License Termination Plan Public Meeting and Federal Register Notice ML23313A1322023-11-15015 November 2023 Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant ML23310A0712023-11-0707 November 2023 Audit Plan Cover Letter - Crystal River Unit 3 Nuclear Generating Plant LTP ML23187A1112023-07-25025 July 2023 Acceptance of Requested Licensing Action License Request to Add License Condition to Include License Termination Plan Requirements ML23107A2722023-06-13013 June 2023 Letter Transmitting NRC Survey Results for East Settling Pond ML23160A2962023-06-0909 June 2023 Response to Crystal River, Unit 3 Supplemental Information Needed for Acceptance on the Application for a License Amendment Regarding Approval of the License Termination Plan ML23107A2732023-06-0707 June 2023 Orise Independent Survey Report Dcn 5366-SR-01-0 IR 05000302/20220032023-05-25025 May 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2022003 ML23103A1902023-04-19019 April 2023 Request for Supplemental Information Cover Letter ML23058A2532023-03-22022 March 2023 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River, Unit 3 - NRC Inspection Report No. 05000302/2022003 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML22265A0192022-09-26026 September 2022 Nuclear Generating Plant - U.S. Nuclear Regulatory Commission'S Analysis of ADP CR3, Llc'S Decommissioning Funding Status Report (License No. DPR-72, Docket Nos. 50-302 and 72-1035) IR 05000302/20220022022-08-0909 August 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022002 IR 05000302/20220012022-05-0303 May 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report 05000302/2022001 ML22116A1752022-04-27027 April 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3- Independent Spent Fuel Storage Installation Security Inspection Report 07201035/2022401 ML22105A3992022-04-18018 April 2022 Nuclear Generating Plant - Change in NRC Project Manager ML22011A1362022-01-31031 January 2022 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20210042022-01-24024 January 2022 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report No. 05000302/2021004 ML22024A2142022-01-24024 January 2022 Nuclear Generating Plant - NMFS NRC Letter - Crystal River Energy Complex Biological Opinion Status (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21351A0052021-12-20020 December 2021 NRC Analysis of ADP CR3, LLC Decommissioning Funding Status Report for the Crystal River Unit 3 Nuclear Generating Plant (License No. DPR-72, Docket Nos. 50-302 and 72-1035) ML21322A2702021-11-24024 November 2021 Nuclear Generating Plant - Issuance of Amendment No. 260 Approving the Independent Spent Fuel Storage Installation Only Security Plan, Rev 3 IR 05000302/20210032021-11-0909 November 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021003 and 07201035/2021001 ML21288A4292021-10-18018 October 2021 Letter - Crystal River Unit 3 Nuclear Generating Plant - Correction to Safety Evaluation Related to the Issuance of Amendment No. 259 Approving the Independent Spent Fuel Storage Installation Only Emergency Plan ML21238A0952021-10-13013 October 2021 Issuance of Amendment No. 259 Approving the ISFSI-Only Emergency Plan, Revision Draft a IR 05000302/20210012021-08-12012 August 2021 Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3 - NRC Inspection Report Nos. 05000302/2021001 and 05000302/2021002 ML21182A1032021-07-0606 July 2021 Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan ML21159A0422021-06-28028 June 2021 VY and CR Indirect License Transfer Package ML21060B4142021-04-12012 April 2021 U.S. Nuclear Regulatory Commission Analysis of Duke Energy Florida, Llc'S Initial Decommissioning Funding Plan for the Crystal River Independent Spent Fuel Storage Installation ML21028A5912021-03-0202 March 2021 Letter to Reid Forwarding Exemption from 10 CFR Part 20, Appendix G, Section Iii.E ML21055A7832021-02-25025 February 2021 Letter to Reid, Change in NRC Staff Project Management for Crystal River Unit 3 Nuclear Generating Plant ML21012A3142021-01-13013 January 2021 Independent Spent Fuel Storage Installation Security Inspection Plan IR 05000302/20200012020-11-19019 November 2020 NRC Inspection Report No. 05000302/2020001, Accelerated Decommissioning Partners (ADP) CR3, LLC, Crystal River Unit 3, Crystal River, Florida ML20269A2922020-10-0707 October 2020 NRC Form 311 QA Program Approval Revision 10 Related to Crystal River 3 ML20101G5822020-04-10010 April 2020 CR-3 License Transfer SE Corrected Cover Letter ML20069A0232020-04-0101 April 2020 Order Approving Transfer of Licensed Authority from Duke Energy Florida, LLC, to ADP CR3, LLC, and Draft Conforming Administrative License Amendment ML20050D0142020-02-19019 February 2020 NRC Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2020001, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML20050F7702020-02-14014 February 2020 30-Day Notice of Payment from the City of Tallahassee Trust Fund Non-Qualified Nuclear Decommissioning Trust Fund for Crystal River Unit 3 ML20015A5672020-01-15015 January 2020 Independent Spent Fuel Storage Installation Security Inspection Plan ML20009D0432020-01-10010 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Corrected Safety Evaluation for Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19339G5092020-01-0202 January 2020 Letter to Hobbs, Crystal River Unit 3 Nuclear Generating Plant - Approval of Partial Site Release for Facility Operating License No. DPR-72 ML19343A8252019-12-0606 December 2019 Letter from Erika Bailey, Oak Ridge Institute for Science and Education, to John Hickman, NRC, Forwarding Independent Confirmatory Survey Summary and Results for the 3,854-Acre Area Partial Site Release at the Crystal River Energy Complex IR 05000302/20190022019-11-20020 November 2019 NRC Inspection Report No. 05000302/2019002 and Independent Spent Fuel Storage Installation Inspection Report No. 07201035/2019002, Duke Energy Florida, LLC, Crystal River Unit 3, Crystal River, Florida ML19317D0932019-10-25025 October 2019 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance - Engine Systems, Inc. Report No. 10 CFR21-0127, Rev. 0, Emd Fuel Injectors - Seized Plunger and Bushing ML19261A0702019-09-19019 September 2019 VEGP U3 Proficiency Watches Prior to Fuel Load ML19177A0802019-06-26026 June 2019 Nuclear Generating Plant (CR-3) - Notification of Revised Post-Shutdown Decommissioning Activities Report (Revised PSDAR) ML19170A1942019-06-14014 June 2019 Application for Order Consenting to Direct Transfer of Control of Licenses and Approving Conforming License Amendment ML19129A1402019-05-15015 May 2019 Letter to Hobbs, Correction to Amendment No. 257 Approving Independent Spent Fuel Storage Installation (ISFSI)-Only Emergency Plan, Revision 1 2024-01-09
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23354A0632023-12-22022 December 2023 Cover Letter - Crystal River License Termination Plan Request for Additional Information ML23354A0642023-12-22022 December 2023 Enclosure - Crystal River License Termination Plan Request for Additional Information ML23313A1322023-11-15015 November 2023 Request for Additional Information for the Environmental Assessment of the License Termination Plan for Crystal River Unit 3 Nuclear Generating Plant ML23103A1922023-04-19019 April 2023 Request for Supplemental Information Enclosure ML21182A1032021-07-0606 July 2021 Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan ML16032A1772016-02-0404 February 2016 J. Hickman, NRC, Letter to T. Hobbs, Crystal River 3, Request for Additional Information for Emergency Plan Change ML15026A4162015-02-0202 February 2015 Request for Additional Information Regarding the 10 CFR 50.54(p) Changes to the Security Plans ML14274A1392015-01-0808 January 2015 Request for Additional Information, License Amendment Request to Revise Technical Specifications and License Conditions to Create Permanently Defueled Technical Specifications ML14133A5032014-05-14014 May 2014 Correction, Request for Additional Information on the Post Shutdown Decommissioning Activities Report ML14104A0392014-04-28028 April 2014 Request for Additional Information on the Post Shutdown Decommissioning Activities Report ML13175A2152013-06-28028 June 2013 Request for Additional Information Regarding Request to Rescind Fukushima-Related Orders ML13018A3072013-02-0101 February 2013 Request for Additional Information for Extended Power Uprate License Amendment Request ML12355A6592012-12-21021 December 2012 Nuclear Generating Plant - RAI 9.3 of the Near-Term Task Force Fukushima Dai-ichi.. ML12333A0892012-12-19019 December 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12310A2912012-11-15015 November 2012 Request for Additional Information for Changes to Security Plan ML12240A0152012-08-28028 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12219A1912012-08-16016 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12213A3032012-08-0303 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request (Srxb) ML12202A0602012-08-0202 August 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12125A1622012-08-0101 August 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML12194A4172012-07-17017 July 2012 Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML12174A2922012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12171A3472012-07-0505 July 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12102A0442012-05-0404 May 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12052A1302012-03-0202 March 2012 Request for Additional Information for Extended Power Uprate License Amendment Request ML12003A2172012-02-0808 February 2012 Nuclear Generating Plant - Request for Additional Information for Extended Power Uprate License Amendment Request ML11326A2312011-12-0707 December 2011 Request for Additional Information for Extended Power Uprate License Amendment Request ML11308A6592011-11-17017 November 2011 Generating Plant - Request for Additional Information Regarding 60-Day Response to Bulletin 2011-01, Mitigating Strategies ML11301A1142011-11-0808 November 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1128602942011-10-12012 October 2011 IR 05000302-11-005; 11/14-18/2011; Crystal River Unit 3, Notification of Inspection and Request for Information ML11175A1512011-06-30030 June 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML11137A1742011-06-22022 June 2011 Nuclear Generating Plant; H. B. Robinson Steam Electric Plant, 2; and Shearon Harris Nuclear Power Plant, Unit 1 Request for Additional Information Regarding 2011 Decommissioning Funds ML1115403412011-06-0202 June 2011 Nuclear Generating Plant - Notification of Inspection and Request for Information 05000302/2011501 ML11122A0002011-05-26026 May 2011 Request for Additional Information for the Review of the Crystal River, Unit 3, License Renewal Application ML1112501592011-05-0505 May 2011 Notice of Inspection and Request for Information 05000302/2011003 ML1108202262011-03-31031 March 2011 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1031402722010-11-16016 November 2010 Request for Additional Information for the Review of the Crystal Review Unit 3 Nuclear Generating Plant, License Renewal Application ML1029503292010-11-0808 November 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant License Renewal Application ML1030202942010-10-28028 October 2010 Nuclear Generating Plant - Notification of Inspection and Request for Information IR 05000302-10-005 ML1027100652010-10-19019 October 2010 09/27/10 Summary of Telephone Conference Call Held Between NRC and Florida Power Corp., Concerning Draft Request for Information Related to Crystal River, Unit 3, License Renewal Application ML1026002432010-10-14014 October 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1022800102010-08-11011 August 2010 Nuclear Generating Plant - Draft RAIs Regarding Crystal River Unit 3 Part 26 Exemption Request ML1017404972010-07-0808 July 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1015303972010-07-0808 July 2010 RAI for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application ML1014105122010-06-0202 June 2010 Request for Additional Information for the Review of the Crystal River Unit 3 Nuclear Generating Plant, License Renewal Application 2023-04-19
[Table view] |
Text
July 6, 2021 Mr. Billy Reid Site Vice President ADP CR3, LLC 2760 South Falkenburg Road Riverview, FL 33578
SUBJECT:
CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT- REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT TO UPDATE THE EMERGENCY PLAN FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION (EPID L-2021-LLA-0047)
Dear Mr. Reid:
By application dated March 17, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21085A750), ADP CR3, LLC (ADP CR3; the licensee) requested approval by the U.S. Nuclear Regulatory Commission (NRC) for proposed changes to the Crystal River Unit 3 Nuclear Generating Plant (CR-3) Independent Spent Fuel Storage Installation Emergency Plan (IOEP). The proposed changes would revise the emergency action levels, revise the emergency response organization, incorporate the Emergency Action Level Bases Manual into the IOEP, and remove items unnecessarily carried over from the Permanently Defueled Emergency Plan and previous emergency plans.
In order to complete its review, the NRC staff requests additional information as specified in the Enclosure to this letter. The requested information was discussed with ADP CR3 during a teleconference with the NRC staff on June 30, 2021. In order to continue the review of the CR-3 IOEP, please respond to this request for additional information within 45 days.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
B. Reid If you have any questions regarding this request or the ongoing license amendment review, please contact me at (301) 415-3178 or via e-mail at marlayna.doell@nrc.gov.
Sincerely, Signed by Doell, Marlayna on 07/06/21 Marlayna V. Doell, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-302 and 72-1035
Enclosure:
Request for Additional Information cc: Crystal River Listserv
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO INCORPORATE PROPOSED CHANGES TO THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION EMERGENCY PLAN ADP CR-3, LLC CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT DOCKET NOS. 50-302 AND 72-1035 By application dated March 17, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21085A750), ADP CR3, LLC (ADP CR3; the licensee) requested approval by the U.S. Nuclear Regulatory Commission (NRC) for proposed changes to the Crystal River Unit 3 Nuclear Generating Plant (CR-3) Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan (IOEP). The proposed changes would revise the emergency action levels, revise the emergency response organization (ERO), incorporate the Emergency Action Level Bases Manual into the IOEP, and remove items unnecessarily carried over from the Permanently Defueled Emergency Plan (PDEP) and previous emergency plans.
The following information is needed to complete the NRC staffs technical review. Specifically, the following requests for additional information (RAIs) will facilitate the technical review being conducted by the Reactor Licensing Branch staff in the Division of Preparedness and Response in the NRCs Office of Nuclear Security and Incident Response.
RAI-1
Requirement:
Paragraph 50.47(b)(4) of Title 10 of the Code of Federal Regulations (10 CFR), as exempted, requires, in part, that a standard emergency classification and action level scheme, the basis of which includes facility system and effluent parameters, be in use by the nuclear facility licensee.
10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires, in part, the emergency action levels (EALs) that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, as well as the EALs that are to be used for determining when and what type of protective measures should be considered within the site boundary to protect health and safety.
Issue: Section 4.1, Revision of the Emergency Action Levels, of Enclosure 1, Discussion of Change, Technical Analysis, Significant Hazards Determination, and Environmental Enclosure
Considerations, of ADP CR3s March 17, 2021, application states:
The ICs [initiating conditions] associated with the Unusual Event Classification are being deleted from the EALs above because they are primarily associated with a decommissioning nuclear power plant site with spent fuel stored in the spent fuel pool (SFP) and are not applicable to an ISFSI facility, which, according to regulatory guidance, should be addressed with only an Alert emergency classification.
Section 4.1 further, states, in part:
Specifically, Nuclear Energy Institute (NEI) 99-01[, Development of Emergency Action Levels for Non-Passive Reactors,] supports this approach in Section 1.3 ISFSI, which states:
Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR § 72.32 emergency plan are generally consistent with those for a Notification of Unusual Event in a 10 CFR § 50.47 emergency plan (e.g., to provide assistance if requested).
However, the application does not provide a technical justification as to why CR-3 is not able to implement the currently approved EAL scheme that was developed in accordance with endorsed industry guidance and previously approved by the NRC in a letter dated March 22, 2017 (ADAMS Accession No. ML17048A473).
Request: Please provide a technical justification as to why CR-3 is not able to implement the currently approved EAL scheme that was developed in accordance with endorsed industry guidance and previously approved by the NRC, and/or explain how the proposed alternative continues to meet the regulatory requirements related to emergency preparedness.
RAI-2
Requirement:
10 CFR 50.47(b)(4), as exempted, requires, in part, that a standard emergency classification and action level scheme, the basis of which includes facility system and effluent parameters, be in use by the nuclear facility licensee.
10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires, in part, the EALs that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, as well as the EALs that are to be used for determining when and what type of protective measures should be considered within the site boundary to protect health and safety.
Issue: Table 1, Emergency Plan Initiation Conditions Being Deleted or Revised, in Section 4.1 of Enclosure 1 to ADP CR3s March 17, 2021, application removes the following EAL:
PD-HA1: HOSTILE ACTION is occurring or has occurred However, the application does not provide a technical justification for the removal of this EAL and is not consistent with the current CR-3 EAL scheme, which was developed in accordance with NRC-endorsed industry EAL guidance and the NEI document NEI 03-12, Template for the
Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
Request: Please provide a technical justification for the removal of this EAL, as it is currently in accordance with endorsed industry guidance, and was previously approved by the NRC.
RAI-3
Requirement:
10 CFR Part 50, Appendix E.IV.B.1, as exempted, requires that EALs shall be reviewed with the State and local governmental authorities on an annual basis.
Issue: Section 7.2, Emergency Action Levels and Postulated Accidents, of the proposed CR-3 IOEP states:
EALs shall be reviewed with State of Florida government authorities on an ANNUAL basis.
Further, Table 2, Change Summary Table, of Enclosure 1 to ADP CR3s March 17, 2021, application states:
Change Revised reference location for the EAL Technical Bases and deleted reference to Citrus County.
Reason Citrus County no longer reviews EALs. Citrus County Emergency Management is no longer involved in emergency response at CR3.
Request: Please provide a justification that describes how this proposed removal of the Citrus County review of EALs will continue to meet the regulatory requirement.
RAI-4
Requirement:
10 CFR Part 50, Appendix E.IV.D.1, as exempted, requires that the administrative and physical means for notifying local, State, and Federal officials and agencies be described. This description shall include identification of the State and local governmental agencies.
10 CFR Part 50, Appendix E.IV.E.9.a, as exempted, requires provisions for communication with contiguous State/local governments.
Issue: Section 8.2.4, Florida State Watch Office, of the proposed CR-3 IOEP states:
The Florida State Watch Office (SWO) will be notified of an emergency via commercial telephone line.
Further, Table 2 of Enclosure 1 to ADP CR3s March 17, 2021, application states:
Change Revised text for Florida State Watch Office related to SHRD [State Hot Ring Down] and deleted notification to county.
Reason SHRD is no longer required and county notification of an emergency declaration may be performed at the discretion of the State, by the State.
However, in a previous response to an NRC staff RAI (ADAMS Accession No. ML14154A408),
Duke Energy Florida, Inc. (DEF) stated:
The State Watch Office Tallahassee (SWOT) will assume the responsibility to provide notification to the Citrus County Emergency Management (acknowledged by agreements between DEF and Citrus County and also the State of Florida).
Further, the information in Section 9.2.4, Florida State Watch Office, of the current CR-3 IOEP (ADAMS Accession No. ML20203M142) states, in part:
The SWO will notify the Florida DEM [Division of Emergency Management] and Citrus County officials of an emergency at the CR-3 ISFSI.
Request: Please provide a justification that describes how this proposed change to remove the notification to Citrus County will continue to meet the regulatory requirement.
RAI-5
Requirement:
10 CFR 50.47(b)(7), as exempted, requires that the principal points of contact with the news media for dissemination of information during an emergency be established in advance, and that procedures for coordinated dissemination of information to the public be established.
Associated guidance in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,Section II.G, Evaluation Criterion G.3.a, states that each licensee shall designate a point of contact for use by news media during an emergency.
Associated guidance in NUREG-0654,Section II.G, Evaluation Criterion G.4.a, states that each licensee shall designate a spokesperson who should have access to all necessary information.
Associated guidance in NUREG-0654,Section II.G, Evaluation Criterion G.4.b, states that each licensee shall establish arrangements for timely exchange of information among designated spokespersons.
Associated guidance in NUREG-0654,Section II.G, Evaluation Criterion G.4.c, states that each licensee shall establish coordinated arrangements for dealing with rumors.
Issue: Section 10.0, Public Information, of the proposed CR-3 IOEP states:
The ISFSI Manager will coordinate with personnel for the dissemination of information to the media.
Further, Table 2 of Enclosure 1 to ADP CR3s March 17, 2021, application states:
Change Revised Public Information Section Reason Addressed current PI [public information] protocol for new company. The ISFSI Manager is responsible for coordinating public information activities.
However, the information in Section 11.0, Public Information, of the current CR-3 IOEP states:
The Corporate Communications may establish a near-site response team for the CR-3 ISFSI.
The near-site response team will be staffed with a company spokesperson and media communicators, who will provide local interaction with the media. If an event occurs at the CR-3 ISFSI, information will be disseminated to the public in a timely manner.
Briefings with media organizations will be coordinated between Corporate Communications and the near-site response team per Corporate Communications protocols.
Request: Please provide a justification of how this proposed change meets the regulatory requirement and the guidance in NUREG-0654 Evaluation Criteria listed above.
RAI-6
Requirement:
10 CFR 50.47(b)(2) requires that (1) the on-shift facility licensee responsibilities for emergency response are unambiguously defined, (2) adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, (3) timely augmentation of response capabilities is available, and (4) the interfaces among various onsite response activities and offsite support and response activities are specified.
Issue: Section 4.2, Emergency Response Organization Revision - Deletion of the Resource Manager ERO position, of Enclosure 1 to ADP CR3s March 17, 2021, application states:
In accordance with the IOEP, the Resource Manager was notified by the EC
[Emergency Coordinator] within two (2) hours of classification to augment the EC by assisting in assessing the emergency condition, coordinating required resources, including public information interface.
However, the NRCs original intent for the Resource Manager was to provide radiological assistance to determine the radiological status of the ISFSI, as well as technical assistance in the form of engineering support to determine corrective actions, as needed.
Request: Please describe how the CR-3 ISFSI Shift Supervisor/EC has the knowledge, skills, and ability to determine the radiological status, as well as the technical status, during an event at the ISFSI to determine protective actions and corrective actions, as needed.
Ltr ML21182A103 NMSS/DUWP OFFICE NSIR/DPR/RLB OEDO NMSS/DUWP/RDB
/LLWPB NAME MDoell MD MNorris MN JQuichocho JQ BWatson BW DATE Jul 1, 2021 Jul 6, 2021 Jul 6, 2021 Jul 6, 2021 NMSS/DUWP OFFICE
/LLWPB NAME MDoell MD DATE Jul 6, 2021