ML21182A103

Request for Additional Information (RAI) Related to the ISFSI-Only Emergency Plan

ML21182A103
Person / Time
Site:	Crystal River
Issue date:	07/06/2021
From:	Marlayna Vaaler Doell Reactor Decommissioning Branch
To:	Reid B ADP CR3
Doell M
References
EPID L-2021-LLA-0047
Download: ML21182A103 (8)

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