ML23044A200
| ML23044A200 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/2023 |
| From: | Jessie Quichocho NRC/NSIR/DPR/RLB |
| To: | Warnock T US Dept of Homeland Security, Federal Emergency Management Agency |
| References | |
| Download: ML23044A200 (4) | |
Text
Thomas K. Warnock, Branch Chief Radiological Emergency Preparedness Program National Preparedness Directorate Federal Emergency Management Agency 400 C Street, NW Washington, DC 20472
SUBJECT:
FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW REQUESTED OF REVISION TO THE NEXTERA SITE EMERGENCY PLANS
Dear Mr. Warnock:
By letter dated October 14, 2022, as supplemented by letter dated December 9, 2022 (Agencywide Documents Access and Management System Accession Nos. ML22278A031 and ML22343A254, respectively), Florida Power & Light Company (FPL), acting on behalf of itself and as agent for NextEra Energy Seabrook, LLC and NextEra Energy Point Beach, LLC, is submitting a request to change the emergency plan for each site to the U.S. Nuclear Regulatory Commission (NRC), in accordance with Section 50.54(q)(4) of Title 10 to the Code of Federal Regulations (10 CFR). Specifically, a new fleet Common Emergency Plan with site-specific annexes is proposed. In this submittal, FPL, NextEra Energy Seabrook, LLC, and NextEra Energy Point Beach, LLC are referred to collectively as NextEra), the proposed fleet Common Emergency Plan was developed utilizing NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (FEMA-REP-1). Refer to URL below to access the application and supplement.
https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22278A031 https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22343A254 NextEra states that the proposed changes to the emergency plans for each site would standardize the emergency plans across the fleet and will make program wide improvements by standardization of response organizations, duties and responsibilities, processes, procedures, and training. NextEra also will align the sites using consistent standards and definitions.
Section 3.7.2, [Potential RIE 6-2] Reduced Hospital and Ambulance Drill Participation and Periodicity of each sites enclosure, Evaluation of Proposed Changes, to NextEras application provides the licensees assessment of the proposed changes for the hospital and local ambulance drill participation and frequency. Based on the results of this assessment, NextEra concluded the following:
Therefore, the hospitals use an all-hazards approach to determine the community-risk and priorities of its emergency response preparation (training, drills, etc.) on the risk / priority. Maintaining the Contaminated Medical February 13, 2023
T. Warnock 2
Emergency Drill annual frequency, places a false priority /risk and circumvent the 42 CFR 482.15 community all-hazards regulations for the hospitals.
The 10 CFR Part 50 Appendix E and 10 CFR 50.47(b) regulations do not specify a frequency to perform the emergency medical drill. The annual frequency is specified in NUREG-0654 and provides the NRC approved guidance how to comply with the regulations. Licensees may voluntarily use the guidance in the document to demonstrate compliance with the NRC regulations or provide methods or solutions that differ from those described. The alternate method of basing the drill frequency on the ORO community-risk assessment is appropriate and meets the intent of the planning standards.
The change to the emergency medical drill scope retains the annual requirement for the station while allowing the hospital and ambulance service the ability to participate under and within their regulatory requirements. This should provide a commitment which the NRC can evaluate as an acceptable alternate method to comply with 10 CFR Part 50 Appendix E and 10 CFR 50.47(b) regulations.
NextEra further stated:
This drill participation arrangement was discussed with the OROs [offsite response organizations] (hospitals and ambulance providers) and their concurrence is documented in Enclosure 10. 0, Attachment 5, Offsite Response Organization Concurrence, provides copies of letters from each offsite response organization confirming the completion of their review of the proposed Common Emergency Plan and site-specific annexes.
Due to the extent of the proposed changes for the hospital and local ambulance drill participation and frequency, the NRC is requesting FEMAs review of the proposed licensee changes to verify that no potential adverse impacts exist that would preclude the effective implementation of the existing FEMA-approved State and local radiological emergency response plans and procedures.
Per the Memorandum of Understanding Between the Department of Homeland Security /
Federal Emergency Management Agency (FEMA) and NRC Regarding Radiological Response, Planning and Preparedness, dated December 7, 2015 (ADAMS Accession No. ML15344A371),
FEMA has responsibility for determining the adequacy of offsite radiological emergency plans and preparedness and providing its findings to the NRC. As such, I am requesting that FEMA provide its assessment to the NRC by no later than March 24, 2023, to support the NRCs continued technical review and final determination, and completion and issuance of the safety evaluation report approving the licensing action. Please contact me at your earliest opportunity if FEMA will not be able to meet this requested date for a response.
T. Warnock 3
As always, thank you for your assistance. If you have any questions regarding the changes proposed for the NextEra Common Emergency Plan and site-specific annexes, the NRCs evaluation of these proposed changes, or if FEMA will be unable to meet the requested due date of March 24, 2023, please contact Michael Norris at (301) 287-3754.
Sincerely, Jessie Quichocho, Branch Chief Reactor Licensing Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: C. Fiore, FEMA HQ Signed by Quichocho, Jessie on 02/13/23
Ltr ML23044A200 OFFICE NSIR/DPR/RLB NSIR/DPR/RLB NAME MNorris JQuichocho DATE Feb 13, 2023 Feb 13, 2023