ML23173A152
| ML23173A152 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Point Beach, Seabrook, Turkey Point  |
| Issue date: | 06/22/2023 |
| From: | Justin Poole Plant Licensing Branch 1 |
| To: | Phillabaum J NextEra Energy |
| Poole J | |
| References | |
| EPID L-2022-LLA-0146 | |
| Download: ML23173A152 (34) | |
Text
From: Justin Poole (He/Him)
To: Phillabaum, Jerry Cc: Hipo Gonzalez
Subject:
Request for Additional Information RE: Fleet Emergency Plan Amendment Request Date: Thursday, June 22, 2023 1:41:00 PM Attachments: L-2022-LLA-0146 RAI Questions.pdf
- Jerry, By letter dated October 4, 2022, as supplemented by letter dated December 9, 2022 (Agencywide Documents Access and Management System Accession (ADAMS) Nos.
ML22278A031 and ML22343A254, respectively), Florida Power & Light Company, NextEra Energy Point Beach, LLC, and NextEra Energy Seabrook, LLC (collectively, NextEra or the licensee), submitted a license amendment request (LAR) for Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station, Unit No. 1; St. Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4, to the U.S. Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, the proposed license amendment request would create a new fleet common emergency plan with site-specific annexes developed utilizing NUREG 0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support Nuclear Power Plants, Revision 2 dated December 2019 (ML19347D139), (NUREG-0654). In reviewing the submitted information, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is necessary to complete its review.
On May 3, 2023, the NRC staff sent the licensee DRAFT RAIs to ensure that the questions are understandable, the regulatory basis is clear, there is no proprietary information contained in the RAIs, and to determine if the information was previously docketed. On June 7, 8, and 12, 2023, the NRC and the licensee held clarification calls. The reason for multiple calls was due to the number of RAIs. During the calls, it was decided, for clarity, that the NRC staff would specify for each question whether that question pertained to all sites or if the question was site specific. In addition, portions RAIs 45 and 50 were re-worded to ensure clarity of what the NRC staff is requesting. During the call the licensee requested a response date of 45 days from the date of this email. The NRC staff informed the licensee that this timeframe is acceptable. The attached is the final version of the RAIs. These RAIs will be put in ADAMS as a publicly available document.
Justin C. Poole Project Manager FitzPatrick/Seabrook/NextEra Fleet NRR/DORL/LPL I U.S. Nuclear Regulatory Commission (301)415-2048
REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLANS FLORIDA POWER & LIGHT COMPANY NEXTERA ENERGY POINT BEACH, LLC NEXTERA ENERGY SEABROOK, LLC POINT BEACH NUCLEAR PLANT SEABROOK STATION UNIT 1 ST. LUCIE NUCLEAR PLANT TURKEY POINT NUCLEAR GENERATING PLANT DOCKET NOS. 50-250, 50-251, 50-266, 50-301, 50-335, 50-389, AND 50-443 By application dated October 4, 2022, as supplemented by letter dated December 9, 2022 (Agencywide Documents Access and Management System Accession (ADAMS)
Nos. ML22278A031 and ML22343A254, respectively), Florida Power & Light Company, NextEra Energy Point Beach, LLC, and NextEra Energy Seabrook, LLC (collectively, NextEra or the licensee), submitted a license amendment request (LAR)for Point Beach Nuclear Plant, Units 1 and 2; Seabrook Station, Unit No. 1; St. Lucie Plant, Unit Nos. 1 and 2; and Turkey Point Nuclear Generating Unit Nos. 3 and 4, to the U.S. Nuclear Regulatory Commission (NRC) for review and prior approval pursuant to Section 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). Specifically, the proposed license amendment request would create a new fleet common emergency plan with site-specific annexes developed utilizing NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support Nuclear Power Plants, Revision 2 dated December 2019 (ML19347D139), (NUREG-0654). The proposed fleet common emergency plan is referred to as the NextEra Common Emergency Plan.
The following requests for additional information (RAI) is needed for the NRC staff to complete its review.
Command and Control Function Section 3.3.1, Site Emergency Director at 90 minutes, of the LAR enclosure, Evaluation of Proposed Changes, states:
Per the guidance in NUREG-0654, Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, an augmented Senior Manager should fulfill the Emergency Operations Facility Director major task at 60 minutes.
However, Section 2.2.1, [Potential RIE 2-1] Site Emergency Director at 90 Minutes, of the LAR supplement states, The proposed emergency plan adds 30 minutes to the augmentation response time for the Site Emergency Director minimum staff ERO position that performs the Command-and-Control function.
The justification for the additional 30 minutes response time provided in Section 2.2.1 states, There are no unique skills nor capabilities present in this position that are critical to site response that cannot be mitigated by shift staff in adjusting the response from 60 to 90 minutes.
Issue: The NextEra LAR does not provide an individual to relieve the Shift Manager of either the Shift Manager function or the Emergency Direction function within 60 minutes of an alert or higher declaration nor does it provide sufficient justification to support the deviation from NUREG-0654 guidance.
Request: Concerning Command and Control:
Section 3.3.1, Site Emergency Director at 90 minutes, of each site-specific LAR enclosure, Evaluation of Proposed Changes, states:
The demonstration and evaluation of the Shift Manager to perform their emergency plan functions is continuously evaluated during emergency planning drills/exercises and operations training simulator sessions.
This section further states, Licensed Operator Continuing (LOR) training periodically has scenarios that extend to 90 minutes without augmented ERO involvement.
Issue: The proposed NextEra Common Emergency Plan includes 20 emergency plan responsibilities for the shift manager. No evidence was provided that the shift manager responsibilities are demonstrated and/or evaluated for 60 minutes after an alert or greater declaration.
Request: Provide objective evidence that LOR simulator training scenarios evaluated the performance of all shift manager ERO tasks as identified in the proposed NextEra Common Emergency Plan. This evidence should demonstrate successful performance of these tasks for 90 minutes or more following an alert or higher declaration.
Requirement:
It is not clear that an SRO would be available to provide oversight for each nuclear power unit in addition to the shift manager.
Request: For the proposed NextEra Common Emergency Plan, clarify how Turkey Point will ensure that an SRO will be available for each operating unit with an additional SRO available to perform the command-and-control function. [this RAI is specific to Turkey Point]
Communications Function Section 2.2.3, [Potential RIE 2-3] ORO Communicator at 90 Minutes, of the LAR supplement states:
If the offsite agency needs additional information, as discussed above, the control room can provide the information that is needed with minimum burden to the on-shift staff.
The justification for the additional 30 minutes response time provided in Section 3.3.3, ORO
[offsite response organization] Communicator at 90 minutes, of the LAR states:
The augmentation (relief) of this position should occur within 60-minutes of an Alert ECL, or greater, and is intended to relieve the on-shift staff of this EP function. This function should consist of 2 staff members to fulfill the communication needs, at a minimum: 1 for the NRC and 1 for ORO notification and status updates. Additional communicators may be called upon as needed, and at the discretion of the licensee.
This section further states, To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and] maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan.
Section 3.3.1.1, Emergency Plan Change Assessment, of the LAR states:
The proposed emergency plan assigns a Shift Communicator (typically the Shift Manager) to fill the Communications function, as a collateral duty.
Issue: The proposed NextEra Common Emergency Plan would rely on one on-shift communicator who could be assigned other tasks to perform the ORO and emergency notification system (ENS) communications.
Request: Concerning ORO and ENS communication, provide the following:
Section 2.2.4, [Potential RIE 2-4] ENS Communicator at 90 Minutes, of the LAR supplement states:
The shift communicator is able to communicate immediately, not to exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, with the NRC HOO to provide real time information and an open line if desired.
Section 3.3.4, ENS Communicator at 90 minutes, of the LAR states:
The augmentation (relief) of this position should occur within 60-minutes of an Alert ECL, or greater, and is intended to relieve the on-shift staff of this EP function. This function should consist of 2 staff members to fulfill the communication needs, at a minimum: 1 for the NRC and 1 for ORO notification and status updates. Additional communicators may be called upon as needed, and at the discretion of the licensee.
This section further states, To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and] maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan.
Issue: Section 3.3.1 Paragraph 1, Emergency Plan Change Assessment, of the LAR supplement states:
The proposed emergency plan assigns a Shift Communicator (typically the Shift Manager) to fill the Communications function, as a collateral duty.
The proposed NextEra Common Emergency Plan would rely on one on-shift communicator who could be assigned other tasks to perform the ORO and ENS communications.
Licensees are required by 10 CFR 50.72(c)(3) to maintain continuous communications with the NRC when requested. Licensees have a responsibility to provide enough on-shift personnel knowledgeable about plant operations and emergency plan implementation to enable timely, accurate, and reliable reporting of events without interfering with plant operation. The effectiveness of the NRC during an event depends in large measure on complete and accurate reports from licensees.
Request: Explain who will relieve the on-shift communicator of the ENS communication function within 60 minutes of an alert or higher declaration and how it meets NUREG-0654 guidance for the NRC communicator to not support the performance of collateral duties.
Issue: The application does not identify the ORO or the ENS [NRC] communicators on-shift to perform the communication functions. The NRC staff could not determine if there was sufficient
on-shift capability to perform the ORO and NRC communication functions. Note: this request focuses on on-shift capability.
Request: Concerning ORO and ENS communication:
Request: Clarify who will ensure ERDS operation within one hour of an alert or higher emergency classification. Note: because the proposed NextEra LAR would not provide ERO augmentation for 90 minutes, this function would rely on the on-shift staff. The clarification should include an evaluation regarding the availability and capability of the designated individual to perform this function. The NextEra Common Emergency Plan or Implementing Procedures should be updated to reflect these assignments.
Radiation Protection Function Section 3.2.4, On-shift RP Personnel Allowed Collateral Duties, of the LAR states:
The ability to provide radiological expertise when the plant is experiencing an event with serious radiological consequences is crucial, due to the unknown radiological environment faced by emergency workers, particularly at the onset of the event. This function should be staffed by 2 qualified RP staff members on-shift (or 1 per unit for multi-unit sites). These staff members should not have any collateral duties during emergency response.
This section further states,
Consistent with NUREG-0654 R2, the proposed emergency plan assigns the Dose Assessments /Projections [function] as a collateral duty. This emergency response collateral duty can be assigned to any on-shift individual qualified in Dose Assessment.
NUREG-0654, Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, note 1 states:
Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. A 10 CFR Part 50, Appendix E on-shift staffing analysis must be performed to support assignment of multiple roles to individual responders on-shift. For augmented ERO positions, a performance-based approach is acceptable for evaluating whether augmented personnel can adequately perform collateral functions without having competing priorities.
Issue: The NextEra LAR does not include an evaluation based on analysis or evaluation that demonstrates how an RP technician can concurrently perform dose assessment and RP functions. Additionally, as stated in the NextEra LAR, RP staff should not have any collateral duties during emergency response.
Request: Provide objective evidence of how an on-shift RP technician can concurrently perform dose assessment and RP functions.
Section 3.2.4, On-shift RP Personnel Allowed Collateral Duties, of the LAR states:
Personnel who are not ANSI qualified RPTs, such as an appropriately trained and qualified operator or a chemistry technician, may be assigned to the dedicated on-shift RPQI [radiation protection qualified individual] position. When the RPQI position is not filled by a qualified ANSI RPT, they cannot be given time sensitive or other tasks during emergency response that interfere with the Radiation Protection function.
Table B-1, On-Shift and Augmenting ERO Staffing Plan, of the proposed NextEra Common Emergency Plan provides one RP technician and one RP qualified individual with augmentation by three RP technicians and two RP qualified individuals responding within 90 minutes of an alert or greater classification.
Issue: Based on the above, the NextEra LAR, as supplemented, would provide one qualified RP technician for 90 minutes after an alert or greater classification.
Request: Explain what NextEra design features or capabilities, that are unique to NextEra facilities, that justify reliance on a single qualified radiation protection technician to perform all required RP functions for 90 minutes after the declaration of a radiological event or provide sufficient justification for the proposed deviation from the guidance of NUREG-0654.
Section 3.2.5, Fewer OSC Response Personnel, of the LAR states:
NextEra controls the qualification of the ERO as outlined in 10 CFR 50.47(b)(15).
To ensure that qualifications are consistent throughout the fleet, the RPQI qualification requirements are maintained in Section O of the proposed emergency plan. The RPQI ERO personnel will be task qualified to the tasks listed in NUREG-0654 Revision 2 Table B-[1] (shown above).
This section further states, This approach meets the intent of 50.47(b)(15) and allows the Systematic Approach to Training (SAT) process to determine and control the RPQI qualification requirements by task. The proposed emergency plan will utilize the SAT process to set the qualification requirements of the RPQI, independent of an ANSI 8.1 standard, while ensuring that all personnel are trained to be able to respond to an emergency - not to be a day-to-day RPT.
Issue: The proposed ERO qualifications for RPQI ERO personnel in the NextEra Common Emergency Plan does not meet the systematic approach to training for radiation protection technicians pursuant to 10 CFR 50.120, Training and qualification of nuclear power plant personnel. The LAR references tasks that are not part of a program that is subject to the SAT requirements of 10 CFR 50.120. The LAR also refers to NUREG-0654, Revision 2, Table B-1 tasks that would be performed by radiation protection technicians qualified under 50.120 and not by task qualified individuals.
Request: Provide a discussion of how RPQIs will be qualified as RP Technicians in addition to training on the tasks listed on NUREG-0654, Table B-1.
Section 3.2.5, Fewer OSC Response Personnel, of the LAR states:
Even with a SG [steam generator] tube rupture using the main condenser as the cooldown medium, the turbine buildings will not be unmanageable with the responders as the major steps of each sites emergency operating procedures for a SG tube rupture will have completed their major functions of identify - isolate -
cooldown - depressurize - terminate safety injection are expected to be complete prior to ERO arrival. All temperature control steps later in the procedures where the ERO may be present will be minimal temperature control steps which send minimal additional contaminated steam into the secondary systems. As the limiting accident that will expand radioactively controlled/
contaminated areas outside of the radiologically controlled area, there is no need to staff PWR [pressurized water reactor] sites at the same level outlined in the NUREG, which factored in BWR [boiling water reactor] designs into their calculations for staffing levels.
The NextEra LAR states in the above justification, these steps, are expected to be complete prior to ERO arrival.
Request: Provide clarification that addresses the following:
Section 3.3.6, Radiation Protection Personnel at 90 Minutes, of the LAR states:
While not all Alert ECLs (or lower) have radiological consequences, licensees should develop their ERO staffing plans for a worst-case scenario from a radiological risk perspective, i.e., an event which results in the immediate (within 60-minutes) loss of 2 or more fission product barriers leading to significant and unknown radiological conditions. The augmentation (support) of this position should occur in two stages: within 60 minutes of an Alert ECL or greater, 3 additional qualified RP staff should be available, and within 90 minutes of an Alert ECL, or greater, an additional 3 additional qualified RP staff should be available, and both are typically staffed in the OSC.
This section further states:
Radiation protection personnel perform multiple roles during normal and emergency plant operations. These roles include access control, personnel monitoring, and dosimetry, in addition to HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting during emergency response operations. Per the guidance in Table B-1 of NUREG-0654, there should be two augmented responders at 60 minutes for the major task of Radiation Protection.
To adequately support an extension in response timing of the radiation protection 60-minute responders to 90 minutes, the licensee should show that the on-shift HP staffing includes as a minimum, four HP technicians in total for the site. The extra HP technicians are needed for in-plant protective actions for the other personnel added to the on-shift staffing to compensate for the extension in augmentation time, and to assess any offsite releases of radioactive materials.
Issue: The NextEra LAR, does not provide sufficient information for the NRC staff to conclude that one qualified RP technician could perform the RP tasks described by in the LAR for 90 minutes following an alert or higher declaration.
Request: For the RP technician, provide the following:
Section 3.3.6, Radiation Protections Personnel at 90 Minutes, of the LAR states:
Due to the availability of FLEX equipment, NextEra stations have diverse protection against loss of ECCS capability and other systems, which provides a basis for determination that no immediate ECCS repair and corrective actions are likely necessary for on-shift personnel prior to augmentation of maintenance personnel.
This section further states:
By accounting for FLEX equipment and strategies that eliminate or prolong the onset of core damage and any radiological release of activity the RP challenges are simplified and the need for a 60-minute radiation protection personnel response is diminished.
Issue: The FLEX strategy, as codified by 10 CFR 50.155, provides mitigation strategies for beyond design basis external events and for mitigation strategies for a loss of large areas of the plant impacted by the event, due to explosions or fire. The NextEra LAR does not provide sufficient information that FLEX equipment provides a basis supporting the NextEra determination that no immediate ECCS repair and corrective actions are likely necessary for on-shift personnel prior to augmentation of maintenance personnel for a broad spectrum of events.
Request: Provide the following clarifications regarding the NextEra FLEX strategy:
Section 3.3.6, Radiation Protections Personnel at 90 Minutes, of the LAR states:
The NEI 12-01 based staffing analysis performed for using the proposed emergency plan on-shift ERO identified no task overlap or overburden of the Radiation Protection function out to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> for design basis and other ER related events.
NEI 12-01, Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, describes the assessments that will determine the required staff necessary for responding to external events. Additionally, NEI 12-01 assumes that a hostile action does not occur during the period that the site is responding to the event. Because NEI 12-01 is limited to external events and assumes that a hostile action, NEI 12-01 is insufficient to justify extending or eliminating ERO augmentation positions. Additionally,
10 CFR 50.155 withdrew the orders and removed license conditions that were, in part, the basis for NEI 12-01.
Request: Provide a regulatory or technical basis for using NEI 12-01 to extend or eliminate ERO augmentation positions. Include in your discussion how the basis specifically addresses how a 6-hour augmentation is consistent with the 10 CFR 40.47(b)(2) requirement for timely augmentation.
Section 3.3.6, Radiation Protections Personnel at 90 Minutes, of the LAR states:
The NEI 10-05 based On-shift Staffing Analysis performed using the proposed emergency plan on-shift ERO identified no task overlap or overburden of the Radiation Protection function out to 120 minutes for design basis and other ER related events.
Issue: The scope of tasks evaluated pursuant to NEI 10-05 is limited to the immediate actions performed by the on-shift staff. NEI 10-05 does not evaluate any tasks specifically performed by the augmenting ERO. Because NEI 10-05 is does not include the tasks performed by the augmenting ERO, NEI 10-05 does not provide a justification for extending or eliminated ERO augmentation positions.
Request: Provide a regulatory or technical basis for using NEI 10-05 to extend or eliminate ERO augmentation positions. Include in your discussion how this basis specifically address how a 2-hour augmentation is consistent with the 10 CFR 40.47(b)(2) requirement for timely augmentation.
Issue: The LAR does not provide sufficient information supporting assigning all ERO responsibilities to a single individual for conditions that may warrant a SAE or higher of a declaration even when a classification advisor is available.
Request: For SAE or higher declarations, provide objective evidence supporting the performance of all site emergency director functions are able to be performed without delay or conflict.
Supervision of Radiation Protection Staff and Site Radiation Protection Function Section 3.2.7, No OSC RP Supervisor Position, of the LAR states:
The Lead OSC Supervisor is assigned the RP aspect of the Supervision of Repair Team Activities. To ensure that Lead OSC Supervisor position can perform the RP supervision sub-function, their ERO training / qualification program will include previous RP Supervisor experience or will receive training to supervise RP emergency response tasks. See Section O of the proposed emergency plan for the description of the qualification of the Lead OSC Supervisor.
Section O of the proposed NextEra Common Emergency Plan states:
The lead OSC supervisor is trained to perform RP supervisory tasks. [No further detail is apparent.]
Issue: The NextEra LAR does not provide sufficient information for the NRC staff to conclude that previous experience or training to perform RP supervisory tasks would ensure that the lead OSC supervisor would be qualified and proficient to perform the RP supervision function.
Additionally, the LAR does not provide objective evidence that the OSC supervisor could concurrently perform the lead OSC supervisor and RP supervisor functions.
Request: Provide the following clarifications regarding the OSC RP supervisor:
Section 3.3.5, TSC RP Coordinator at 90 Minutes, of the LAR states:
This function is important for effective emergency response to a radiological event because the management of RP resources, and the assistance this position provides the Emergency Coordinator, is crucial for response to radiological events. Radiological events can be very significant and constantly evolving and require significant expertise in radiation and radiological consequences. The evaluation of radiological events, and the development of effective protective action recommendations, requires this expertise to support the Emergency Coordinator in making these decisions. This position is also responsible for the direction and protection of FMTs. The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC.
Additionally, Section 2.2.5, TSC RP Coordinator at 90 Minutes, of the supplement states:
The AOP/EOP procedure sets have specific guidance for direction and control of RP/QI resources during an event. The shift manager has the authority to provide immediate dose extensions for life saving, facility saving, or prevention/mitigation of release. This decision is informed by the rest of the operating crew and procedure sets.
And, Performing a comparative task analysis (refer to Analysis 1) between the Shift Manager and the Site RP Coordinator [SRPC], the tasks are same / similar between the SM and SRPC. Where there is a gap is with experience. Experience cannot be mitigated with training as the knowledge requirements for the positions are same/ similar. Experience is mitigated through procedure use and adherence. As outlined above, all NEE [NextEra] sites have AOP/EOP sets that are based off most recent PWR Owners guidance which incorporates industry best practices, including RP direction.
Issue: The NextEra LAR does not provide sufficient information for the NRC staff to conclude that significant expertise in radiation and radiological consequences will be available within 60 minutes of and alert or higher declaration. The NextEra LAR does not provide sufficient information for the NRC staff to conclude based on similar emergency plan task descriptions for the shift manager and RP coordinator that experience cannot be mitigated with training as the knowledge requirements for the position are the same/similar and that experience is mitigated through procedure use and adherence. Additionally, it is not clear to the NRC staff how the decision to provide immediate dose extensions could be informed by the rest of the operating crew and procedure sets.
Request: Provide the following clarifications regarding the TSC RP coordinator:
Dose Assessment/Projection Function Issue: There is no designated on-shift individual available to perform the dose assessment function. The NRC staff could not determine if there was sufficient on-shift capability to perform the dose assessment function. Note: this focuses on on-shift capability of the dose assessment function and not on the timing of relief and augmentation.
Request: Concerning the dose assessment function, provide the following:
Request: Concerning the Dose Assessment function:
Request: Concerning the dose assessment function, provide the following:
Emergency Classification Function Request: Provide an evaluation through an analysis that the TSC classification advisor can perform all the functions identified in the NextEra Common Emergency Plan for the TSC
classification advisor without potentially delaying event classification and protective action recommendations.
Section 3.3.2, Classification Advisor at 90 minutes, of the LAR states, The augmentation (relief) of this function [classification advisor] should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC.
Maintaining the ability to perform this function at all times ensures that ECL decisions, and as applicable, the PAR decisions, are timely and accurate as these decisions have a direct relationship to public health and safety from the consequences of a radiological event. This function shall work in coordination with the OSM, or Emergency Coordinator, depending on which position is in command and control, and as a result should be available on shift and in the TSC.
Issue: The proposed NextEra LAR provided justification that could eliminate the on-shift classification advisor but did not provide a justification that supports either the extension or elimination of the classification advisor at the TSC.
Request: Provide objective evidence that establishing a 90-minute requirement for the TSC classification advisor would not impact the ability to perform the classification function at the TSC.
Engineering Function Issue: Section 3.4.2, On-Shift ERO Positions, of the LAR states that the STA and classification advisor functions are performed as collateral duties.
Request: Regarding on-shift ERO staffing:
Security Function Section 3.3.10, Security Liaison at 90 minutes, of the LAR states:
The licensees Security Force is controlled and maintained by the licensees NRC approved physical security plan and does not need to be reflected in the Emergency Plan. However, the establishment of a Security Liaison position in the TSC is advantageous to ensure effective coordination between the security force and the ERO, particularly for events where offsite resources are necessary as well as for security related events and site personnel accountability. The augmentation (support) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed by a Security Liaison in the TSC to coordinate security-related activities with that of the ERO.
This section further states:
The Security Liaison position provides communication and coordination resources that are not needed until the TSC and OSC are augmented at the 90-minute point in time.
NUREG-0654 provide guidance for a Security Liaison to respond within 60 minutes of an alert or greater declaration.
Issue: Security related events and events where offsite resources are necessary could occur within 60 minutes of an alert or greater classification. The proposed changes to TSC and OSC staffing times described in the LAR does not justify the proposed adjustment of the security liaison augmentation time from 60 to 90 minutes.
Request: Provide objective evidence that the Security Liaison will not be required for 90 minutes. Your discussion should address security related conditions that could require offsite resources, coordination, or personnel accountability within 60 minutes of an alert or higher declaration.
Repair Teams Activities Function Section 3.3.9, OSC Craft at 90 minutes, of the LAR states:
Due to the availability of FLEX equipment, NextEra stations have diverse protection against loss of ECCS capability and other systems, which provides a basis for determination that no immediate ECCS repair and corrective actions are likely necessary for on-shift personnel prior to augmentation of maintenance personnel.
This section further states:
By accounting for FLEX equipment and strategies that eliminate or prolong the onset of core damage and any radiological release of activity the RP challenges are simplified and the need for a 60-minute radiation protection personnel response is diminished.
The FLEX strategy, as codified by 10 CFR 50.155, provides mitigation strategies for beyond design basis external events and for mitigation strategies for a loss of large areas of the plant impacted by the event, due to explosions or fire.
Issue: The NextEra LAR does not provide sufficient information that the use of FLEX equipment provides a basis supporting the NextEra determination that no immediate ECCS repair and corrective actions are likely necessary for on-shift personnel prior to augmentation of maintenance personnel for a broad spectrum of events.
Request: Provide the following clarifications regarding the NextEra FLEX strategy:
Supervision of Repair Teams Activities Function Section 3.2.8, Single Craft Supervisor Position, of the LAR states, An Electrical Supervisor, a Mechanical Supervisor, and an I&C Supervisor should be staffed within 90-minutes of an SAE ECL, or greater, and is typically staffed in the OSC. The OSC Supervisor can effectively manage the craft
[personnel] resources for the additional 30-minutes prior to the [supervisory]
respond, as demonstrated through drills and exercises, without compromising the staffs reasonable assurance finding in accordance with 10 CFR 50.47(a).
This section further states:
The position of FIN Supervisor is filled by management and supervisory personnel from the Maintenance Department who are familiar with direction of all disciplines within the department.
Issue: The NextEra LAR does not provide sufficient information that the lead OSC supervisor would be qualified and proficient to manage multiple maintenance disciplines at all NextEra facilities.
Request: Concerning the proposed FIN supervisor:
Field Monitoring Teams Function Section 3.2.6, No On-site Field Monitoring Team, of the LAR states:
The ability to locate, monitor, and track a radioactive plume is important to ensure appropriate protective measures are taken in response to a radiological event. The ability to staff these teams before they may be needed (i.e., before a radiological release) greatly enhances the ability of the licensee to provide timely and accurate PARs.
This section further states, Based upon NRC guidance two Field Monitoring Teams are sufficient to monitor radiological conditions after a SAE is declared. By not designating onsite and offsite FMTs, a total of two FMTs can sufficiently provide radiological monitoring at NextEra stations under all conditions.
Issue: The proposed NextEra Common Emergency Plan does not provide the capability to perform on-site field monitoring within 60 minutes of an alert or higher declaration.
Request: Provide objective evidence that NextEra facilities can assess the protected area for radiation and contamination during radiological events within 60 minutes of an alert or higher declaration.
Section 3.2.6, No On-site Field Monitoring Team, of the LAR states:
For NextEra stations, two Field Monitoring Teams are sufficient to perform on-site and off-site field monitoring activities. All NextEra sites are located on major bodies of water (their EPZs being approximately 40% water or greater) with no requirements nor capabilities for monitoring activities on these bodies of water.
As each sites EPZ is ~40+% water, there is not as much area to cover for the field monitoring teams. With NextEra EPZs being effectively smaller than landlocked sites, less personnel are needed to cover an effectively smaller EPZ.
Issue: The NextEra LAR states that the NextEra EPZs are effectively smaller than landlocked sites which require less personnel to cover the smaller EPZ.
Request: Provide clarification regarding the effectively smaller EPZ and NextEra sites. The clarification should address the following:
Section 3.2.6, No On-site Field Monitoring Team, of the LAR states:
Based upon NRC guidance two Field Monitoring Teams are sufficient to monitor radiological conditions after a SAE [site area emergency] is declared.
NUREG-0654 describes that one onsite field monitoring team (FMT) and one offsite FMT will be available within 60 minutes of alert or greater classification.
Issue: The LAR provides field monitoring team (FMT) augmentation following a site area emergency or greater classification that is not consistent with NUREG-0654 guidance that follows an alert or greater classification.
Request: Provide the following clarifications regarding FMT augmentation.
Media Information Function
Request: Provide the following for St. Lucie and Turkey point only:
Information Technology Function Section 3.2.9, No IT [information technology] Technician ERO Positions, of the LAR states:
Per NUREG-0654 R2, minimum staff ERO IT positions are only required to be described in the emergency plan if critical digital assets (CDAs) are identified per 10 CFR 73.54, Protection of digital computer and communication systems and networks. The proposed emergency plan relies on PI ProcessBook for monitoring plant parameters, which has been determined to be a CDA.
This section further states, Each of the EP related digital assets were evaluated as part of implementation of the Cyber Security Rule, 10 CFR 73.54(b). Under NEI 13-10, "Cyber Security Control Assessments," EP Critical Digital Assets have been assessed and controls have been put in place to protect the assets against cyber-attack. In conjunction with these controls, alternate administrative, non-digital, or adequately independent means have been put in place for performing each EP function, should the digital component or program fail.
Issue: The proposed NextEra Common Emergency Plan would rely on remote dose assessment and engineering. It is not clear whether the proposed changes were assessed as an EP critical digital asset.
Request: Provide a clarification that remote dose assessment and engineering were assessed as potential EP critical digital assets or provide objective evidence that demonstrates this assessment is not necessary.
Remote ERO Augmentation Section 3.8.1 of the LAR states:
ERO members responding remotely to an emergency are capable of performing all functions and tasks assigned to their positions, including support provided to other ERO members, as described in the emergency plan and implementing procedures. These positions support the on-shift staff prior to activation of the TSC and EOF.
Line 100 of Analysis 4 of the LAR supplement states:
The remote positions (Remote Dose Assessor and engineers) report to the Shift Manager until their associated response facility is activated.
The current ERO augmented dose response for NextEra sites include multiple individuals at a single facility. In addition to a dose assessor and an RP supervisor, the facilities include technical and communications personnel that provide appropriate plant and core status information to the dose assessor. NextEra proposes that the dose assessor and reactor engineer would provide augmentation remotely within 60 minutes of an alert or greater classification. The proposed NextEra Common Emergency Plan would have the supporting facility staff within 90 minutes of an alert or greater classification.
Issue: This LAR, as supplemented, would require the dose assessor and reactor engineer to rely on the control room staff for discussions related to the development of an accurate and timely dose assessment.
Request: Concerning remote dose assessment:
Section 3.8.1 of the of the LAR states that the following key considerations were evaluated when determining the remote ERO response positions and capability:
Additionally, this section states:
If all else fails, personnel would respond to the NextEra corporate or station location/facility to perform the function remotely.
Although the LAR states that key considerations were evaluated, the LAR provides high level summary statement regarding the desired state without providing an objective evaluation based an analysis that supports the proposed changes.
Issue: Because dose assessment relies on timely and accurate plant information, event progression information, and communicating the results of dose assessment, a failure of any of these elements could impact the ability of dose assessment. It is not clear what NextEra facility (corporate, or site location) would be available to perform the function remotely. Finally, there was no evaluation of how much time it will take to respond to these alternate facilities nor is it clear whether these facilities would provide the appropriate capability to support the dose assessment function.
Request: Concerning remote dose assessment:
Section 3.8.1 of the LAR states that the SAT process will be used to determine the initial and continuing training requirements. The training analysis will not be limited of focused on the remote ERO responders but also address the ERO responders interfacing with the remote responders.
Issue: Although the LAR states provides an approach to training that appears thorough, no details were provided that demonstrate that any training would be required to support remote ERO implementation.
Request: For remote dose assessment, provide the following:
Section 3.8.1 of the LAR states:
The following areas are examples which could be applicable based upon the remote EROs responsibilities and task performance results:
Issue: It was not clear to the NRC staff whether the LAR is asking to approve remote augmentation of classification of events, development of PARs, and assessment of offsite consequences in addition to the requested remote ERO augmentation for dose assessment and system engineering.
Request: provide the following:
Section 3.8.1, Added Allowance for Remote Response of Engineering and Dose Assessment Function, proposed remote response for the reactor engineer, mechanical engineer, electrical engineer, and the dose assessor.
Section 3.8.1 of the LAR states:
ERO members responding remotely to an emergency are capable of performing all functions and tasks assigned to their positions, including support provided to other ERO members, as described in the emergency plan and implementing procedures. These positions support the on-shift staff prior to activation of the TSC and EOF.
Issue: The current NextEra augmented dose response includes multiple individuals at a single facility. In addition to a dose assessor and an RP supervisor, the facilities include technical and communications personnel that provide appropriate plant and core status information to the dose assessor. NextEra proposes that the dose assessor and reactor engineer would provide augmentation remotely within 60 minutes of an alert or greater classification. The proposed
NextEra Common Emergency Plan would have the supporting facility staff within 90 minutes of an alert or greater classification.
Request: Concerning remote dose assessment:
Issue: In the LAR, as supplemented, the proposed NextEra Common Emergency Plan includes remote joint information system (JIS) staff within 60 minutes of an alert or greater classification.
Other than the inclusion of this remote augmentation position in the NextEra Common Emergency Plan, no additional justification was apparent. The proposed NextEra Common Emergency Plan does not include dedicated on-shift communicators or a site emergency director for 90 minutes.
Request: Explain how the media information function can be completed remotely by a single individual. Your discussion should describe how the JIS individual would obtain the appropriate information without burdening the shift manager as well as describing how the JIS remote responder would communicate the information as needed.
Issue: Table B-1, On-Shift and Augmenting ERO Staffing Plan, of the LAR includes a note stating that JIC/JIS staff to address media inquiries does not need to be performed in the joint information center (JIC), but the joint information system function needs to be established at this point. This note is not consistent with the note in NUREG-0654 stating the JIC/JIS staff does not need to be in the TSC/OSC.
Request: Provide the following for the Media Information function:
Other Section 3.1, Technical Advancements and Program Enhancements of the LAR states:
These improvements collectively support the overall conclusion that there would be no degradation or loss of function resulting from the proposed [NextEra site]
Issue: In the LAR, as supplemented, NextEra provided a list of improvements but did not provide objective evidence supporting a substantial increase in emergency response organization response time. Because NUREG-0654 was issued in December of 2019, all the listed improvements identified in the LAR, except for FLEX strategies, were in place when Table B-1, Minimum On-Shift and Augmented Staffing, (Table B-1) was issued. The deviation justification provided by NextEra consist of broad summary statements that describe the proposed changes but do not provide objective evidence that supports the NextEra statement of no degradation.
Request: Provide a supporting analysis or other objective evidence that justifies the NextEra conclusion that there would be no degradation or loss of function when ERO augmentation response time is increased from 60 minutes to 90 minutes.
Section 3.3, ERO Augmentation Analysis, for Point Beach states:
The ERO augmentation analysis concludes that the difference in times between the proposed common emergency plan 60- and 90-minute response criteria and the NUREG-0654 R2 [revision 2] 60- and 90-minute response criteria does not adversely delay turnover of responsibilities or negatively impact/overburden the ability of the on-shift personnel to perform operational actions or key functions.
This alternate staffing approach continues to maintain initial facility accident response in all key functional areas at all times and provides timely augmentation of response capabilities.
Issue: In the LAR, as supplemented, NextEra proposes a 90-minute ERO response time that is not consistent with NUREG-0654 Table B-1, Minimum On-Shift and Augmented Staffing, (Table B-1). Neither the section titled ERO Augmentation Analysis or any other section of the LAR provided an analysis of the tasks that would be performed by the augmenting ERO staff that could support the extension of ERO augmentation time. It was not clear to the NRC staff how extending ERO augmentation response times from 60 to 90 minutes did not adversely delay turnover of responsibilities.
Request: Provide a supporting analysis that supports the NextEra conclusion that extending ERO augmentation response time from 60 to 90 minutes does not delay turnover of responsibilities.
Issue: In the LAR, the responsibilities and staffing provided in Figure B.4, Interrelationship of Emergency Response Organizations, of the NextEra Common Emergency Plan are not consistent with the responsibilities and staffing of the proposed TSC and EOF.
Request: Provide clarification of the apparent differences between TSC and EOF interfaces between Figure B.4, Interrelationship of Emergency Response Organizations, and the ERO responsibilities described in the proposed NextEra Common Emergency Plan.
For Point Beach only, Section 3.6.2, Removed reference to previously available sound-powered communications system, the disposition section of the LAR for Point Beach states, Sound powered phone system was unofficially abandoned at the site and replaced with a handheld radio system. Operations staff are required to have access to the radio system.
Issue: It was not clear to the NRC staff that the sound powered phone system is currently functional. Additionally, no information was provided indicating that the radio system provides equivalent communications capability as the sound-powered communications system.
Request: Concerning sound powered phone system:
Request: Provide a clarification for Point Beach auxiliary operator staffing that demonstrates sufficient auxiliary operators are available to perform plant operation support as required by the Point Beach technical specifications concurrent with meeting the requirements of the Point Beach fire protection plan.
NUREG-0654,Section I.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: Sections E, Notification Methods and Procedures, of the site-specific annexes do not provide enough information to meet Evaluation Criteria E.2.
Request: Provide additional information that meets Evaluation Criteria E.2. This should include description of primary and backup methods, and the organizations or titles/positions responsible for activating the system.
Sections E, Notification Methods and Procedures, of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states in part, In conjunction with OROs, NextEra sites have established the content of the follow-up messages, which will include additional information regarding event conditions and response actions.
Issue: There is no description of the content of the follow-up messages in the NextEra Common Plan, nor any of the site-specific annexes.
Request: Provide a description of the content of the messages in the NextEra Common Plan, and in the site-specific annexes. Or, provide a justification for not addressing all of the evaluation criteria with respect to content of the follow-up notifications.
Issue: Section F, Emergency Communications, of Enclosure 9, EP-SBK-140, SBK [Seabrook]
Emergency Plan Annex, provides a summary of the communication networks.
The Seabrook site-specific annex does not have NRC Communications Channel(s) listed.
Request: Provide a discussion of NRC Communications Channel(s) in the Seabrook annex, consistent with the other site-specific annexes.
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a TSC is established, using current Federal guidance, from which nuclear power plant conditions are evaluated and mitigative actions are developed.
NUREG-0696, Functional Criteria for Emergency Response Facilities, provides guidance for the TSC.
Issue: Section H.1 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, Site specific details of the primary and backup TSC are described in the site annexes.
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 site-specific details in these site-specific annexes of the functional criteria in NUREG-0696 (i.e., size, structure, habitability, and instrumentation, data system equipment and power supplies) or provide a justification for not addressing all of the functional criteria in these site-specific annexes.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.3 states that a EOF [Emergency Operations Facility] is established, using current Federal guidance, from which nuclear power plant conditions are evaluated and mitigative actions are developed. NUREG-0696, Functional Criteria for Emergency Response Facilities, provides guidance for the EOF.
Issue: Section H.3 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, Site specific details of the EOF are described in the site annexes.
The site-specific details in these site-specific annexes do not address some of the functional criteria in NUREG-0696 (e.g., function, size, structure, habitability, instrumentation, data system equipment and power supplies, etc.).
Request: Provide site-specific details in these site-specific annexes to address the functional criteria in NUREG-0696 (e.g., function, size, structure, habitability, instrumentation, data system equipment and power supplies, etc.). Or, provide a justification for not addressing all of the functional criteria in these site-specific annexes.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.4 states that an alternative facility (or facilities) is established, using currently provided and/or endorsed guidance, which would be accessible even if the NPP site is under threat of or experiencing hostile action.
Issue: Section H.4 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, The alternative facility can communicate with the Control Room, site security, and EOF.
The functions of offsite notification and PARs can be performed from the Alternative Facility. Emergency response team planning and preparation can be performed from the Alternative Facility.
The NextEra Common Emergency Plan does not address the capability for engineering assessment activities at an alternate facility (or facilities).
Request: Provide justification for not addressing the regulatory requirements or describe the process for providing engineering assessment activities at an alternative facility (or facilities).
NUREG-0654,Section II.H, Evaluation Criterion H.1 states that a TSC is established, using current Federal guidance, from which nuclear power plant conditions are evaluated and mitigative actions are developed. NUREG-0696, Functional Criteria for Emergency Response Facilities, provides guidance for the EOF.
Issue: Section H.1 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, TSC has the capability to support the remote response of the ERO engineering positions.
This statement is requesting NRC approval for the use of generic remote ERO positions in the TSC.
Request: Provide a clarification on the purpose of this statement and provide a justification for the use of generic remote ERO positions in the TSC.
Requirement:
NUREG-0654,Section II.H, Evaluation Criterion H.3 states that a EOF [Emergency Operations Facility] is established, using current Federal guidance, from which nuclear power plant conditions are evaluated and mitigative actions are developed. NUREG-0696, Functional Criteria for Emergency Response Facilities, provides guidance for the EOF.
Issue: Section H.3 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, The EOF has the capability to support the remote response of ERO positions.
This statement requests NRC approval for the use of generic remote ERO positions in the EOF.
Request: Provide clarification on the purpose of this statement and provide a justification for the use of generic remote ERO positions in the EOF.
Requirement:
Issue: Section H.3 of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, Personnel qualified in dose assessment are available on shift, remotely, and in the EOF.
[emphasis added]
This statement requests NRC approval for the use of generic remote ERO positions.
Request: Provide clarification on the purpose of this statement and provide a justification for the use of generic remote ERO positions.
Requirement:
NUREG-0654,Section II.N, Evaluation Criterion N.4.a states, Emergency medical drills are conducted annually. These drills involve a simulated, contaminated individual and contain provisions for participation by support services agencies (i.e., ambulance and offsite medical treatment facility).
Issue: Section N.4.a of Enclosure 5, EP-AA-100, NextEra Common Emergency Plan, states, Each NextEra site will conduct an onsite simulated medical drill once per calendar year.
The scope of the emergency medical drill will include a simulated on-site injured and contaminated individual and medical/ first aid treatment, including contamination control.
Emergency Medical Drill offsite participation and periodicity for support Hospital and Ambulance services are performed in accordance with the 42 CFR 482.15 regulations and are not included in the scope of the station medical drills.
The NRC staff requested an evaluation of this change by the Federal Emergency Management Agency (FEMA) in letter dated February 13, 2023 (ML23044A200). In a letter dated March 24, 2023 (ML23086A284) FEMA stated, This change proposes that Emergency Medical Drill offsite participation and periodicity for support Hospital and Ambulance services are performed in accordance with the 42 CFR 482.15 regulations. Hospitals are accredited by The Joint Commission in compliance with 42 CFR 482.15, which does not meet the minimum demonstration requirements for the ORO medical services drill. Joint Commission requirements for accreditation rules change frequently based on membership concerns. The Joint Commission currently does not have requirements for CBRN [chemical, biological, radiological and nuclear] related exercise. How will the ORO meet the demonstration standards for the FEMA REP Program assessment if only following Joint Commission standards?
Request:
and contain provisions for participation by support services agencies (i.e.,
ambulance and offsite medical treatment facility).